The rating method for evaluating the sanitary quality of milk measures the extent to which a shipper complies with standards contained in the GRADE "A" PMO. These nationally recognized standards--rather than local requirements--are used as a yardstick in order that ratings of individuals BTUs or attached shippers and milk plants may be comparable to each other, both interstate and intrastate. Ratings are expressed in terms of percentage compliance. For example, if the milk plant and dairy farms comply with all of the requirements of the GRADE "A" PMO, the sanitation compliance rating of the pasteurized milk supply would be 100 percent: whereas, if the plant or some of the dairy farms fail to satisfy one or more of these requirements, the pasteurized milk rating would be reduced in proportion to the amount of milk and milk products involved in the violation and to the relative public health significance of the violated items. Procedures for collection of data, computation of sanitation compliance ratings for raw milk for pasteurization and pasteurized milk, and computation of the enforcement rating of the milk regulatory agency responsible for administering milk sanitation regulations are described in the following sections.
During an INTERSTATE MILK SHIPPERS' (IMS) rating or check rating, it is necessary to determine compliance of the BTU with the requirements of Appendix N of the GRADE "A" PMO. The following criteria are to be used in making that determination. If the BTU or attached supply is not in substantial compliance, a rating or check rating is not to be completed and the State Rating Agency shall immediately withdraw IMS certification.
(a) Record Review.
Determine from records that are stored in a manner acceptable to the rating agency that all milk pick-up tankers are screened daily prior to processing for beta lactams with an approved test method; as necessary, determine that all producers are randomly tested 4 times in any consecutive 6 months for other drug residues if directed by M-a-75.
Compliance with the above item would be satisfied in the following manner:
(1) Records indicating that milk was always shipped to an IMS listed shipper will suffice for actual test results.
(2) If milk is shipped to a non-listed plant, records indicating actual testing must be provided or available for review. When the state regulatory agency has determined adequate documentation for compliance with this section exists, the rating agency may accept this documentation. The responsible rating officer may at their discretion request records on the testing of loads of milk that are sent to non-listed plants.
If records are requested, the rating officer should choose and request to review records for no more than 15 days unless these selected records show a problem.
(b) Notification and Disposition.
If a load sample or individual producer sample is positive for a drug residue, determine if the regulatory agency was immediately notified of the method of proper disposition to keep contaminated milk out of the food chain.
(c) Reinstatement.
Determine if the violative producer was not allowed to ship milk until the milk no longer tested positive for drug residues.
Data from which the ratings are determined are obtained by the State Milk Sanitation Rating Officers from the records on file with the milk regulatory agency, and from the evaluation of sanitary practices and facilities at the dairy farms. It is not necessary, except on very small milksheds, to inspect all dairy farms since a sufficiently accurate determination of the percentage compliance with the sanitation requirements can be determined by surveying statistically selected dairy farms.
(a) Number of Dairy Farms to be Rated
(1) The minimum number of dairy farms to be included in the rating depends upon the number in the area to be rated and the accuracy desired. To obtain an accuracy such that the probable error in the individual percentages of compliance with the various items of sanitation will be less than 5 percent, the minimum number of dairy farms selected at random for inspection during the rating shall be taken from Table 1.
| Number in BTU or attached supply | Number to be rated |
|---|---|
| 1 to 24 | all |
| 25 to 54 | 25 |
| 55 to 59 | 26 |
| 60 to 64 | 27 |
| 65 to 71 | 28 |
| 72 to 78 | 29 |
| 79 to 86 | 30 |
| 87 to 94 | 31 |
| 95 to 105 | 32 |
| 106 to 116 | 33 |
| 117 to 130 | 34 |
| 131 to 147 | 35 |
| 148 to 167 | 36 |
| 168 to 191 | 37 |
| 192 to 222 | 38 |
| 223 to 262 | 39 |
| 263 to 316 | 40 |
| 317 to 394 | 41 |
| 395 to 514 | 42 |
| 515 to 725 | 43 |
| 726 to 1,192 | 44 |
| 1,193 to 5,000 | 50 |
| 5,001 to 10,000 | 100 |
| 10,001 to over | 200 |
(2) The preceding table is used to determine separately the number of dairy farms to be included in the rating. The probable error is not applicable to small samples. If the total number is 25 or less, the entire number must be rated.
(b) Random Selection of Dairy Farms to be Rated
The individual dairy farms included in the rating must be representative to reflect conditions throughout the BTU or attached supply. It is important that the selection method excludes elements of pre-selection and provides a truly random sample. The selection of farms for a rating should be made from a current listing of producers making up the BTU or attached supply and may be compared to a list for the previous 60 days to determine if an appreciable shifting of producers has taken place. Random selections, once made, should be deviated from only in cases of emergencies. Replacements, where necessary, should also be selected at random. Whenever possible, random selection or announcements of such selections for only one day's work at a time should be made. Examples of methods, which are satisfactory for the random selection for dairy farms, include the following:
(1) The name of each dairy farm in the BTU or attached supply is written on a small card, one name per card. These cards are then thoroughly shuffled and the number of dairy farms to be included in the rating as determined from the table in 2.a. (1) above is selected.
(2) The selection of dairy farms is made at intervals from a complete card index, ledger record, or other list. When this method is used, the sequence interval chosen must be such that the entire card index, ledger record, or other list is subject to the sampling method. The sequence interval may be determined by dividing the total number of dairy farms by the number needed for the rating. For example: if there were 293 dairy farms in the BTU or attached supply, Table 1 in 2.a. (1) above indicates that 40 will be included in the rating and the sequence interval in this case would be every seventh dairy. The first dairy farm in sequence is picked at random from the complete index or list in order that chance alone determines the selection of individual names.
(3) Immediately prior to the initial random drawing of dairy farms to be selected for inclusion in a rating, every producer, which produces 40% or more of the volume of milk in a BTU, which consists of 5 producers or more, must become a separate BTU.
(c) Recording of Inspection Data
(1) During a rating, inspection data are recorded on the form FDA 2359a, "Dairy Farm Inspection Report," the items of which correspond to the items of sanitation in Section 7 of the GRADE "A" PMO.
(2) Sanitary conditions are evaluated in terms of the requirements of Section 7 of the GRADE "A" PMO. Professional judgement alone must dictate whether an observed deficiency is representative of day-to-day significant conditions or is an anomaly. When significant violations of any given requirement are noted, the corresponding items or subitems on the individual dairy farm inspection form are marked with an "X". Each subitem found in violation should be carefully marked, as this affects the computation of the sanitation compliance rating. The number of pounds of milk sold daily is needed for computing the rating and is entered in the appropriate place at the top of each sheet.
