SSOP Calf Raising Reference: Risk Reduction: Frequency: Remediation: Procedure:

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Calf Raising Reference: Animal Nutrition and Conditions, Item 7 Risk Reduction: Properly raise healthy replacement heifers and beef steers, and prevent risk of cross contamination with other facilities/ personnel Frequency: 24 hours a day, 7 days a week Remediation: If this procedure is suspected to be inadequate, investigate root causes of cross contamination and revise the SSOP and infrastructure for its implementation Procedure: Follow the procedures below 1. Collection and transport of calves a. All calves come from fresh cows that give birth in the dry pen, pen 3 b. The fresh cow is allowed to nurse, clean and nurture the newborn calf for the 1 st day i. All calves should be immediately bottle fed a half gallon of warm fresh raw colostrum and have their navel dipped with iodine ii. This is in the pasture, be careful when near the fresh cow as she can be hostile c. After a day on the pasture with the fresh cow, the calf is put into a trailer with the fresh cow to be transported to the calf area, pen 4 d. The calf is unloaded in the calf area and walked into her new hutch i. This is to ensure the tractor and trailer is not contaminated by driving into the calf raising area e. The cow is taken to the dairy to have the colostrum collected, see Fresh Cow SSOP 2. Caring for calves a. The calf is immediately fed colostrum, given a sequential ear tag, vaccinated with Calf Guard and Enforce 3 i. Ear tags should be entered into DHI Plus when fresh cow records are entered 1. Hard copy written on Fresh Cow Log ii. Ensures proper immunization from respiratory illness and diarrhea/scours b. Calves should be fed twice a day at roughly 6AM and 3PM 1. See 3 for collection of milk and colostrum 2. See 2d for cleanliness of bottles ii. Fresh colostrum should be fed for at least two days c. All calves should be given fresh water and alfalfa with grain in their respective feed buckets at each feeding i. See 2d for cleanliness of buckets d. All milk bottles/nipples and water/feed buckets should be washed after every feeding with clean water and bleach to disinfect and clean milk and manure residues e. Once a week all hutches should be moved to a clean and dry location, all bedding replaced, all hutches pressure washed to clean off any manure i. Clean hutches should be ready on standby so the calves can move into dry, pressure washed hutches. Version 3: 12/31/2012

ii. Remove the soiled hutches and pressure wash them with the designated water source and never wash them at the creamery or dairy iii. Be sure all hutches are at least 2 apart to allow for air circulation and reduce risk of cross contamination from one calf to another f. Hospital hutches i. There will be a designated hospital area in the closest few (as many as needed) hutches ii. These hutches will not be communal, single hutches only iii. Special attention will be provided to these calves on a daily basis to treat their illness and quarantine them from the rest of the calves g. All calves should be dehorned and vaccinated h. All bull calves that are due to be castrated should have a rubber band applied within the first month of life i. Once the bull calf is castrated, record the Enrollment change from M to S in DHI Plus i. Calves should be weaned at 3 months, moved to Pen 5 and String Change inputted into DHI-Plus j. Regular inventory should be taken of all calves to ensure DHI-Plus accurately reflects the location and status of each calf (male versus steer, pen 4 or 5 or 6 or 3, etc.) k. During winter months i. Be sure all tarps are in working condition and down when raining ii. Be sure bedding is adequate and dry iii. Be sure all hutches are facing away from the direction of wind and rain iv. Be sure all hutches are in good condition with no missing boards l. During summer months i. Be sure all hutches are up off the ground to allow for air flow ii. Burn flies or spray Pyganic to reduce fly populations 3. Collection and transport of colostrum and milk to feed calves a. All colostrum should be collected from clean, healthy cows only i. See Fresh Cow SSOP b. When the Calf Raising Personnel travel to the dairy to pick up the raw milk for each feeding 4. Separation from all other departments and employees a. Separation from the calf area and other personnel and buildings is critical b. Under no circumstances should equipment from the calf area be used in other departments, including: i. Pressure washers, vehicles, brushes, buckets, hoses ii. The calf area shall have its own designated equipment and those should not be loaned or used in other departments c. Personnel should be properly trained to know i. Who to call for supplies so they don t enter the creamery to get them themselves ii. Where not to go and what areas they can access iii. What equipment they can use iv. What to wear and how to properly protect themselves and their environment v. The entirety of this SSOP 5. Separation from visitors and administration Version 3: 12/31/2012

