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Are monitoring and record keeping for vitamin addition required under HACCP in the Grade “A” PMO?

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Are monitoring and record keeping for vitamin addition required under HACCP in the Grade “A” PMO?

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The PMO requires vitamin testing and vitamin use volume control in Grade “A” milk plants. No exception is provided for HACCP plants. Section 6 requires: Assays of milk and milk products as defined in this Ordinance, to which vitamin(s) A and/or D have been added, shall be made at least annually in a laboratory, which has been accredited by FDA and which is acceptable to the Regulatory Agency, using test methods acceptable to FDA or other official methodologies, which gives statistically equivalent results to the FDA methods. Vitamin testing laboratories are accredited if they have one (1) or more certified analysts and meet the quality control requirements of the program established by FDA. Laboratory accreditation and analyst certification parameters are specified in the EML manual. In addition, all facilities fortifying milk or milk products with vitamins must keep volume control records. These volume control records must cross reference the form and amount of vitamin D, vitamin A an

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