Note: A deficiency should not be based entirely on discussion held with a farm employee. Confirmation of a deficiency should be made with responsible owner or manager in charge.
(d) Recording of Laboratory and Other Test Data
(1) Records on file with the regulatory agency are used in determining compliance with bacterial, drugs, somatic cell, and temperature requirements. The acceptance of data from official or officially designated laboratories is contingent upon the utilization of standard procedures by the laboratories concerned. Accordingly, it is necessary for the Milk Sanitation Rating Officer to determine from the Official State laboratory-certifying agency that both sampling and laboratory procedures have been approved in accordance with the methods of Evaluation of Milk Laboratories, 1978 Recommendations of the United States Public Health Service/Food and Drug Administration (1995 Revision) (EML). Rating shall not be conducted when an approved laboratory is not utilized by the regulatory agency for the necessary tests.
(2) Compliance with drug residue, bacteria, somatic cell, and cooling temperature requirements is based on whether, at the time of the rating, a dairy farm meets the standards of Section 7 of the GRADE "A" PMO. Credit for bacteria, somatic cell and cooling requirements shall be given if no more than two of the last four sample results exceed the limits. Provided, that the last sample result is within the limit. No credit for compliance with drug residue, bacterial, somatic cell and cooling temperature shall be given when less than the required number of samples have been examined during the preceding 6 months. For rating purposes, the preceding 6 months is considered to be the elapsed period of the month in which the rating is made and the preceding 6 months. Dairy farms which have had a permit for less than 6 months at the time of the rating and for which the regulatory agency has not yet examined the required number of samples, shall be given credit: Provided that the last sample result is within the limits.
(3) The Milk Sanitation Rating Officer may utilize the milk regulatory agency records in determining compliance with those items of sanitation which require laboratory tests to complete the evaluation.
a. Rating results are transferred to the computation form, FDA 2359k, "Status of Raw Milk for Pasteurization." These forms may be obtained from the regional offices of the PHS/FDA. The form is sufficiently flexible to permit various combinations of pages to be used for reporting ratings of area or individual shippers.
b. The identity of each dairy farm included in the rating and the total pounds of milk sold daily expressed to the nearest 100 pound unit (cwt.) (e.g., 3,760 pounds per day will result in an entry of 38 in column A) are entered in the first and second columns, respectively, of form FDA 2359k. Violations of items or subitems are indicated by an "X" in the appropriate columns. The sum of the weights of all items and subitems found violated at each dairy farm is entered in the column headed "Total Debits" (column B). This figure is then multiplied by the number in column A (Pounds Sold Daily-Nearest cwt.) and the results entered in column C entitled "Pounds Sold Daily (100 pound units) X Total Debits". When all entries have been made, the figures entered in this column are totaled as are the number of pounds sold daily by all the dairy farms rated. (See Section H, # 8 for example.)
c. The sanitation compliance rating is derived from the following formula:
Rating = 100 - (Sum of Column C [cwt. Sold Daily X Total Debits]) divided by (Sum of column A [cwt. Sold Daily]). This rating figure is entered in the appropriate space on the upper right hand corner of the page. It is also entered in the "Report of Milk Sanitation Ratings", FDA 2359j.
d. Provision is also made on the form for computing the percentage of dairy farms violating individual items of sanitation. The number of dairy farms violating each item may be totaled and the percentage computed by dividing this number by the total number of dairy farms rated and then multiplying by 100. The percentage of producers violating an item may also be determined by using the "Table for Computing Percent Violations". (Page 47).
During an IMS rating or check rating, it is necessary to determine compliance of the transfer station, receiving station, and processing plant with the requirements of Appendix N of the GRADE "A" PMO. The following criteria are to be used in making that determination. If the transfer station, receiving station and milk plant are not in substantial compliance, a rating or check rating is not to be completed and the State Rating Agency shall immediately withdraw IMS certification.
(a) Record Review.
Determine from records that are stored in a manner acceptable to the rating agency that all milk pick-up tankers are screened daily prior to processing for beta lactams with an approved test method; as necessary, determine that all producers are randomly tested 4 times in any consecutive 6 months for other drug residues if directed by M-a-75.
Transfer stations, receiving stations and milk plants having an attached supply with loads that occasionally are diverted by direct farm shipment shall be deemed in compliance if the following criteria are met:
(1) Records indicating that milk was always shipped to an IMS listed shipper will suffice for actual test results.
(2) If milk is shipped to a non-listed transfer station, receiving station and/or milk plant, records indicating actual testing must be provided or available for review. When the regulatory agency has determined adequate documentation for compliance with this section exists, the rating agency may accept this documentation. The responsible rating officer may at their discretion request records on the testing of loads of milk that are sent to non-listed plants.
(b) Regulatory Notification.
If a load of milk was found to have a positive drug residue, determine if the regulatory agency was properly notified.
(c) Industry Notification.
If a load of milk was found to have a positive drug residue, determine if the holder of the BTU or attached supply permit that the farms are attached to was properly notified.
Data from which ratings are determined are obtained by State Milk Sanitation Rating Officers from the records on file with the milk regulatory agency and from an evaluation of sanitary practices and facilities at milk plants, transfer stations, and receiving stations. Receiving stations and transfer stations may be considered as an integral part of the milk plant to which milk is shipped. Therefore, all such stations not having individual ratings and supplying the plant selected for rating must be included. Receiving stations and/or transfer stations, which are not an integral part of a milk plant, shall have individual ratings and may be rated, separate from their BTU's.
(a) Recording of Inspection Data
(1) During a rating, inspection data are recorded on the form "Milk Plant Inspection Report," FDA 2359. The items of this form correspond to the items of sanitation in Section 7 of the GRADE "A" PMO.
(2) Sanitary conditions are evaluated in terms of the requirements of Section 7 of the GRADE "A" PMO. Professional judgment alone must dictate whether an observed deficiency is representative of day-by-day sanitary conditions or is an anomaly. When significant violations of any given requirement are noted, the corresponding items or subitems on the individual milk plant inspection form are marked with an "X". Each Subitem found in violation should be carefully marked, as this affects the computation of the sanitation compliance rating.
