Operational guideline: Dairy product inspection

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1.0 Purpose

The purpose of the document is to provide guidance to Canadian Food Inspection Agency (CFIA) inspection staff with procedure to verify that dairy products in Canada are safe, wholesome and meets the requirements of the Safe Food for Canadians Act and Regulations and the Food and Drugs Act and Regulations.

This document is intended to be used in conjunction with the Standard Inspection Procedures (SIP) and the Operational Guideline on General Principles of Sampling and the Operational Guideline on Net Quantity Verification.

The guidance outlined below may be used when verifying compliance of dairy product, to aid in the assessment of a Preventive Control Plan (PCP) related sub-element, as part of a food safety investigation or follow-up to a complaint.

2.0 Authorities

The inspection powers, control actions and enforcement actions authorized by the above legislation are identified and explained in the Operational guideline – Food regulatory response guidelines.

3.0 Reference documents

4.0 Definitions

Unless specified below, definitions are located in either the:

5.0 Acronyms

Acronyms are spelled out the first time they are used in this document and are consolidated in the Food business line acronyms list.

6.0 Operational procedure

6.1 Sampling

Please refer to the Operational guideline - General Principles for Sampling for sampling procedures that are common to all foods. Refer to the CFIA Sampling Information (internal access only) for details on sample unit size and frequency for sampling plans. The Inspector Toolkit in the SIP contains the list of equipment required for sampling and product inspection.

6.1.1 Sampling techniques for specific dairy products Bulk butter
  1. Place the butter in a place suitable for aseptic sampling.
  2. Remove the spatula from the sterile wrapping.
  3. Pull back liner into position for sampling and position spatula in the butter.
  4. Open a sterile, sealable sampling bag.
  5. Using the spatula, remove sample from the corner of the block of butter, as this location will give a more effective detection of surface yeast or mould.
  6. Place sample into the sterile sample bag.
  7. Seal the samping bag.
  8. Keep the samples cool by placing them in an insulated container.

Frozen bulk butter can also be sampled using a drill and a sterilized auger. Refer to the Operational procedures: Core Drilling Procedure for Sampling Food Product. (under development) Dry dairy powder

The sampling room must be clean, well-lit, and free from dust, odours, and excessive drafts. Do not sample in a damp storage room or where steam is discharged because dry milk absorbs moisture quite readily when exposed to the atmosphere even for a relatively short period of time.

Dry dairy powder packaged in bags
  1. Using a sterile sampling spoon, first discard or push to the sides, the surface portion of the powder to a depth of at least 15 mm.
  2. Collect the required sample size.
  3. Transfer the sample to the sterile composite sample bag. The same sterile spoon can be used to collect all sub-samples that are mixed to create a composite sample.
In-line sampling of dry dairy powder

Samples may be taken by the operator in-line during packaging. If this is the case, note on the sample submission form that samples were collected by in-line sampling by the operator. Bulk cheese

Cheese that is manufactured through a continuous process, and for which individual vats cannot be easily separated, will have the entire production run considered as one lot or batch.

Use a sterile cheese trier or knife with a pointed blade when sampling hard or semi-soft cheese in bulk. Use a sterile spatula to sample soft or cream cheeses.

Cheese samples covered with a crust, rind, or in a brine or curd form is sent to the lab as is. The lab will prepare the sample for analysis in its original form so that the analyses will reflect all the edible portions of the cheese. Ice cream and other frozen dairy desserts
If the container is 2 litres or less, send the whole container for analysis. If the container is larger than 2 litres, using aseptic techniques, scrape off the surface of the frozen dairy dessert with a spoon and collect the sample size specified in the sampling plan. Samples must be kept frozen.

6.2 Types of dairy product analysis

This section describes product analyses that are unique to dairy products.

