Pasteurized Milk Ordinance - 72 hour storage tank rule

Hi, new member here hoping to get some insight into the PMO 72 hour rule for raw milk storage. The ordinance says that milk can only be stored in the silo for 72 hours before the tank needs to be cleaned... but doesn't necessarily say that you need to pasteurize right away. It does say that bacterial counts prior to pasteurization need to be 300,000 CFU/mL or less. My question is: Is it ok to move the milk from one tank to another to wash the silo after 72 hours and hold it in the new tank for another couple days before pasteurizing? Or is the bacterial load before pasteurizing the only limiting factor here. Thank you.

When I worked at a dairy we were strict about using the raw milk within 72 hours and pasteurized milk within 24 hours to meet those cleaning requirements. What you are suggesting, I believe would fall under an extended run which would need to be approved to do (now and in the future). I believe if you were to submit a plan documenting how you would test the raw milk to comply with Section 7 prior to use, plan in place if you cannot use it how it would be discarded, and everything specified #1-9 below you have a chance of getting it approved but your regulatory body. Just call and ask who oversees your facility, they will let you know. 

Page 74 of PMO. 
ITEM 12p. CLEANING AND SANITIZING OF CONTAINERS AND EQUIPMENT

1. All multi-use containers and utensils are thoroughly cleaned after each use and all equipment is thoroughly cleaned at least once each day used, unless the Regulatory Agency has reviewed and accepted information, in consultation with FDA, supporting the cleaning of multi-use containers and utensils at frequencies extending beyond one (1) day or seventy- two (72) hours in the case of storage tanks, or forty-four (44) hours in the case of evaporators, which are continuously operated. Supporting information shall be submitted to and approved by the Regulatory Agency prior to initiating the qualification period if required. Finished product produced during an extended run shall meet all applicable requirements of Section 7. of this Ordinance. Any significant equipment or processing changes shall be communicated to the Regulatory Agency and may result in a reverification of the extended run proposal, if it is determined that the change could potentially affect the safety of the finished milk and/or milk product(s). The supporting information may include but is not limited to:

1. Statement of proposal, including desired cleaning frequency.
2. Product and equipment description.
3. Intended use and consumers.
4. Distribution and storage temperatures of product.
5. Diagram of process of interest. \
6. Process parameters, including temperature and times.
7. Hazard evaluation and safety assessment.
8. Review of equipment for sanitary design.
9. When indicated by a hazard evaluation and safety assessment, a plan for initial qualification shall be developed to address identified critical process parameters.

Otherwise, storage tanks shall be cleaned when emptied and shall be emptied at least every seventy-two (72) hours. The seventy-two (72) hour time period starts when milk first enters a cleaned and sanitized storage tank

Hi Kara, thank you for the feedback!

When I started at a dairy, I was told the same thing.   "Yes, we need to clean the raw milk / cream tanks every 72 hours, but we can just pump the milk/cream to another freshly cleaned tank.   Then we can use the product for another 72 hours" - sound about right?

As I recall, the regulation for ambiguous (ie -emptied vs processed)

However, it's a horrible idea.   First, you are likely increasing the amount of spoilage organisms that will survive pasteurization.    This will cause you huge problems elsewhere.  Second, it is probably a lot tracing nightmare.  etc

I would ask the local regulator on the interpretation.   Even if they agree it is permissible, I would still try and place parameters around it.   IE only move once, need to completely empty all tanks every X days, etc.  It should be more of an emergency practice than standard operating procedure.    It will bite you eventually.  

Hi kingstudruler, I agree. The ordinance is ambiguous, but holding over (or extended runs) could definitely lead to problems with both the points you mentioned. Thanks for the response.

Hi kingstudruler, I agree. The ordinance is ambiguous, but holding over (or extended runs) could definitely lead to problems with both the points you mentioned. Thanks for the response.

Dairys are amazing places.   In many cases, they will teach you best practices and how to do things correctly.  

On the flip side, they will teach you that one (even inadvertent) bad decision made by someone will ruin your day, week, month and test your problem-solving skills.  

Hello All,

I'm wondering if the 72 hour countdown start when CIP is done or when product is introduced to the cleaned silo? Sometimes we CIP over the weekend so we can have clean silos to start with ...

Thanks!