(3) The average number of pounds of milk and milk products processed daily is needed for computing the rating and is entered in the appropriate place at the top of the "Milk Plant Inspection Report," FDA 2359. When a deficiency in a milk plant affects only one type of packaging (paper; glass; single-service plastics; multi-use plastics; dispenser; cottage cheese; sour cream or yogurt containers) or the capping of these containers, or an individual pasteurization unit used (HTST, HHST, aseptic, or vat), only the quantity of all products affected by the deficiency, rather than the entire plant output, is recorded for use in the computation of the plant sanitation compliance rating. Only violations of Items 16p, 18p and 19p of the GRADE "A" PMO are to receive partial debits. Provided that bacterial and Coliform counts may be partially debited for the particular product involved. All other violations should be considered as affecting the entire product output of the milk plant.
(b) Recording of Laboratory and Other Test Data
(1) Regulatory agency records are used in determining compliance with bacterial, Coliform, phosphatase, drug, and temperature requirements. The acceptance of data from official or officially designated laboratories is contingent upon the utilization of standard procedures by the laboratories concerned. Accordingly, it is necessary for the Milk Sanitation Rating Officer to determine from the Official State laboratory-certifying agency that both sampling and laboratory procedures have been approved in accordance with the methods of the EML. Ratings shall not be conducted when an approved laboratory is not utilized by the regulatory agency for the necessary tests.
(2) Compliance with requirements for bacterial counts, Coliform counts, and cooling temperatures is based on whether, at the time of the rating, a plant's products meet the standards of Section 7 of the GRADE "A" PMO. Each product (including commingled raw milk prior to pasteurization) in each of these categories shall be debited if 2 of the last 4 sample results exceed the limits, and the last sample result is in violation. A debit shall be given when less than the required number of samples has been examined during the preceding 6 months. For rating purposes, the preceding 6 months is considered to be the elapsed period for the month in which the rating is made and the preceding 6 months. Milk plants which have had a permit for less than 6 months at the time of the rating and milk or whey drying plants which do not operate on a year round basis and for which the regulatory agency has not yet examined the required number of samples shall not be debited. Provided that the last sample result is within the limit.
(3) The Milk Sanitation Rating Officer may utilize regulatory agency records in determining compliance with those items of sanitation which require laboratory tests to complete the evaluation. Official records of field tests may also be used in lieu of performing such tests during the rating. Provided that the Milk Sanitation Rating Officer is satisfied as to the competency of the regulatory agency personnel to perform these tests as described in Appendix I of the GRADE "A" PMO.
a. Rating results are transferred to the computation form, "Status of Milk Plants," FDA 2359L, which may be obtained from the regional offices of the Public Health Service/Food and Drug Administration. The name of the plant and the total pounds of milk and milk products processed daily (expressed to the nearest 100 pound unit [cwt.], e.g., 86,340 pounds per day will be an entry of 863) are entered in the first and second columns, respectively. If the plant's daily output varies, the daily average (based on actual operating days) for the week preceding the rating is used to calculate pounds processed daily. Violations of items or subitems are indicated by an "X" in the appropriate column. When a deficiency in a milk plant affects one type of packaging, capping, or individual pasteurization unit used the number of pounds of all products so packaged or pasteurized are debited. In such cases, entries are made on separate lines below the name of the plant concerned. The name or names of the product(s) affected by the violation(s) of Items 16p, 18p, and 19p, or the bacterial or Coliform standards of the GRADE "A" PMO is entered in the first column together with a parenthetic entry of the total volume in 100 pound units (cwt.) of the product(s) involved. Care must be taken not to enter this quantity in the second column where it would again be included in the total pounds processed daily. (See Section H, # 9 and 10 for examples.)
b. For receiving or transfer stations operated by the plant and under the same routine supervision as the plant and shipping to the plant, the name of the station is entered in the first column, together with a parenthetic entry of the hundredweight (cwt.) shipped daily. No entry is made in the second column (column A).
If the pounds shipped daily by a station to the milk plant varies, the recorded quantity is the daily average (based on actual operating days) of the shipments for the week preceding the rating. Violations of items or subitems are indicated by an "X" in the appropriate following column(s). To facilitate the rating computations, receiving station's or transfer station's entries follow the entries for the milk plant. If the rating of the receiving station or transfer station is equal to, or higher than, that of the milk plant, or equal to 90 percent or higher, the milk plant rating is considered as being inclusive of the receiving station(s) or transfer station(s) violations and no entry is made in the "Total Debits," column B, for the station. However, if the receiving station or transfer station rating is less than 90 percent and lower than the plant, it is subtracted from the rating of the milk plant(s) which it supplies and the difference is entered in the "Total Debits" column B.
This difference is then multiplied by the quantity of milk shipped daily by the receiving or transfer station to the milk plant and entered in the column headed "cwt. Processed Daily X Total Debits," column C. (See Section H, # 11 for examples of these calculations.)
c. The computation procedure for a milk plant is similar to that for dairy farms, except that a modified procedure is necessary in computing debits for violations involving only one type of packaging, capping or individual pasteurization unit, or individual products violating the bacterial or Coliform standards and for violations involving receiving or transfer stations (where the latter is explained in the preceding paragraph). For such violations, the entry in column B, "Total Debits," is multiplied by the actual number of pounds of product involved, as entered parenthetically in the first column, rather than by the entire plant output from column A. This figure in entered in column C, "cwt. Processed Daily X Total Debits." The formula for determining the sanitation compliance rating for the milk plant is as follows:
Rating = 100 - (Sum of column C [cwt. Processed Daily X Total Debits]) divided by (Sum of column A [cwt. Processed Daily]).
d. This rating figure is entered in the appropriate space in the upper right hand corner of the form entitled "Status of Milk Plants," FDA 2359L. It is also entered on the form entitled "Report of Milk Sanitation Rating," FDA 2359j, in the appropriate place.
e. The name(s) of the bulk tank unit(s), receiving station(s) and/or transfer station(s) shipping into the milk plant, which are separately rated and listed are also entered in the first column below the name of the plant but the quantity of milk supplied daily is entered parenthetically in the same manner as for locally supervised stations. The poundage is not recorded in the second column (column A) since this quantity is already accounted for in the milk plant figures. If the rating for the transfer station(s) and/or receiving station(s) is equal to, or higher than that of the milk plant, the plant rating is considered as being inclusive of the station(s) violations, therefore, no entry is made in column B, "Total Debits." However, if the receiving station(s) and/or transfer station(s) rating is less than 90 and lower than that of the milk plant, the difference is entered in column B, "Total Debits." This difference is then multiplied by the number of pounds shipped daily by the receiving station(s) and/or transfer station(s) to the milk plant and entered in column C entitled "cwt. Processed Daily X Total Debits."