a. Management and Administration must have access to the calf area to successfully implement the needs of this SSOP, the full OPDC RAMP protocol and management of the operations i. Whenever Management enters the area, they should take all the precautions in this SSOP, especially precautions to wash their boots and hands after leaving the calf area b. Visitors include: Ecovisits, vendors of calf products, calf buyers, friends and family i. Reduce to a minimum the traffic of visitors into the calf area ii. Their immune systems may or may not be adequate iii. They are not knowledgeable of our SSOP s iv. And they may inadvertently harm themselves or cross contaminate OPDC v. For those who do enter the calf area 1. Discuss this SSOP 6. Proper clothing and GMP s for calf area a. Anyone entering the calf raising area, including regular staff and visitors, should be wearing proper clothing and rubber boots b. After leaving the calf area i. Wash off boots and step in foot bath sanitizer solution ii. Wash your hands 7. Signage and training a. Signage is posted at barrier entrance of the calf area i. There is only one entrance to the calf area, everyone must read the sign and wash their boots at the entrance/exit Version 3: 12/31/2012

Fresh Cows Reference: Animal Nutrition and Conditions, Item 6 Risk Reduction: Prevent contamination of milk for human consumption with colostrum and properly care for fresh cows and colostrum which is essential to calf nutrition Frequency: 24 hours a day, 7 days a week Remediation: If this procedure is suspected to be inadequate, investigate root causes of cross contamination and revise the SSOP and infrastructure for its implementation Procedure: Follow the procedures below 1. Fresh cows are collected from dry pen a. Dairy staff marks a green F on her hip and a green ankle bracelet on one of the hind legs to indicate the fresh cow status b. Dairy staff records the fresh cow in the herd management program and on the Fresh Cow Record sheet c. Fresh cow is put in the hospital pen for management, milking and care 2. First 5-7 days after freshening a. Collect colostrums from fresh cows in hospital pen last i. Use a separate, designated milk machine, hose, bucket for all fresh cows 1. Do not use the mastitis bucket and machine with hose 2. Keep bucket, milk machine, separate hose in sanitizer solution between uses ii. Milk this cow slowly (not all at once) into stainless milk buckets iii. Keep the stainless milk bucket off the floor of the milk barn on a stainless rack iv. Keep the openings of the stainless milk bucket closed with a closed-loop milk hose v. After milking, pour the colostrum into plastic buckets for transporting to the calf area to be fed to newborn calves vi. Dairy staff thoroughly COP clean the stainless milk bucket prior and milk machine vii. Non-conforming colostrum (bloody, mastitis, etc) should be discarded and not fed to calves 1. Wash the bucket thoroughly prior to setting all parts in bucket with water and sanitizer solution between use viii. All colostrum shall be collected in a clean, sanitary fashion using all standard operating procedures for udder cleanliness 1. Collect all colostrums as if it is to be sold as Pet Food, regardless if it is fed to OPDC calves or not

b. Carefully treat the cow, if necessary i. Udder balm udder is inflamed and or hard ii. Teat dilators if a blocked teat is observed iii. Oxytocin in cow won t let milk down and to assist in removing retained placenta 3. Release cow to milk pen a. Only after the following issues are resolved i. No more colostrum ii. No retained placenta and all afterbirth is cleaned out iii. Milk conforms with flavor, color, smell and all Grade A standards b. Move her to Pen 2 i. Document the movement by input String Change in DHI Plus

Clean In Place CIP Reference: Milking Conditions, Item 9 Risk Reduction: Ensure consistency in clean milk line and food contact surfaces used in milking clean Grade A raw milk for human consumption Frequency: CIP: After each milking, twice a day, 365 days a year SUPER CIP: Once per week Remediation: If this procedure is suspected to be inadequate, investigate root causes of cross contamination and revise the SSOP and infrastructure for its implementation Procedure: Follow the procedures below 1. CIP a. CIP is the process of Cleaning In Place i. This is accomplished by having a closed loop with a recirculation pump using water of various temperatures and chemicals b. Prior to applying jetter cups to milk machines i. Wash all floors, milk machines, milk hose and pulsator hose c. Attach jetter cups to all milk machines and secure milk machines to the jetter cup holders down low d. Open CIP water valve and turn CIP controller on e. Rinse the line with cold water until all milk is removed from the line f. Fill 80 gallons of hot (>140 degrees F temperature at thermometer, exit >160) water into the CIP vat i. Grade A standards only require 120 degrees F or hotter 1. Add 30 oz of Liquid CIP detergent 2. Wash for 10 minutes a. Recirculate hot water in vat while washing b. After wash, remove recirculating hose from vat to empty g. Fill 80 gallons of warm water (100 degrees) into the CIP vat i. Add 16 oz of Reflex Sanitizer ii. Wash for 5 minutes 1. Recirculate water in vat while washing 2. After wash, remove recirculating hose from vat to empty h. Do not rinse the line, just open the drains and let the water drain i. Assure all milk hoses are hanging high and flowing to duck bill drains or milk line for drainage 2. SUPER CIP a. Follow all steps for a CIP