6.2.1 Alkaline phosphatase

The alkaline phosphatase test can be used to verify pasteurization statements and/or product label claims. If the phosphatase test is deemed necessary, it is sampled under the National Microbiological Monitoring Program (NMMP). Inspectors should consult with their supervisor to determine if phosphatase testing is necessary. A positive result indicates that the product does not meet the pasteurization requirements as outlined in section B.08.002.2 of the FDR.

6.2.2 Domestic raw milk for chemical residues

The CFIA has Memorandum of Understandings (MOU) or agreements with some provinces to monitor chemical residues in raw milk. The province collects samples of raw milk from dairy farms and submits them to CFIA for analysis. It is important that sampling is done throughout the sampling period in order to represent normal conditions throughout the year.

Refer to Raw Milk Samples: Stability of Chemical Residues (internal access only - RDIMS 3553543) and Basic Guidelines for the Collection of Raw Milk Samples (internal access only - RDIMS 3147092) for current guidance from Science Branch.

6.2.3 Vitamin addition verification

Inspectors may need to verify that mandatory vitamin fortification and/or vitamin addition in the licensed establishments complies with the requirements of the FDA and FDR use the Industry guidance Dairy Processing Systems: Vitamin Addition. Dairy Processing Systems: Vitamin Addition.

Inspect milk products with Vitamin A, C and D additions.

The sample units for analysis should be selected with these considerations:

  • Select the most recent production available
  • Target any product that would be most adversely affected by the process such as skim milk as it would have the least naturally occurring vitamin A and therefore would give the best indication of the efficiency of the fortification system; for Vitamin D, it is best to take homogenized (whole) milk

Milk can still be analyzed if the sample unit has leaked so long as the leak remains contained in its plastic bag. Wrap individual containers in a double plastic bag. In addition, milk in cardboard cartons should be wrapped in paper towels prior to placing in plastic bags to absorb any condensation.

6.3 Cheese composition standards verification

Cheese manufactured at federally licenced dairy establishments are required to meet the compositional requirements of the SFCR and the FDR related to the content of casein derived from milk, partly skimmed milk, skimmed milk, ultra-filtered milk, ultra-filtered partly skimmed milk, ultra-filtered skimmed milk (fluid milks) and cream, collectively referred to as percentage casein derived from milks (%CDM). The requirements for casein content are found in FDR B.08.033(1).

This verification is not required for cheese produced using only fluid milks, and cream (no addition of powders, milk protein concentrate, whey protein concentrate, etc.). Compositional requirements of these cheeses will be verified during an Ingredient Verification.

The batch records should contain the following information:

  • date of production
  • vat number
  • type of cheese
  • formulation name/number or reference
  • quantity of milk, partly skimmed milk, skim milk and their ultra-filtered counterparts and cream used in the vat/batch
  • for each milk/cream used, the fat and protein content (if not available on the batch record, this information is to be provided by the company from plant lab testing results or Milk Marketing Board invoices)
  • final weight of cheese produced and, if available, its total protein content
  • % fat and % moisture of the cheese produced

The Cheese Composition Verification (internal access only - RDIMS 1768043) is an excel worksheet available for inspectors to record and perform calculations. The instructions to using this worksheet is in Appendix 1.

Satisfactory inspections

The cheese verification is considered satisfactory when the average %CDM value of the three vats/batches meets or exceeds the %CDM requirement for the cheese variety assessed.

Non satisfactory inspections

The cheese is considered non satisfactory if the overall average of the three lots/vats is under the minimum required %CDM.

6.4 Grade verification

Butter, cheddar cheese and dry dairy powders have grades designated in the Canadian Grade Compendium Volume 4 – Dairy Products. Application of grades is optional however when a grade is applied the establishment responsible to ensure that the claim on the package is correct. For inspection purposes, dry dairy powders are analyzed for grade in the laboratory, while cheddar cheese and butter are graded organolelptically by a qualified grader (provided by the licensed operator).

