Death to the Dipper

death of the dipper
 

In the dairy industry, the statement, “That’s how we have always done it,” is a common one. Walk onto almost any farm and somewhere in the milk house is a dipper hanging on the wall. The Pasteurized Milk Ordinance (PMO) and Standard Methods for the Examination of Dairy Products (SMEDP) exhaustively outline how to take an accurate dip sample from a bulk tank, but the entire industry acknowledges this is an archaic sampling method. Using a dipper is fraught with opportunities for human error and contamination; yet it has long been considered the ‘Gold Standard’ of sampling.

Three years ago, I submitted a proposal for the approval of an aseptic sampling method for bulk tanks to the Food and Drug Administration (FDA). They requested an associated data study that compared the proposed aseptic sampling method to the dipper method. This was akin to comparing a 1978 Ford Pinto to a 2020 Ferrari F8 Tributo. Nonetheless, I completed the comparison and submitted the study and data package.

The 2019 National Conference on Interstate Milk Shipments (NCIMS) meeting went by and multiple attempts to contact the FDA Center for Food Safety and Applied Nutrition (CFSAN) group went unanswered. Not easily deterred, I spent the last two years lobbying the states individually. Then seemingly out of nowhere, while following stay at home directives and working from my couch, a supplement to FDA Memorandum of Information 06-12 appeared in my inbox.

The supplement specifically approves the use of an aseptic sampling method for all bulk tanks and silos.

Prior to the email, dairy producers had only one approved method to sample a bulk tank, which was the dipper. FDA MI-06-12 stated, producers could only use an aseptic sampler on a horizontal silo if the manhole cover was not accessible. That effectively limited producers from using an aseptic method since bulk tanks all have accessible manholes. Bulk tanks make up more than 90% of storage units on dairy farms. With this change accepted by the FDA and NCIMS executive board, dairy producers can now use the aeseptic sampling method as a tool for minimizing contamination and for providing representative sampling data that can directly control their quality payments.

milk house dipper sampling

Another old dipper replaced with a QualiTru sampling system!

Dairy producers can now stop saying, “That is how we have always done it.” They now have choice in sampling. The sampling method provides aseptic sampling of bulk tanks from the ground, instead of a certified sampler climbing a ladder to dip the tank. In these challenging financial times, dairy farmers need every opportunity they can get and the FDA just handed them a major win.

You can find the new appendment on the QualiTru website’s Regulatory Approvals page at FDA memo M-I-06-12 (Supplement 1)

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Brett Roeller is the Director of National Accounts at QualiTru Sampling Systems. Find out a little more about him on QualiTru’s Our Team page. Visit Our Blog for other articles Brett has produced.


By Brett Roeller
Director of National Accounts, QualiTru Sampling Systems
brett@qualitru.com   Follow Brett on LinkedIn