b. During hot water step i. Add 5 pounds of CD-10 caustic powder to Liquid CIP c. Alternatively, do an additional hot water cycle before starting CIP i. Add 64 oz of Du-A-Way acid to hot water without Liquid CIP detergent ii. Rinse well to ensure all acid is removed from the line before starting normal CIP procedure with 30 oz of Liquid CIP detergent 1. DO NOT mix Du-A-Way acid with Liquid CIP as it is very dangerous 3. PPE and Safety a. PPE is Personal Protective Equipment and includes: 1. Safety glasses 2. Gloves 3. Respirator 4. Apron 5. Rubber boots b. Never add more chemicals than this SSOP requires i. More is not better, it can actually be dangerous to your safety ii. Never deviate from this protocol, chemicals will react differently with different temperature water and also with other chemicals if they are mixed c. Always wear PPE when handling chemicals and during CIP d. Maintain air circulation in CIP room and avoid directly inhaling chemicals as they are very harmful e. MSDS is available in the break room i. There will be a laminated copy of the MSDS and this SSOP near the chemicals f. Call the Dairy Manager and 911 immediately if you are injured by chemicals 4. A quick reference of the chemicals used and their treatment is: Chemical Use First Aid for all Liquid CIP Hot water detergent Rinse eyes 15 min Reflex Acid Warm water acid In eye wash station, Du-A-Way SUPER CIP acid Drink water if ingested, Du-Brite Stainless cleaner acid Move to ventilated area if inhaled

Herd Monitoring Reference: Animal Nutrition and Conditions, Item 1 Risk Reduction: Maintain a health, disease-free herd Frequency: Daily Remediation: Communicate with Dairy Manager any time an illness or disease is identified Procedure: Follow the policies below 1. Monitoring for Johnnes, hardware disease, pink eye, cancer eye, tumors, hoof warts and other disease a. OPDC strives to have a healthy and mobile herd b. Johnnes i. Is not curable and any cow presenting with Johnnes symptoms must be culled immediately ii. The milk from this cow shall not be used for calves as it can transmit and spread c. Pink eye i. Cows with pink eye should be quickly identified 1. The sooner the treatment is given, the more effective ii. Cows will be organically treated by placing a patch over the infected eye 1. Remove (replace if needed) the patch after 2 weeks to see progress d. Cancer eye i. In some cases, the Veterinarian can remove the cancer 1. However, most of the time will continue to spread ii. Since there is no cure and cows with severe cancer eye are not accepted for beef, culling early on is the best option e. Tumors i. Tumors are usually present on the jaw and legs ii. In some cases; they can be lanced, cleaned, drained and sprayed with antiseptic topical or iodine solution iii. When the tumor becomes a problem that results in lameness or reduction of body condition due to inability to eat, culling the cow is the best option 1. Ethical considerations must be considered as waiting to cull because she is producing milk is not always fair to the animal if she is suffering a. Consider all aspects, including pain and suffering f. Hardware disease