6.5 Determination of % solids for frozen dairy

The requirements for % solids and % solids from milk fat are found in the Canadian Standards of Identity Volume 1 Dairy. This method calculates the percentage of the weight of the product which can be attributed to the solids and fat, for comparison to the minimum requirements for certain frozen products. This method is used in place of a net quantity of frozen dairy products which would be accomplished by displacement, as frozen dairy is sold by volume not mass.

  1. Weigh the lot: 10 samples are selected and weighed. These samples should be taken from various places in the storage and/or skid so as to be as representative of the lot as possible. Calculate the average weight of the ten samples.
  2. Calculate the weight of the solids and fats

    1. Multilply the average weight of the lot by the actual % solids and % fat (from the plant records of a composition analysis), or
    2. Multiply the average weight of the lot by the minimum % solids and % fat permitted by the regulations.

    Two calculations are required:
    Total solids (g/l) = actual weight (g) × % solids
    Solids from fat (g/l) = actual weight (g) × % fat

  3. Determine whether the lot meets the minimum (and/or maximum) requirements of the products listed below. For the purpose of this methodology, there are two categories of frozen product:

    Plain: may have added flavours only. There is no particulate matter.

    Added: have added chocolate chips, syrups, flavoured ribbons, fruits, nuts, or other confections

    1. Ice Cream

      The minimum percent solids from fat for plain ice cream is 10%, and is 8% for added products.

      The table below indicates the minimum acceptable weights for solids and solids from fat.

      Container Size Min. weight of solids Plain
      Min. solids from fat
      Min. solids from fat
      500 ml 90 g 25 20
      1 L 180 g 50 40
      2 L 360 g 100 80
      4 L 720 g 200 160


      1 litre Vanilla Ice Cream with an average actual weight of 525 g, and using the minimum percentages of solids and fat

      Total solids = 525 g × 36% = 189 g/l
      Acceptable (minimum is 180 g from table)
      Solids from fat = 525 g × 10% = 52.5 g
      Acceptable (minimum is 50 g from table)

      The lot passes because it meets the minimum requirements for both total solids and solids from fat.

    2. Light Ice Cream

      There is only a minimum percentage total solids for both plain and added light ice cream (33%). There is both a minimum and maximum percentage for solids from fat which also depends on whether the product is plain or added light ice cream (> 5% to 7.5% plain / > 5% to 6% added)

      Plain (weight of solids from fat) Added (weight of solids from fat)
      Container size Min. weight of solids (g) Min. (g) Max. (g) Min. (g) Max. (g)
      500 ml 80 > 12.5 18.75 > 12.5 15
      1 L 160 > 25 37.5 > 25 30
      2 L 320 > 50 75 > 50 60
      4 L 640 > 100 150 > 100 120


      2 L of light chocolate ice cream (plain) with an average weight of 1025 g, using the minimum % soids and fat from the regulations.

      Total solids = 1020  g × 33% = 338.25 Acceptable (320 g from the table)

      Solids from fat = 1020 g × 5% = 51.25 Acceptable (50 g from table)

7.0 Appendices

For general inquiries related to this Operational Guidance Document, please follow established communication channels, including submitting an electronic Request for Action Form (e-RAF).

Appendix 1: Completing the cheese composition verification worksheet

Ingredients: List all milk, partly skimmed milk, skimmed milk and their ultra -filtered (UF) counterparts and cream used in column A of the worksheet. The last row of this column is kept for UF milk only due to programmed calculations in the Excel spreadsheet. UF milk, as defined in the DPR, means, milk, partly skimmed milk or skim milk that has been subjected to a process in which it is passed over one or more semi-permeable membranes to partially remove water, lactose, minerals and water-soluble vitamins without altering the whey protein to casein ratio and that results in a liquid product. The UF milk must meet this definition in order to be considered as part of the casein derived from milks.

Volume: Enter the quantity (in hL) for each ingredient in column A. To convert from litres, kgs, or lbs, see conversion factors in Appendix 2.