f. If, upon receipt, one or more shipper(s) of unattached raw milk for pasteurization violates bacterial, and/or cooling requirements, the violations are debited against the rating of the receiving station(s) and/or transfer station(s) shipping the milk prior to combining the ratings in accordance with the methods described above.
a. The form, FDA 2359j, consists of two parts. The "Report of Milk Sanitation Rating" is on the front side and the "Report of Enforcement Methods" is on the back. (See Section G, # 1 and 2 for an example of these forms.) This form provides a means of measuring the degree to which the enforcement provisions of the GRADE "A" PMO are being applied by the regulatory agency. It serves to delineate specific areas where a milk sanitation program needs strengthening. The rating method provides for separate appraisals of these provisions as they are applied to dairy farms and milk plants. In some cases, the enforcement rating is derived by combining these appraisals with an appraisal of other regulatory actions for which the milk regulatory agency is responsible.
b. Appraisal of items is based on the Milk Sanitation Rating Officer's observations during the rating and his/her review of the regulatory agency's records for the lesser of the following periods:
(1) The period since the last rating, but not less than 6 months or,
(2) The 2 years preceding the date of the current rating.
c. Enforcement rating scores shall be computed utilizing Appendix A, (Guidelines for Computing Enforcement Ratings) (See Page 49).
d. The enforcement rating applies directly to the individual regulatory agency; therefore, there are no provisions for combining the enforcement ratings of two or more enforcement agencies. Enforcement ratings shall be made in accordance with the procedures in the following paragraphs.
e. For rating purposes, to determine inspections have been made at the established frequency, the interval shall include the designated period plus the remaining days of the month in which the inspection is due.
a. When an individual shipper offers for sale only raw milk for pasteurization directly from dairy farms, known as a bulk tank unit, (there are no receiving/transfer stations, or plant involved) all items in Part I, FDA 2359j should be evaluated. The total of the credit column of Part I will be the enforcement rating and should be recorded on page 1 of this form in the appropriate place. (See Section H # 6 and 1 for examples).
b. When an item requires separate action on the part of the regulatory agency with respect to each dairy farm, compliance is prorated on the proportion of dairy farms included in the rating for which official records show the item to have been satisfied. When an item requires an action by the regulatory agency that affects the entire program, quantitative estimates of compliance by the above-described procedure are not applicable. These items have the percent complying column of the schedule blocked out and the full weight of the items is debited or credited, depending upon whether the milk sanitation program is satisfying the pertinent provisions of the GRADE "A" PMO. In appraising these items, the Milk Sanitation Rating Officer's judgement should be based on the attainment of objectives toward which the provisions of the appropriate sections are directed and not on occasional circumstances or insignificant deviations in procedure. (See Section H, #6 for example).
c. For rating purposes, to determine if inspections have been made at the established frequency, the interval shall include the designated period plus the remaining days of the month in which the test is due.
d. For dairy farms inspected under the provisions of Appendix P the following rating criteria applies:
a. When an individual shipper offers for sale raw milk for pasteurization which is shipped from a receiving station, transfer station, or milk plant with one or more dairy farms rated with it, all items in Part II (Milk Plants) except items 5, 7, 8, and all items in Part III (Individual Shipper Rating) shall be evaluated. When a receiving station and/or transfer station receives and trans- ships raw milk for pasteurization from one or more rated and listed BTU's and wishes a separate listing for its facilities, all items in Part II except 5, 7 and 8, and all items in Part III except 1 shall be evaluated; The procedures outlined in 3.b and 4.a (3) should be followed in computing the enforcement rating of the receiving station and/or transfer station.
b. The total weight, which can be earned in Part II, is 65. Therefore, the sum of the total credits earned in Part II should be divided by 65 and multiplied by 100. For example: Assume that addition of all credits (omitting items 5, 7 and 8) under Part II equals 60. Then 60 divided by 65 multiplied by 100 equals 92.3 percent. Fractions of 0.5 or higher are increased to the next whole number and fractions of less than 0.5 are dropped. Under these rules, the 92.3 percent in this example would equal 92 percent. The sum of the credits in Parts I and II is transferred to Part III. The sum of the credits in Part III will be the enforcement rating of the regulatory agency. (See Section H, #4 for examples of these calculations).
c. When an item requires separate action on the part of the milk regulatory agency with respect to each receiving station or transfer station, compliance is based on the proportion of receiving stations or transfer stations that are included in the rating for which local records show the item to have been satisfied. If an item requires more than one test or determination (Part II, Items 2, 4, 6, 9, and 10), then compliance is also based on the proportion of tests or determinations which, according to local records, were made at the required frequency. For example: If only 6 of the required 8 inspections were made in the past 2 years, the compliance would be 6/8 or 75 percent.
d. When an item requires an action by the regulatory agency, which affects the entire control program, quantitative estimates of compliance by the procedure described in the preceding paragraph are not applicable. These items have the "Percent Complying" column of the schedule blocked out, and the full weight of the item is debited or credited, depending upon whether the program being rated is satisfying the pertinent provisions of the GRADE "A" PMO. In appraising these items, the milk Sanitation Rating Officer's judgement should be based on the attainment of objectives toward which the milk sanitation regulations are directed and not on occasional circumstances or insignificant deviations in procedure.
(a) Milk Plant With Unattached Supply of Raw Milk
(1) When an individual shipper of pasteurized milk and milk products imports all raw milk for pasteurization from outside the jurisdiction of the regulatory agency in which the plant is located, only Part II and III of "Report of Enforcement Methods," FDA 2359j, page 2, shall be evaluated. If an item requires more than one test or determination (Part II, numbers 2, 4, 5, 6, 7, 8, 9, and 10), then compliance is also based on the proportion of tests or determinations which, according to local records, were made at the required frequency. For example: In an enforcement rating all required tests must be performed on each individual pasteurizer to receive credit. Compliance is determined by multiplying the number of pasteurizers (units) by the number of 3-month periods (quarters) in a rating period. For example, if a plant with 4 pasteurizers is rated over a 2 year span and 1 pasteurizer is not completely tested during 1 quarter, then compliance is calculated as: 4 X 8 = 32 Unit-Quarters, less one non-complying quarter = 31/32 X 15 = 14.5 points.