i. Is caused by cows eating metal ii. Magnets were placed in all cows rumen in 2010 1. No ongoing protocol is established for ensuring all purchased cows and replacement heifers have magnets 2. This will be discussed if hardware disease becomes a factor iii. Magnets on TMR mixer wagon discharge to catch all ferrous metal in feed g. Hoof warts i. Having cows in a clean, dry environment is the best natural prevention to hoof warts and disease 1. Flush or scrape lanes as needed, usually 3 times daily 2. Wash holding pen after every milking pen ii. Copper Sulfate water solution in a footbath is also good preventative maintenance 1. 5 pounds of copper sulfate should be added to each of the 2 foot baths prior to each milking 2. Footbaths get dirty from cows tracking in mud a. Wash them out after each milking b. Fresh water should be used iii. When cows have clinical foot wart problems, a hoof trimming and treatment is required 1. Milkers and other dairy staff who identify the cow should communicate with the Dairy Manager, write down the cow number and symptom observed 2. Isolate cow in the hoof trimming chute 3. Thoroughly clean the hoof with a stiff bristled brush and clean water and copper sulfate solution 4. Trim the hoof 5. Pack the infected area with copper sulfate and wrap with a clean bandage 6. Repeat every other day until the hoof is returned to its normal state and cow has regained mobility 7. If cow is not able to be cured, cull her when her immobility becomes an issue of accessing feed, pain and suffering, reduction in milk volumes, or reduction in body condition h. Although lameness is a symptom, not a disease; it is still a concern and primary reason for culling the herd i. Considerations 1. Pain and suffering of animal and animal welfare 2. Immobility reduces ability to access the feed a. Subsequent reduction of body condition and susceptibility to further illness ii. Cull cows when either of the above listed considerations are a problem 1. Try to preventatively treat the cow before it advances too far a. Foot bath, hoof trimming, etc

Human Factor Management Reference: Testing Protocols and Results, Item 3 Risk Reduction: Prevent employees, outside vendors, equipment, and tools used in dairy and calves from cross contaminating creamery and processing personnel and facilities Frequency: 24 hours a day, 7 days a week Remediation: If this procedure is suspected to be inadequate, investigate root causes of cross contamination and revise the SSOP and infrastructure for its implementation Procedure: Follow the procedures below 1. Outside Vendors a. OPDC occasionally uses services from outside vendors for maintenance, repairs and construction b. Under no circumstances shall work be done while food processing is taking place c. A thorough cleaning of all surfaces in the building and equipment that was in contact with the outside vendors should be completed before the next scheduled processing shift i. Special COP and CIP cleaning shall be performed on the actual parts they were working on and they shall be inspected for conformity with Grade A sanitary standards (i.e. smooth and cleanable, etc) 2. Maintenance Personnel a. Since OPDC Mechanics and Maintenance Personnel must work on buildings and equipment in multiple departments; their tools, bodies, boots, tool carriers and equipment are all possible vectors of contamination b. Special care should be taken before entering the processing facilities to: i. Change out of any contaminated clothing ii. Change boots to proper color coded boots iii. Place all tool bags and carriers inside a disposable plastic bag liner c. A thorough cleaning of all surfaces in the building and equipment that was in contact with the outside vendors should be completed before the next scheduled processing shift i. Special COP and CIP cleaning should be performed on the actual parts they were working on and they should be inspected for conformity with Grade A sanitary standards (i.e. smooth and cleanable, etc)

3. Color Coded Boots a. Dairy personnel should wear company-issued black boots i. Occasionally, employees want to invest in more luxurious boots ii. This is permitted, as long as the boots are a dark color other than white b. Creamery personnel should wear company-issued white boots i. If maintenance, management or other visitors enter the Creamery; they should also wear white boots designated for clean rooms only 4. Uniforms a. Company-issued uniforms should be worn by all employees in the Dairy and Creamery i. Since no changing rooms are provided, employees should come to work in their company-issued uniform ii. Employees should not wear uniforms when off duty iii. Dairy employees should have blue shirts and navy pants iv. Creamery employees should have white shirts and either white or navy pants v. No street cloths should be worn over the uniforms 1. In cold winter months, jackets are permitted to be worn over the uniforms, but caution should be used to ensure no draw strings or part of the jacket can come in contact with food surfaces 2. Dairy and Creamery employees are also permitted to wear rain suits and aprons over their uniform in inclement weather and/or when working conditions require it 5. Foot Baths a. Foot baths should be at the entrance of all Creamery processing facility doors b. Chlorine solution of 200 PPM should be used to ensure proper disinfecting of under sides of boots c. Foot baths should be drained, washed and solution replaced a minimum of once daily or as needed 6. Mud Room (WORK IN PROGRESS, PENDING IMPROVEMENTS) a. A changing room for all personnel, called the Mud Room, is built at the primary entrance of the creamery b. This area should be used to remove street shoes and jackets in order to put on company-issued white boots, aprons and other uniform clothing items i. This should be used for the start and completion of the shift, boots do not need to be exchanged with street shoes during the shift at exiting through the Mud Room c. Lockers are provided in the break room, so the Mud Room should not be used for storing valuables and personal items d. Once the employee or visitor enters the creamery i. Wash hands, put on gloves and hairnet, step in secondary foot bath 7. Break Room (WORK IN PROGRESS, PENDING IMPROVEMENTS) a. The break room is a common eating, resting and meeting area for all departments b. Careful precautions should be made to prevent cross contaminations, including

