Value-added opportunities for dairy farmers are one way to stabilize long-term dairy farm profitability, bring another generation into the business or grow without adding land and cows. As farm gate prices remain bleak over an extended period, some producers may be considering a move to on-farm, value-added processing for their dairy products.

However, the grass is not always greener for the on-farm creamery. Moving into an on-farm processing enterprise raises the need for an entirely new skill set in the plant, potential new employees, capital, finite and meticulous records, and compliance with multiple layers of regulations and bureaucracy.

The layer of distance and protection between farm and consumer is now erased; the buck stops where the creamery door opens in terms of a product that is both safe and compliant with all food processing regulations. And there is no shortage of regulatory agencies from state, USDA, FDA and in some cases, county health departments and state departments of natural resources.

Any violation, whether intentional or accidental, can trigger a product recall and in some cases fines. Mooville Creamery of Nashville, Michigan, learned the hard way that a short lapse in filing paperwork is all it takes to trigger a recall.

Michigan Department of Agriculture and Rural Development (MDARD) food safety protocols allow a 24-hour grace period for the processor to voluntarily recall product after a violation, according to the state’s website. After the grace period, MDARD publishes and releases the recall.

MDARD released the recall on Mooville Creamery last October, which affected two bottling runs and approximately 10,000 gallons of milk. About 75 percent of the milk had already been consumed according to owner, Doug Westendorp. “It still cost us about $15,000 in returned product,” he says. “They could have fined us, but they didn’t.”

Karen Kelley of Kelley Country Creamery in Fond du Lac, Wisconsin, says, “It’s not a matter of if, but when you have a recall.” The word alone can cause customers to jump to conclusions and stop purchasing from a business, even if the recall is based on paperwork filing and not on actual food safety matters.

Kelley’s family researched the possibility of a value-added product for four years with their 65-cow dairy. Adding an ice cream processing facility and a retail parlor was the route chosen, and Kelley Country Creamery opened seven years ago.

Times were simpler then. With ongoing implementation of the Food Safety Modernization Act (FSMA), under regulation by the FDA, the amount of required records has grown to such an extent it makes Kelley believe she might not have gone into processing had she known what future demands would be made on her small creamery.

At least one person per food processing facility must be certified on the new code standards. FSMA requirements replaced food safety codes that had not been updated for over 70 years.

FSMA implementation will add to the regulatory burden. And for the small creamery, writing plans for training, recalls, documenting suppliers and details for each ingredient truly is a burden that takes time away from production. Kelley must be in compliance by September 18, 2017, requiring her to write plans that fulfill the requirements during the busiest season of the year for an ice cream parlor.

When it comes to FSMA, Greg McGuire, vice president of operations at Guernsey Farms Dairy in Northville, Michigan, says, “Get educated and do it quickly. There is a lot out there to read and know.”

According to McGuire, courses that will help bring processors up to speed are being offered through FDA and information can be found on their website.

While the components of new FSMA rules are many, Kelley suggests four key areas of concentration.

–Have a recall plan in place. Have a list of key people in place, define each person’s tasks, plan how to release recall information, including a sample press release which includes all required content, and have a plan for working with media.

–Use proven suppliers. Know who suppliers are and purchase only from approved suppliers that provide certificates of assurance.

–Keep accurate and updated records. Document every ingredient in every product batch. Record information on ingredients purchased and received including date, lot number, storage location and how the product is used.

–Extensive employee training. Employees must be trained to follow all protocols established by the creamery, and proof of training must be included in each employee file. Not only will inspectors check to see if training protocols are written, they will likely quiz employees to determine if practices in the plant correspond with written protocol.

If products used in processing are also used in a retail operation, retail employees must follow the same protocols and therefore receive the same training.

In some ways, Kelley believes she has a head start on the process because she kept detailed product records since their ice cream plant and parlor opened. New regulations come with templates to help create plans, document hazards and allergens, and record suppliers. Each set of paperwork must be refreshed every six to 12 months.

“I’m a person who gives much attention to detail; I spent a lot of time, energy and money to build a quality product up front. It’s very important that I have that protocol in place and it’s being used so I don’t have to have a recall,” Kelley says.

“However, we are all human, and mistakes can happen. People in business take a lot of care in what they do to make sure the big things don’t happen. They put a lot of hard work into their endeavor, and they want to stay in business.”

Westendorp feared it would take years to regain lost sales and overcome image issues due to the recall. However, damage to their name and image appears to be minimal this time. “I don’t really believe it hurt us; we had all positive comments from customers, and our sales never dropped off. When people understood that it was just paperwork and just government, they totally understood.”