For rating purposes, to determine if the required tests have been performed at the established frequency, the interval shall include the designated period plus the remaining days of the month in which the test is due.
(2) When an item requires an action by the regulatory agency, which affects the entire control program, quantitative estimates of compliance by the procedure described in the preceding paragraph are not applicable. These items have the "Percent Complying" column of the schedule blocked out, and the full weight of the item is debited or credited, depending upon whether the program being rated is satisfying the pertinent provision of the GRADE "A" PMO. In appraising these items, the Milk Sanitation Rating Officer's judgement should be based on the attainment of objectives toward which the milk sanitation regulations are directed and not on occasional circumstances or insignificant deviations in procedure.
(3) The utilization of milk from a separately rated source which has a milk sanitation compliance and/or enforcement rating which is not equal to 90 percent or higher is a violation of Section 11 of the GRADE "A" PMO and would be debited on Item 4, Part III, "Report of Enforcement Methods", Form FDA 2359j.
(4) When computing Part III, there will be zero credit in Item 1. It will be necessary to increase the weight for Item 2 to .90 to negate the zero credit in Item 1. Example: Total credit in Part II is 94 and Items 3 and 4 of Part III have full credit of 4 and 6 respectively, the calculations will be: (94 X .90) = 84.60 + 10 = 94.6 or 95 percent enforcement rating. (See Section H, # 2 for example).
(b) Milk Plant with Attached Supply of Raw Milk
(1) When an individual shipper of pasteurized milk and/or milk products receives raw milk for pasteurization from within the jurisdiction of the regulatory agency in which the plant is located, Parts I, II, and III of "Report of Enforcement Methods," FDA 2359j, page 2 shall be evaluated. If raw milk for pasteurization is received from both attached and unattached supplies, only those sources from attached supplies will be evaluated in Part I. Milk from unattached supplies will be evaluated in Item 4, Part III. If an item requires more than one test or determination (Part II numbers 2, 4, 5, 6, 7, 8, 9, and 10) then compliance is also based on the proportion of tests or determinations which, according to local records, were made at the required frequency. For example: if, in an enforcement rating of a milk plant, only 8 of the required 10 individual dairy products had been sampled at the required frequency during the preceding required time period, the compliance would be 8/10 or 80 percent under Part II, number 7.
(2) When an item requires an action by the regulatory agency, which affects the entire control program, quantitative estimates of compliance by the procedure described in the preceding paragraph are not applicable. These items have the "Percent Complying" column of the schedule blocked out, and the full weight of the item is debited or credited, depending upon whether the program being rated is satisfying the pertinent provisions of the GRADE "A" PMO. In appraising these items, the Milk Sanitation Rating Officer's judgement should be based on the attainment of objectives toward which the milk sanitation regulations are directed and not on occasional circumstances or insignificant deviations in procedure.
(3) The utilization of milk from a separately rated source which has a milk sanitation compliance and/or enforcement rating which is not equal to 90 percent or higher is a violation of Section 11 of the GRADE "A" PMO and would be debited on Item 4, Part III, "Report of Enforcement Methods" Form, FDA 2359j.
Ratings made by the methods described measure the degree to which the shipper and enforcement practices of a regulatory agency conform to the standards and procedures contained in the GRADE "A" PMO. Space is provided on the "Report of Milk Sanitation Rating," page 1 of FDA 2359j, for presenting a summary of rating results and recommendations of the Milk Sanitation Rating Officer.
Sanitation compliance ratings computed in accordance with procedures previously described and other data pertinent to the shipper are entered in the "Summary of Rating Results." When the sanitation compliance rating of raw milk for pasteurization has been combined with the rating(s) of unattached supplies in accordance with the conditions and procedures found under "Preparation of Interstate Milk Shipper Reports" Section F.2.c. (2) or F.2.c. (3)(b); the combined rating, rather than the rating of the attached supply is entered in the summary.
In the course of conducting a rating and computing ratings, additional facts may become apparent which, if presented, would be of value to the regulatory agency in directing the local milk sanitation program so as to be more effective. Milk Sanitation Rating Officers are urged to prepare a supplementary narrative report of their rating findings. This report should include, but not be limited to, the following:
a. A statement regarding the general status of the milk sanitation program, including both strengths and weaknesses.
b. Discussion of needs for greater program emphasis as indicated by the compliance levels of sanitation items and enforcement practices found during the rating.
A summary of the narrative report, including the specific measures recommended for program improvement, is entered on page 1 of FDA 2359j, under the heading "Recommendations of Milk Sanitation Rating Officer." The full report should be discussed in detail with the appropriate officials of the regulatory agency. Such discussions contribute to better understanding of the problems involved and provide local regulatory agency authorities with an opportunity to discuss means of implementing the Milk Sanitation Rating Officer's recommendations. (See Section H, # 1 for example).
a. The Sanitation Compliance and Enforcement Ratings of Interstate Milk Shippers (IMS List) is a biannual publication of the Milk Safety Team, Food and Drug Administration, Washington, DC 20204. This is a part of the activities of the Food and Drug Administration in cooperation with the States in their joint program for certification of interstate milk shippers.
b. Triplicate copies of the "Interstate Milk Shipper Report," FDA 2359i (see Section G, # 6 for example), shall be submitted by the State to the appropriate regional office of the Food and Drug Administration for shippers who desire to be listed in the publication referred to in paragraph (a.) above. The biannual lists are published on the first day of January and July and the publication deadline for inclusion in the succeeding list is not later than the first day of the preceding month. Sanitation compliance ratings of a shipper are not published unless the written permission of the shipper concerned has been obtained by the State milk sanitation rating agency. One copy of this written permission should accompany each triplicate set of "Interstate Milk Shipper Report," FDA 2359i, submitted to the Food and Drug Administration Regional Office. Once a shipper has been listed, all new ratings must be submitted to the regional office even though the shipper has refused to sign a written permission for publication. Supporting sampling and laboratory certification reports, as specified in the Procedures Governing the Cooperative State-Public Health Service/Food and Drug Administration Program for Certification of Interstate Milk Shippers, are also necessary for inclusion and retention of the shipper on the list.