8. Calves SSOP i. All employees should wash boots off in the provided wash area near the entrance to the break room ii. Remove overalls and contaminated clothing, if necessary a. The Calf Raising Area is located within 150 feet of the Break Room and offices i. This close proximity, and the potential presence of pathogens in the calves manure are cause to segregate personnel and minimize cross contamination b. Dairy employees and anyone exiting the calf raising area should wash their boots at the designated exit barrier i. A footbath is provided, all users should first wash their boots with the water hose and then step in the footbath to prevent footbath contamination ii. Wash your hands after washing your boots iii. Dairy personnel should drain, rinse, and replace the chlorinated solution in the footbaths at least once daily c. Under no circumstances should any white boots or Creamery employees go into the calf area 9. Milkers and Dairy Personnel a. Anyone coming in contact with cows will follow the protocol below at hire: i. TB skin test ii. Physical iii. SSOP training iv. Drug testing b. All milkers that are sick should not work until they are better i. Report to Dairy Manager so we can schedule a backup milker *Strike through items are a work in progress, planned but not yet completed.

Recalls Reference: Testing Protocols and Results, Item 3 Risk Reduction: Reduce risk of customer illness from consuming products containing pathogens Frequency: Immediately after being issued a Product Recall, Quarantine Notice or other formal document by CDFA, Milk and Dairy Foods Branch Remediation: Immediately follow requirements of the Quarantine, inspect the facilities and suspected areas, identify the root causes of the problem, find a solution to the problems, fix them and retest Procedure: Follow the procedures below 1. Product Recall and Quarantine a. Follow all required items in the Quarantine Notice b. Distribution i. Bring all product back to OPDC for inspection, counting and verification ii. Mark all products with a black X on the closure to identify it has been taken back from a store iii. Issue the store a credit for the returned product c. Creamery i. Stop all processing immediately ii. Clean the plant thoroughly iii. As product comes back from Hub s to OPDC, clearly segregate and hold that product for CDFA inspection iv. Work closely with OPDC Administration on a plan of action to resolve the issues v. Work closely with CDFA d. Administration i. Generate a sales report and customer list to give CDFA to show which stores received the product on Recall ii. Immediately distribute a statement to all customers letting them know which product(s) are being recalled and that they should remove the products from the retail shelf iii. Tell them NOT to destroy the products, but to hold onto them in cold storage until OPDC Reps pick them up iv. Manage Human Resources, Public Relations, and financial concerns

2. Dairy Degrade a. DPH inspects the dairy as Grade A Raw for Human Consumption b. In the event the dairy is not in compliance with Grade A Raw for Human Consumption, a degrade is issued and the dairy is only certified to produce Grade A Raw Milk for Pasteurization i. In a rare case, the dairy could also be out of compliance with those standards, in which case the dairy would be degraded to Grade B c. If the dairy is degraded, all milk from the dairy going to the OPDC plant must be received accordingly i. Grade A Raw Milk for Pasteurization can only be separated with the cream going butter, skim sold for pasteurization and cheese ii. No class 1 or 2 products can be made until the dairy is reinstated for Grade A Raw Milk for Human Consumption 3. Plant Degrade a. CDFA inspects the plant as Grade A b. If a finished product does not pass 2 out of 4 samplings, a 2/4 Notice is issued i. The plant is inspected to identify possible contamination points ii. Cleans the plant thoroughly 1. Repair the issues that are identified in the inspection iii. The CDFA inspector will come back in no less than 3 days and no more than 21 days to gather samples for retesting c. If 3 out of the last 5 samples are not in compliance with Grade A standards, a product degrade is issued by CDFA i. Do not bottle, process or release any of the degraded products until a Reinstatement Notice is issued by CDFA ii. Clean the plant thoroughly iii. Bottle or otherwise process 2 separate lots of product 1. Have them available for CDFA to come back and send off for testing iv. When the Reinstatement Notice is issued, proceed with production and distribution of product