Dear kisslee,
Apologise for my ignorance of dairy product but is the step you are referring to before or after pasteurisation?. (i guess the former based on flowchart in Mike's attach.)
Not my product area at all but, if before pasteur., undoubtedly Mike’s suggested logic of removing coliform inputs is critical although I noticed that the NZ attachment repeatedly suggested the avoidance of setting up
CCPs for receiving goods, an implicit acknowledgement of the difficulty perhaps? Whatever, actual data will probably be necessary in addition to the magic COA. I expect you hv such already ? Nonetheless, I presume the pasteurisation step will eliminate coliforms quite efficiently within it's design level. If after pasteu., the equipment etc obviously triggers in.
The kind of scenario you are looking at seems to conceptually have similarities to predictions of max.
haccp storage times for chilled finished products, or perhaps even semi-finished items – these are often based on criteria such as”maximum x generation times such that the level of a defined species, eg L.mono, will not exceed Y cfu/g”. Software programs hv been used for above for many years for pathogens, but coliform no idea. Mikes first attach. is a (high-powered) deliberation on such things.
The item somewhat missing from yr posts is experimental data, eg what the current situation actually is like with respect to coliform ?. I presume you run control charts as in Mikes attach.? I appreciate that you may prefer to primarily run on quick feedback data rather than micro. but for validation purposes, probably no choice but to collect. This is illustrated in Mike’s amazing 2nd attach.
I daresay you hv done all the above thinking already !?
Rgds / Charles.C
PS, after noticing Mike's comment earlier, i presume there is a pasteurisation ??