Fat concentration: Enter the fat concentration in kg/hL or % for each ingredient in column A. The fat concentration should be taken from the company’s inline analysis. If not available, lab tested values can be used. Values calculated from the Milk Marketing Board monthly invoices may be used if no other values are available. The values must represent each individual milk, not the final blend in the vat. (To convert inline analysis or lab tested values from kg/kg to kg/hl see Appendix 2).

Protein concentration: Enter the protein concentration for each ingredient in column A. The protein concentration should be taken from the company’s inline analysis. If not available, lab tested values can be used. Values calculated from the Milk Marketing Board monthly invoices may be used if other values are not available. For cream, see the table in this Appendix for protein values based on fat levels. The values must represent each individual milk, not the final blend in the vat. To convert lab tested values from kg/kg to kg/hl see Appendix 2.

Protein values for cream
% MF Protein (kg/hL or % milk)
0.5 Skim milk 3.5
10 3.166
12 3.095
15 2.990
18 2.884
20 2.814
30 2.462
31 2.427
32 2.392
33 2.357
34 2.322
35 2.286
36 2.251
37 2.216
38 2.181
39 2.146
40 2.110
41 2.075
42 2.040
43 2.005
44 1.970
45 1.935

For columns C and D: All plant analyses or lab tested values used should be cross-checked with the Milk Marketing Board monthly invoices for gross variations. When using values from the monthly invoice, the plant should indicate which class (3a, 3b or 5a) of milk was used in the formulation being assessed. Definitions for the classes of mill can be found on the Canadian Dairy Commission website page titled Harmonized Milk Classification System.

If the fat and protein concentrations are not listed on the Milk Marketing Board invoice in kg/hl, the following formula, which incorporates the weight (kg) of fat/protein and the total volume (hl) for the class of milk used, should be applied;

For example:

(kg of fat or protein in class x milk) ÷ hl of class x milk = kg/hl fat or protein in class x milk

Box E: Record the total weight (kg) of cheese produced for that vat/batch of cheese and must also include the weight (kg) of any wastage (as provided by the plant), such as cheese fines or any additional curds that may get discarded.

Note: For continuous processes, where information is available on a single vat basis as well as the total production, both the individual and cumulative data should be collected. This will allow for more information to be gathered on how the plant controls its process. The calculations will be based on the cumulative data so the total volume of inputs to all vats should be used in column B. The total weight of cheese produced from all vats is entered in Box E.

Box F: Record the total protein content (%) in the finished cheese.
The total protein content of the cheese is taken from the results of the CFIA laboratory analysis. The box will be left blank until the lab analysis results are received.

Repeat this process 2 more times until the 3 vat/batch records selected have been reviewed and the data for each entered into the Cheese Composition Verification Worksheet. For continuous processes, repeat this process until 3 different days/runs have been assessed. All vats from a single day/run are combined to equal one set of values.

Appendix 2: Calculation for converting weight of milk or cream to volume

The formula for calculating density to be used in converting a weight of milk or cream to volume is as follows:

  • Density = 1 divided by (Skim content / Skim Density) + (BF (butterfat) test / BF Density)

In order to use the formula properly the following conventions must be followed:

  • Skim content = (1 − Butterfat test). For example the Skim content of 35% cream is 1 − .35 = .65
  • Skim Density = 1.0355 kg/LFootnote 1
  • Butterfat Density = 0.95260 kg/L


The density of 35% cream is:

1 / ((.65 / 1.0355 kg/LFootnote 1) + (0.35 / .9526 kg/L))
= 1 / (.627716 L/kg + .36742 L/kg)
= 1 / .99514 L/kg
= 1.00488 kg/L

In order to determine the volume of cream in at this butterfat content it is necessary to divide the weight of the cream by the density.


15,333 kg of cream at 35%
= 15,333 kg / 1.00488 kg/L × 0.01 hL/L
= 152.38 hL

Pounds (lbs) To Kilograms (kg)
1 lb = 0.454 kg
1 kg = 2.2 lbs