Single system approach

The extent of the DFSV Single System Approach

The regulatory remit of DFSV, as defined in the Dairy Act 2000, is specific to dairy food safety. Consequently, DFSV’s regulatory powers (licensing and enforcement) are used only to ensure the delivery of dairy food safety outcomes.

The DFSV single system approach makes use of our regulatory model to also streamline compliance systems and assurance arrangements for delivery of market access.

As a service to industry and the Department of Agriculture, DFSV provides the Department of Agriculture with assurance that dairy manufacturers in Victoria are meeting their dairy export market access requirements.

The following outlines the extent of our single system approach and the roles and responsibilities of the relevant regulators.

 

Area of risk  Regulator   In the DFSV single system  Who does what      

Dairy food safety

 

 

 

 

 

 

 

 

DFSV

 

 

 

 

 

 

 

 

Yes

 

 

 

 

 

 

 

 

DFSV:

  • approves food safety programs
  • issues licences 
  • conducts audits
  • ensures compliance with domestic food safety standards
  • follows up on non-compliance
  • takes regulatory action
  • provides scientific and technical advice.

Dairy product export market access

 

 

 

 

 

 

Department of Agriculture

 

 

 

 

 

 

 

Yes

 MoU

 

 

 

 

 

 

 Department of Agriculture:
  • undertakes initial assessment and approval of company approach to market access requirements
  • enforces action on non-compliance with export market access requirements.
DFSV:
  • conducts audits
  • reports to the Department of Agriculture.
Dairy shed effluent management

 

 

 

 

 

 

EPA

 

 

 

 

 

 

Yes

 

 MoU DFSV and EPA

 

 

 

 

 DFSV:
  • provides consolidated, de-identified data reports to the EPA.
EPA:
  • monitors water quality
  • educates auditors and farmers
  • takes regulatory action when a regional risk profile is determined by EPA to be high.
Residues in bobby calves

 

 

 

 

 

 

 

DEPI

 

 

 

 

 

 

 

No

 

 

 

Refer to Dairy Australia for details of industry program

 

 

 Dairy Australia:
  • leads an on-farm follow up program
Department of Environment and Primary Industries
  • takes action on non-compliance with domestic residue limits.
Meat industry quality assurance program
  • addresses non-compliance with export market access residue limits.

 

 

 

Background to the Single System concept

The regulatory remit of DFSV, as defined in the Dairy Act 2000, is specific to dairy food safety. Consequently, DFSV’s regulatory powers (licensing and enforcement) are used only to ensure the delivery of dairy food safety outcomes.

 

In addition, and via formal agreement with the Federal Department of Agriculture, DFSV provides the Department of Agriculture with assurance that dairy manufacturers in Victoria are meeting their dairy export market access requirements. Note that the Department of Agriculture regulates this export market certification, not DFSV.


DFSV provides this assurance, as a service to industry and the Department of Agriculture. The Department of Agriculture entrusts all routine audit related market assurance work to DFSV. The Department of Agriculture requires evidence as to whether companies are meeting their agreed market access elements. DFSV, through its audit function, enables the Department of Agriculture to make this assessment and by doing so avoids duplication of audits (by the Department of Agriculture). It is the Department of Agriculture that determines the action on non-compliance in the export market access area, such as export of product being suspended.

 

Apart from very rare exceptions, to be able to export every company needs independent verification that they have met domestic food safety requirements as a first step to access the market. This is the core remit of DFSV. Building on the food safety remit to include assessment of compliance with export market requirements was a natural progression with respect to the DFSV and Department of Agriculture collaborative approach, and was strongly supported by the dairy industry.

 

Dairy companies include all of their DFSV approved food safety requirements and all additional export market access requirements in their respective quality assurance (QA) programs. This enables the DFSV audit system to collect relevant information and use appropriate information for food safety purposes or provide information to the Department of Agriculture for market access purposes.

 

Current Single System developments

DFSV also has an agreement with the EPA, again with the aim of avoiding duplicate audits. In this case the activity is specifically the on-farm assessment of management of dairy shed effluent. Most dairy manufacturers have agreed to a specific set of EPA-required questions in their QA programs which will enable an auditor to report on a uniform approach. DFSV collects and aggregates this information from auditors, removing the ID of properties. The DFSV report to the EPA provides the EPA with an overall picture of the risk management of dairy shed effluent across the state. Over time the information will show trends in effluent management to the EPA.

 

Individual manufacturers are developing their own relationship with the EPA, which is entirely appropriate.

 

Whilst the outcomes of the EPA/DFSV management of dairy shed effluent have been supported by the dairy industry the specific detail of the data arrangement with the EPA has been between DFSV and the EPA.

 

Residues management beyond dairy food safety

An emerging area of industry interest is management of residues in bobby calves. In this case the relationship is largely between the meat and dairy industries. The management of residues in bobby calves is an area that could benefit from greater clarity and agreement between the meat and dairy industry. Current confusion in this area can create an impression that DFSV plays a role in managing residues in bobby calves, but this is not the case. Current arrangements for the management of residues in bobby calves are agreed between Dairy Australia, dairy manufacturers, United Dairyfarmers of Victoria, Department of Environment and Primary Industries and key stakeholders in the meat industry.

 

Using the example of a dairy farm;

  • DFSV approves a dairy farmer’s food safety program based on the management systems that must be implemented to ensure the production of safe milk. DFSV does not regulate the additional quality requirements that are included in a dairy company’s quality assurance arrangements with their dairy farm suppliers. However, DFSV does assure the Department of Agriculture that agreed market access requirements for dairy manufacturers have been met. Where bobby calf management requirements are included in a dairy company’s QA arrangement they are not audited as part of the DFSV system and they are not regulated by DFSV.

  • DFSV approves auditors who are competent to assess the effectiveness of a dairy farmer’s management of risks that may affect the safety of the finished dairy product. DFSV’s approval of auditors does not ensure that the auditor has the necessary skills and knowledge to be able to assess the effective management of risks related to bobby calves. The supply chain for bobby calves is significantly different to that of dairy products.

  • The Deed of Undertaking that DFSV enters into with an auditor enables an approved auditor to collect information on-behalf of DFSV. DFSV can only use the information collected for the purposes of ensuring compliance with the Dairy Act. Information that is collected for the purpose of the Dairy Act cannot be used for a different purpose without the consent of the licence holder. Without an agreed system in place, DFSV cannot use any information it obtains under the Dairy Act to assure the management of any matter beyond its remit.

  • While an auditor may check a farmer’s compliance with the company’s QA program at audit, many of the elements that are checked may not be part of the DFSV system. The manufacturer may require additional quality/commercial parameters to be met. As DFSV does not collect or analyse information that relates to elements other than dairy food safety (unless part of a regulated and agreed arrangement – please refer to table), DFSV cannot provide feedback or assure industry performance against any such additional QA program requirements.