(a) Individual Shipper of Raw Milk For Pasteurization
This shipper is commonly referred to as a bulk tank unit or BTU. Following computation of the sanitation compliance rating, Form FDA 2359k, and Part I, "Report of Enforcement Methods," FDA 2359j, the resultant data will be transferred to the "Interstate Milk Shipper Report," 2359i (see Section G, # 6 for example). The earliest rating date shall be the date of the first day of the rating.
(b) Receiving Station or Transfer Station
Following computation of the sanitation compliance rating on forms FDA 2359k and FDA 2359L and Parts I, II, and III of "Report of Enforcement Methods," FDA 2359j, the resultant data will be transferred to the "Interstate Milk Shipper Report," FDA 2359i. The earliest rating date shall be the first day of the rating. When receiving and/or transfer stations who wish a separate listing and receive raw milk for pasteurization from one or more rated and listed BTU's for trans- shipment, the procedures to be followed shall be that of F.2.c. (2) or F.2.c. (3).
(c) Milk Plants
(1) ATTACHED SUPPLY ONLY
(Plant with a single source of raw milk, both under the jurisdiction of the same regulatory agency).
Following computation of the sanitation compliance rating on forms FDA 2359k and FDA 2359L and Parts I, II, III of "Report of Enforcement Methods," FDA 2359j, the resultant data will be transferred to the "Interstate Milk Shipper Report," FDA 2359i. The earliest rating date shall be the first day of the rating of the farms or plant whichever is earliest in time.
(2) ATTACHED SUPPLY AND UNATTACHED SUPPLIES
(Plant with source of raw milk for pasteurization under the jurisdiction of the same regulatory agency as the plant and one or more sources of raw milk for pasteurization from other separate rated and listed sources).
Following computation of the sanitation compliance rating on forms FDA 2359k and FDA 2359L and Parts I, II, III of "Report of Enforcement Methods," FDA 2359j, the resultant data will be transferred to the "Interstate Milk Shipper Report," FDA 2359i. (See Section G, #6 for an example). The earliest rating date and the raw milk sanitation compliance rating shall be computed by the following method.
All unattached supplies shall have a sanitation compliance rating of 90 percent or greater. The sanitation compliance rating of the attached supply shall be reported as the raw milk sanitation compliance rating for the plant. The earliest rating shall be reported on the "Interstate Milk Shipper Report," FDA 2359i. In addition, all unattached supplies, during the 30 days preceding the rating, along with the sanitation compliance rating and rating date of each source shall be listed on the reverse side of the "Interstate Milk Shipper Report," FDA 2359i. If milk is received from an unlisted source or from a source having a raw milk sanitation rating of less than 90 percent, the Food and Drug Administration Regional Office shall be notified and the plant shall be immediately withdrawn from the Interstate Milk Shipper List.
(3) ONLY UNATTACHED SUPPLIES
(Plant with one or more sources of raw milk received from other rated and listed sources).
Following computation of the sanitation compliance rating on the form FDA 2359L, and Parts II and III of "Report of Enforcement Methods", FDA 2359j, the resultant data will be transferred to the "Interstate Milk Shipper Report," FDA 2359i. The earliest rating date and the milk sanitation compliance rating shall be computed by one of the two following options:
(a) Option 1. If all raw milk sources have a published (or submitted for publication) sanitation compliance rating of 90 percent or greater and the plant desires to be listed with the plant rating date, the raw milk will be reported as 90 percent or listed with an asterisk (*) which denotes all supplies are 90 percent or greater. This will eliminate the need for frequent updating of the form, FDA 2359i, by the State milk sanitation rating agency but certain precautions must be taken to insure that the raw supply remains at or above the listed 90 percent sanitation compliance rating. All sources of raw milk for the 30 days preceding the rating and their date of rating must be listed on the reverse side of the form, FDA 2359i. The plant shall be immediately withdrawn from the Interstate Milk Shippers' List when milk is received from an unlisted source or from a source having a raw milk sanitation compliance rating of less than 90 percent. The appropriate Food and Drug Administration Regional Office shall be immediately notified should either of the above events occur.
(b) Option 2. If the plant desires to be listed with the actual sanitation compliance rating of the raw milk (a weighted average of all raw milk sources), the requirements of the proceeding option shall also apply except that:
1) The earliest rating date of any of the raw milk sources or the plant, whichever is earliest in time, will be shown as the earliest rating date on the "Interstate Milk Shipper Report," FDA 2359i.
2) The raw milk sanitation compliance rating will be prorated on a weighted basis in a method similar to the following:
| Supply SCR X Percent of Supply = |
| Unattached supply #1 95.0 X .20 = 19.0 |
| Unattached supply #2 90.0 X .35 = 31.5 |
| Unattached supply #3 92.0 X .45 = 41.4 |
| Total = 91.9 |
| Raw Milk SCR = 92% |
The State Milk Sanitation Rating Officer shall re-compute the raw milk sanitation compliance rating whenever any of the raw milk sources is re-rated and a new FDA 2359i shall be submitted to the Food and Drug Administration Regional Office.
NOTE: The acceptance of milk which is rated less than 90 percent, is a violation of the agreed upon provisions of Option 1, and would initiate an immediate withdrawal of the shippers name from the Interstate Milk Shippers List.
In the case of a plant utilizing only one unattached supply, and that supply is rated less than 90, the sanitation compliance rating of the supply shall be shown on the 2359i, and no credit shall be given under Item 4, Part III, "Report of Enforcement Methods," FDA 2359j.
