Liability Insurance Contributing Columnist


Cheese With A Sprinkle Of Construction Dust?

Jen Pino-Gallagher
Director of Food & Agribusiness Practice
M3 Insurance

August 12, 2022


Drive around the countryside and the number of construction cranes hovering over dairy plants are popping up faster than vegetable stands at a small town intersection.

Dairy processors across the nation are expanding, modernizing and retrofitting existing plants. They are growing to meet both domestic demand and foreign.

According to Mark Stephenson, director of dairy policy analysis at the University of Wisconsin-Madison, per capita domestic consumption is at an all-time high. Global demand, as well, is strong. US dairy processors are exporting a record 17.5 percent of all the products they produce.

Demand drives production. Production drives construction.

Why Spend on Capital Improvements?
Expenditures on capital improvements can lead to more than just increased production. It could lead to greater employee recruitment potential and employee retention. Newer facilities are often a more attractive environment for employees.

And, the expenditures can result in reduced operating expenses like insurance premiums by making your manufacturing facility more insurable for property insurance. Workers’ compensation insurance premiums could also be positively impacted, as capital expenditures and improvements engineer out certain equipment-related hazards.

Considerations for Dairy Plant Construction
While every project is unique and results in its own set of benefits, one universal truth exists. Every single dairy plants construction project must be done in a way that maintains clean and sanity conditions DURING construction as well as post construction.

According to the State of Wisconsin’s ATCP 65.24(1)(a) Buildings, facilities, and equipment used in the operation of a dairy plant shall be soundly constructed and shall be capable of being maintained in a clean and sanitary condition.

Chad Galer, vice president of product research and food safety for Dairy Management, Inc. states that it is imperative to be prepared for planned or unplanned construction events to minimize food safety risks.

Construction activities introduce new risks for contamination due to non-routine people, traffic patterns (room segregation, alternate routes, etc.), infrastructure disturbances, and/or changed sanitation procedures.

Just like the engineers and contractors will have blueprints and building plans, food safety leaders need a food safety construction plan for each project prior to construction starting.

A good construction plan clearly communicates the step-by-step work to be done, gives a timeline of events, identifies who will perform mitigation steps, and when mitigation steps will be taken.

An effective construction plan will also outline any increased environmental monitoring prior to, during and after construction to ensure the mitigation steps are effective.

A robust and detailed plan is needed to manage and maintain a sanitary plant environment during construction events. Controlling Pathogens in Dairy Processing Environments: Guidance for the U.S.
Dairy Industry provides an example of a Food Safety Construction Plan SOP (Appendix C), a Construction Plan Checklist example (Appendix C), and a Dairy Facility Design Checklist (Appendix B).
Failure to adhere to safe construction standards can have major implications.

One dairy product manufacturer involved in a product recall provided the FDA with a draft root cause analysis of the bacterial contamination which prompted their company’s recall.

The dairy processor’s analysis indicated that contractors performing work in the building did not sanitize nor change their shoes upon returning into the building. The processor claimed that their contractor was at fault for the bacterial contamination that led to the product recall.

Key Takeaways
The old adage, fail to plan, plan to fail holds some truth. A well-planned construction project can reduce the risk of a contamination incident caused by the construction project.

By taking the proper precautions, the benefits of capital improvements will far outweigh the risk. But, take the proper precautions. After all, no one wants their dairy product to include of a sprinkle of construction dust

Jen Pino-Gallagher is director of the food and agribusiness practice at M3 Insurance. M3 Insurance offers insight, advice and strategies to help clients manage risk, purchase insurance and provide employee benefits. The views expressed above do not necessarily reflect those of Cheese Reporter. You can contact the columnist by calling (800) 272-2443, or by visiting


Jen Pino-Gallagher

Jen Pino-Gallagher is a Director of Food & Agribusiness Practice at M3 Insurance. M3 Insurance offers insight, advice and strategies to help clients manage risk, purchase insurance and provide employee benefits.
For more information, call (800) 272-2443 , visit

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