Promoting the improvement of dairy quality and safety

in the interest of the dairy industry and the consumer

5. Remedial Action Programs

Remedial action programs with producers/processors and processors/distributors (PD's).

Project purpose:

  • To facilitate awareness of non-conforming results with processors/distributors/PD’s after each quarterly sample run as the first step of the remedial action program.
  • To interact with all processors whose results are in non-compliance with the relevant legal standards.
  • To follow-up by means of personal contacts to address non-conformities.
  • To offer technical assistance by means of DSA developed literature, guidelines and information brochures.
  • To conduct further sampling, where appropriate, to establish whether non-conformances in terms of legal standards are addressed.
  • To hand over unresolved matters to Project goal 6 for further action with higher-level government officials.

Due to its restricted shelf life, fresh milk (heat-treated and raw) non-conforming products require prompt action by the parties involved.

Following the activities of project goal 1 and as a cost-effective measure, this goal provides for procedures whereby information regarding non-conforming test results are communicated to the processors and distributors and where applicable, to retailers. In the event of non-conformances, such persons are contacted to address non-conforming issues as a priority. Telephonic calls and electronic mail are subsequently followed up with personal contacts. This DSA action also allows for technical information being made available to processors and distributors through the DSA industry guideline documentation.

Planned activities and outputs


Projected dates of completion 

Telephonic and electronic contact with product supplier/distributor explain-ing non-conformities as well as the transfer of the information regarding problem-solving, where applicable.

Step 1

  • Facilitate awareness of non-conforming results with processors/ distributors/PD’s after each quarterly sampling run by means of communication of test results through the preferred communication medium.
  • Post, fax or e-mail results to the producer/processor/distributor within three (3) days after results are received back from the laboratory.

Step 2

Visit producers/processors/distributors identified by Project goal 1 of which any Category A or B analysis indicates a non-conformance.

The following actions shall be taken:

  • Arrange an appointment with the highest authority possible, as well as the QC manager/officer.
  • Discuss non-conformance.
  • Offer technical assistance by means of DSA developed literature, guidelines and information brochures.
  • Discuss further actions that will be taken by DSA in case of further non-compliance report.

In the case of a lack of resources e.g. personnel and/or visiting time, the visits will be scheduled according to the following criteria:

  • Geographical location:
    Areas with the highest population of facilities with non-complying products will be targeted first in order to maximize points of contact


  • Order of non-conformance

• Added Water

• Phosphatase positive results

• Inhibitory substances

• E. coli positive results

• Underfilling

Step 3

Follow-up sampling on-site and monitoring as per Project goal 1.

Step 4

  • Identify regular offenders (who has gone through step one and two of the remedial action program) and continue to:

• conduct consumer fraud (addition of water, under filling, misconduct in terms of the quality of the product etc. butterfat, protein) of products not 
   complying with the requirements as stipulated in terms of the Agricultural Product Standards Act, 1990 (Act No. 119 of 1990) Regulations Relating to
   Dairy Products and Imitation Dairy Products (R1510/2019).

• Mislead the consumer (sell of raw milk as pasteurised milk, incorrect labelling of a product, etc.).

• Sell the product with a potential food safety risk to the consumer (if there is any reason to believe that a dairy product poses a definite food safety
   risk to the consumer, step 1 and 2 of the remedial action program will not come into effect).

• Neglect the implementation of good practices (PRP’s) and continues to sell product not complying with microbial standards up to the end of
   shelf life.

  • Forward information to Project goal 2 for the filing of official complaints with authorities.


Industry Partners

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