G. EXAMPLES OF RATING FORMS (PDF, 100KB)
The following pages contain examples of blank forms used in IMS ratings. These forms include:
1. FDA Form 2359j (Page 1) – Report of Milk Sanitation Rating
2. FDA Form 2359j (Page 2) – Report of Enforcement Methods
3. FDA Form 2359k - Status of Raw Milk for Pasteurization
4. FDA Form 2359L – Status of Milk Plants including Receiving Stations
5. FDA Form 2359L - Status of Condensed and Dry Milk Plants
6. FDA Form 2359i – Interstate Milk Shippers Report
7. Evaluation of Sampling Procedures
H. EXAMPLES FOR COMPUTING RATINGS (PDF, 112KB)
The following pages provide examples of forms that have been completed to demonstrate how observations would be recorded. These include:
1. Report of Milk Sanitation Rating (2359j)
2. Report of Enforcement Methods (Plant only) (2359j)
3. Evaluation of Sampling Procedures (Plant) (Part II, Item 8)
4. Report of Enforcement Methods (Receiving station and BTU) (2359j)
5. Evaluation of Sampling Procedures (Farms Only) (Part I, Item 9)
6. Report of Enforcement Methods (BTU – 2359j)
7. Evaluation of Sampling Procedures (Farms Only) (Part I, Item 9)
8. Status of Raw Milk for Pasteurization (2359k)
9. Status of Milk Plant (2359L)
10. Status of Condensed and Dry Milk Plant (2359L)
11. Status of Milk Plant (Plant and Receiving Stations) (2359L)
12. Interstate Milk Shippers Report (2359i)
| Number of Dairies or Plants in Sample | ||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 | 9 | 10 | 11 | 12 | 13 | 14 | 15 | 16 | 17 | 18 | 19 | 20 | 21 | 22 | 23 | 24 | 25 | 26 | 27 | 28 | 29 | 30 | 31 | 32 | 33 | 34 | 35 | 36 | 37 | 38 | 39 | 40 | 41 | 42 | 43 | 44 | 50 | ||
| 100 | 50 | 33 | 25 | 20 | 17 | 14 | 13 | 11 | 10 | 9 | 8 | 8 | 7 | 7 | 6 | 6 | 6 | 5 | 5 | 5 | 5 | 5 | 5 | 4 | 4 | 4 | 4 | 3 | 3 | 3 | 3 | 3 | 3 | 3 | 3 | 3 | 3 | 3 | 3 | 2 | 2 | 2 | 2 | 2 | 1 |
Number of Plants or Dairies Violating an Item |
| 100 | 67 | 50 | 40 | 33 | 29 | 25 | 22 | 20 | 18 | 17 | 15 | 14 | 13 | 13 | 12 | 11 | 11 | 10 | 10 | 9 | 9 | 8 | 8 | 8 | 7 | 7 | 7 | 7 | 7 | 6 | 6 | 6 | 6 | 6 | 5 | 5 | 5 | 5 | 5 | 5 | 5 | 5 | 4 | 2 | ||
| 100 | 75 | 60 | 50 | 43 | 38 | 33 | 30 | 27 | 25 | 23 | 21 | 20 | 19 | 18 | 17 | 16 | 15 | 14 | 14 | 13 | 13 | 12 | 12 | 11 | 11 | 10 | 10 | 10 | 9 | 9 | 9 | 9 | 8 | 8 | 8 | 8 | 8 | 7 | 7 | 7 | 7 | 6 | 3 | |||
| 100 | 80 | 67 | 57 | 50 | 44 | 40 | 36 | 33 | 31 | 29 | 27 | 25 | 24 | 22 | 21 | 20 | 19 | 16 | 17 | 17 | 16 | 15 | 15 | 14 | 14 | 13 | 13 | 13 | 12 | 12 | 11 | 11 | 11 | 11 | 10 | 10 | 10 | 10 | 9 | 9 | 8 | 4 | ||||
| 100 | 83 | 72 | 63 | 56 | 50 | 45 | 42 | 38 | 36 | 33 | 31 | 29 | 28 | 26 | 25 | 24 | 23 | 22 | 21 | 19 | 19 | 18 | 17 | 17 | 16 | 16 | 15 | 15 | 14 | 14 | 14 | 13 | 13 | 13 | 12 | 12 | 12 | 12 | 11 | 10 | 5 | |||||
| 100 | 86 | 75 | 67 | 60 | 55 | 50 | 46 | 43 | 40 | 38 | 35 | 33 | 32 | 30 | 29 | 27 | 26 | 25 | 24 | 23 | 22 | 21 | 21 | 20 | 19 | 19 | 18 | 18 | 17 | 17 | 16 | 16 | 15 | 15 | 15 | 14 | 14 | 14 | 12 | 6 | ||||||
| 100 | 88 | 78 | 70 | 64 | 58 | 54 | 50 | 47 | 44 | 41 | 39 | 37 | 35 | 33 | 32 | 30 | 29 | 28 | 27 | 26 | 25 | 24 | 23 | 23 | 22 | 21 | 21 | 20 | 19 | 19 | 18 | 18 | 18 | 17 | 17 | 16 | 16 | 14 | 7 | |||||||
| 100 | 89 | 80 | 73 | 67 | 62 | 57 | 53 | 50 | 47 | 44 | 42 | 40 | 38 | 36 | 35 | 33 | 32 | 31 | 30 | 29 | 28 | 27 | 26 | 25 | 24 | 24 | 26 | 22 | 22 | 21 | 21 | 20 | 20 | 19 | 19 | 18 | 16 | 8 | ||||||||
| 100 | 90 | 82 | 75 | 69 | 64 | 60 | 56 | 53 | 50 | 47 | 45 | 43 | 41 | 39 | 38 | 36 | 35 | 33 | 32 | 31 | 30 | 29 | 28 | 27 | 26 | 26 | 25 | 24 | 23 | 23 | 22 | 22 | 21 | 21 | 20 | 18 | 9 | |||||||||
| 100 | 91 | 83 | 77 | 72 | 67 | 63 | 59 | 56 | 53 | 50 | 48 | 46 | 44 | 42 | 40 | 38 | 37 | 36 | 35 | 33 | 32 | 31 | 30 | 29 | 29 | 28 | 27 | 26 | 25 | 25 | 24 | 24 | 23 | 23 | 20 | 10 | ||||||||||
| 100 | 92 | 85 | 79 | 74 | 69 | 65 | 61 | 58 | 55 | 52 | 50 | 48 | 46 | 44 | 42 | 41 | 39 | 38 | 37 | 36 | 34 | 33 | 32 | 31 | 31 | 30 | 29 | 28 | 28 | 27 | 26 | 26 | 25 | 22 | 11 | |||||||||||
| 100 | 92 | 86 | 80 | 75 | 71 | 67 | 63 | 60 | 57 | 55 | 52 | 50 | 48 | 46 | 45 | 43 | 41 | 40 | 39 | 38 | 36 | 35 | 34 | 33 | 32 | 32 | 31 | 30 | 29 | 29 | 28 | 27 | 24 | 12 | ||||||||||||
| 100 | 93 | 87 | 81 | 77 | 72 | 69 | 65 | 62 | 59 | 57 | 54 | 52 | 50 | 48 | 46 | 45 | 43 | 42 | 41 | 39 | 38 | 37 | 35 | 35 | 36 | 33 | 33 | 32 | 31 | 30 | 30 | 26 | 13 | |||||||||||||
| 100 | 93 | 88 | 82 | 78 | 74 | 70 | 67 | 64 | 61 | 58 | 56 | 54 | 52 | 50 | 48 | 47 | 44 | 44 | 42 | 41 | 40 | 39 | 38 | 37 | 36 | 35 | 34 | 33 | 33 | 32 | 28 | 14 | ||||||||||||||
| 100 | 94 | 88 | 83 | 79 | 75 | 72 | 68 | 65 | 63 | 60 | 58 | 56 | 54 | 52 | 50 | 48 | 47 | 45 | 44 | 43 | 42 | 43 | 40 | 39 | 38 | 37 | 36 | 35 | 34 | 30 | 15 | |||||||||||||||
| 100 | 94 | 90 | 85 | 80 | 76 | 73 | 70 | 67 | 64 | 62 | 59 | 57 | 55 | 53 | 52 | 50 | 49 | 47 | 46 | 44 | 43 | 42 | 41 | 40 | 39 | 38 | 37 | 36 | 32 | 16 | ||||||||||||||||
| 100 | 94 | 90 | 85 | 81 | 77 | 74 | 71 | 68 | 65 | 63 | 61 | 59 | 57 | 55 | 53 | 52 | 50 | 49 | 47 | 46 | 45 | 44 | 43 | 42 | 41 | 40 | 39 | 34 | 17 | |||||||||||||||||
| 100 | 94 | 90 | 86 | 82 | 78 | 75 | 72 | 69 | 67 | 64 | 62 | 60 | 58 | 56 | 55 | 53 | 51 | 50 | 49 | 47 | 46 | 45 | 44 | 43 | 42 | 41 | 36 | 18 | ||||||||||||||||||
| 100 | 95 | 90 | 87 | 83 | 79 | 76 | 73 | 70 | 68 | 66 | 63 | 61 | 59 | 58 | 56 | 54 | 53 | 51 | 50 | 49 | 48 | 46 | 45 | 44 | 43 | 38 | 19 | |||||||||||||||||||
| 100 | 95 | 91 | 87 | 83 | 80 | 77 | 74 | 71 | 69 | 66 | 65 | 63 | 61 | 59 | 57 | 56 | 54 | 53 | 51 | 50 | 49 | 48 | 47 | 46 | 40 | 20 | ||||||||||||||||||||
| 100 | 96 | 91 | 88 | 84 | 81 | 78 | 75 | 72 | 70 | 68 | 66 | 64 | 62 | 60 | 58 | 57 | 55 | 54 | 53 | 51 | 50 | 49 | 48 | 42 | 21 | |||||||||||||||||||||
| 100 | 96 | 92 | 88 | 85 | 82 | 79 | 76 | 73 | 71 | 69 | 68 | 65 | 63 | 61 | 60 | 58 | 57 | 55 | 54 | 52 | 51 | 50 | 44 | 22 | ||||||||||||||||||||||
| 100 | 96 | 92 | 89 | 85 | 82 | 79 | 77 | 74 | 72 | 70 | 68 | 66 | 64 | 62 | 61 | 59 | 58 | 56 | 55 | 54 | 52 | 46 | 23 | |||||||||||||||||||||||
| 100 | 96 | 92 | 89 | 86 | 83 | 80 | 77 | 75 | 73 | 71 | 69 | 67 | 65 | 63 | 62 | 60 | 59 | 57 | 56 | 54 | 48 | 24 | ||||||||||||||||||||||||
| 100 | 96 | 93 | 89 | 86 | 83 | 81 | 78 | 76 | 74 | 72 | 70 | 68 | 66 | 64 | 63 | 61 | 60 | 58 | 57 | 50 | 25 | |||||||||||||||||||||||||
| Example: An item violated 16 times in survey of 25 dairy farms equals 64% violation. | 100 | 96 | 93 | 90 | 87 | 84 | 81 | 79 | 77 | 74 | 72 | 70 | 68 | 67 | 65 | 63 | 62 | 61 | 59 | 52 | 26 | |||||||||||||||||||||||||
| 100 | 96 | 93 | 90 | 87 | 84 | 82 | 79 | 77 | 75 | 73 | 71 | 69 | 68 | 66 | 65 | 63 | 61 | 54 | 27 | |||||||||||||||||||||||||||
| 100 | 97 | 93 | 90 | 87 | 85 | 82 | 80 | 78 | 76 | 74 | 72 | 70 | 68 | 67 | 65 | 64 | 56 | 28 | ||||||||||||||||||||||||||||
| 100 | 97 | 94 | 91 | 88 | 85 | 83 | 81 | 78 | 76 | 74 | 73 | 71 | 69 | 67 | 66 | 58 | 29 | |||||||||||||||||||||||||||||
| 100 | 97 | 94 | 91 | 88 | 86 | 83 | 81 | 79 | 77 | 75 | 73 | 71 | 70 | 68 | 60 | 30 | ||||||||||||||||||||||||||||||
TABLE FOR COMPUTING PERCENT
(Percentage rounded to nearest whole number)
|
100 | 97 | 94 | 91 | 89 | 86 | 84 | 82 | 80 | 78 | 76 | 74 | 72 | 71 | 62 | 31 | ||||||||||||||||||||||||||||||
| 100 | 97 | 94 | 92 | 89 | 87 | 84 | 82 | 80 | 78 | 76 | 74 | 73 | 64 | 32 | ||||||||||||||||||||||||||||||||
| 100 | 97 | 94 | 92 | 89 | 87 | 85 | 83 | 81 | 79 | 77 | 75 | 66 | 33 | |||||||||||||||||||||||||||||||||
| 100 | 97 | 94 | 92 | 90 | 87 | 85 | 83 | 81 | 79 | 77 | 68 | 34 | ||||||||||||||||||||||||||||||||||
| 100 | 97 | 95 | 92 | 90 | 88 | 85 | 83 | 81 | 80 | 70 | 35 | |||||||||||||||||||||||||||||||||||
| 100 | 97 | 95 | 92 | 90 | 88 | 86 | 84 | 82 | 72 | 36 | ||||||||||||||||||||||||||||||||||||
| 100 | 97 | 95 | 93 | 90 | 88 | 86 | 84 | 74 | 37 | |||||||||||||||||||||||||||||||||||||
| 100 | 97 | 95 | 93 | |||||||||||||||||||||||||||||||||||||||||||