Raw Reason

Volume 134, No. 46  - Friday, May 14, 2010

Below is a copy of an email I sent to the FDA in February:

“From: Daniel Strongin <dan@danstrongin.com>
Date: February 8, 2010 10:30:11 PM GMT-02:00
To: commissioner@fda.hhs.gov

Dear Ms. Hamburg,
I am a consultant specializing in working with small family farmers and small to medium sized producers of value added foods, a former president of the American Cheese Society.

The head of CFSAN was quoted on the front page of the Cheese Reporter saying the 60 day rule for aging cheeses was inadequate, and needs to be changed. I am deeply concerned about this.

Small family farms are important to a free nation, and a safe, secure food supply. (They are not multi-national corporations and cannot afford to have lobbyists or research institutions, so we sometimes forget their importance.) They provide real diversity in our agricultural economy.

Those that focus on dairy have been able to save their farms, and to a degree their rural communities, by producing artisan cheese as part of the renaissance of artisan cheese over the last 20 years. For the first time in a generation, the loss of family farms has slowed, a bit: people are actually returning to farms to produce artisan cheese.

What makes this possible for small producers is the ability to make aged raw milk cheese, because it is more flavorful, more sought after in upscale markets, and restaurants, and safer in smaller scale production, due the freshness of the milk supply.

I am familiar with the arguments against raw milk cheese. The concern is based on a limited set of laboratory data; while it is true, there is a statistical chance, based on laboratory evidence, that aged cheese could carry rare pathogens beyond 60 days, has it, and how often has it? Shouldn’t the real test of an approach that could so adversely affect the small family farmer be the probability in the real world, not in the lab?

Solutions like zero tolerance sound impressive, but are impossible to achieve, and overly simplistic. The right solution, the one that takes into account the complexity of variation in nature, is process control.

Cheeses made with raw milk, are among the safest foods known to man, if made with good process: Lactic fermentation of all kinds, in fact. Reggiano Parmesan for instance, is sold and eaten worldwide and yet, how many cases of foodborne illness have been traced to it? or aged raw milk Cheddar? or a properly fermented pickle or natural olive?

What matters is what is the best and most effective course of action. All sides should be represented, not just those that can afford it: large dairy producers and a handful of professors, who represent a narrow span of the expertise on the safety of aged cheese. For a fair, just and effective solution, I highly recommend checking with Dr.
Catherine Donnelley at the University of Vermont, who has comprehensive data on the subject. I would be glad to recommend others as well. It is important to note that industrial processed food that has caused far more problems than traditional ones, by any measure.

I want to thank you in advance for taking to heart my recommendations, and proving that we are still a country who listens to those who do not have the power or money to manufacture a voice.

Respectfully,
Dan Strongin

To make sure I was on target, I went and did some fact checking. Side stepping the controversy between the zero tolerance wingnuts and the raw milk cures everything wingnuts, I wanted to see if I could come to some reason.
After all, there are not many family farms left in the US.

Make no mistake, the best, the most profitable, and the best selling artisan cheeses are made from raw milk.

So let’s look at the facts, as taken from the CDC Outbreak Tables for Foodborne Illness in Dairy Products from 2000 to 2009: aged raw milk cheese was involved in no incidents of foodborne illness between 2000 and 2009.
Not one. Spinach was more dangerous. Deli meats? Deli meats killed.

Figure 1 below is their own data:

While there is no question that a number of rather unfriendly microbes can grow in milk, and could potentially continue to live in cheese: the operative words are can
and could.

Laboratories make their living by finding what could go wrong, whereas insurance companies make money by knowing what does, not what could. They use actuarial statistics to separate what could happen from what really does.

Or as an old friend of mine put it, when watching one of the founders of DNA make a fool of himself claiming the unconscious mind doesn’t exist because you couldn’t prove the existence of it in a laboratory, “I’ll get some cow paddies and rub them in his face and ask him how he can describe that experience in a laboratory!”

And yet, the FDA is ready to radically alter a process which could have devastating affects on a rapidly diminishing resource, the family farm. Beyond the issue of real vs. possible, the solutions listed were quick fixes, not long term solutions; they treat the symptoms but not the disease.

Pasteurization and irradiation are last ditch attempts to solve processing issues that can only really be solved at the root, on the farm or in the milking parlor where the processing takes place. They come too late in the process, and can mask serious issues.

The goal should be to stop the unwanted from getting into the milk in the first place.

For instance, if feed crops are cut too close to the ground, they can get some manure in them, and with them bacteria. Once in the parlor, if the fittings are not AAA standard, biofilms can form. Some of these can survive pasteurization. If you want to discuss potential dangers, what if one of those turned harmful through mutation. Impossible? Look at the beef industry, look at 0157.

I know of dairy farms from personal experience with sub-standard conditions. At one, the valve on the bulk tank had not been cleaned in over five years and the cooling plate was surrounded by a thick yogurt-like substance. Their response was, since we pasteurize, we didn't think it made a difference.

In the last few years, there has been a bloom of bacteria in our northern states and Canada that survive pasteurization and cause gassing during aging. Doesn’t make people sick, but cost cheese companies a great deal.

A root cause is one that can be changed, and changing it affects a lot of other things and when you change it, the problem goes away. So before a decision is made that could devastate family farming, we should take a deep breath. A cost/benefit analysis is in order. What has actually happened should be more important than what could happen.

Many things that we use daily would have to be eradicated before aged raw milk cheese hit the top of the list if we stick to the could happen standard.

And question begs, if the only real way to ensure a safe food supply is through process, the Quality Discipline would recommend the following: eliminate unwanted bacteria in the milk at the source through process control, before it gets into the cheese.
1. Make certain all dairy processors upgrade to AAA standard and are kept to that standard.
2. Require all producers of aged raw milk cheese to buy only from herds maintained using HACCP, and the Quality Disciplines of continuous improvement and statistical process control.
3. Fund the development of rapid testing so inspection can become part of the process, not after.
4. Focus raw milk cheese production on small to medium facilities only, to avoid the complexity of purchasing from large pools of milk.
I would hate that the ultimate legacy of pasteurization would be the creation of a super-germ. Because it is an after-the-fact fix, and does not address the root cause, leaving the door open to nature’s less savory mutations.

As to pasteurization, for large cheese producers using the milk of many farms it makes sense, or for those who choose to use it; for fresh cheeses and liquid milk it is the law. r

Dan Strongin is managing partner and owner of Edible Solutions, a consulting company focused on helping companies making great food make a profit. He will be writing a monthly column in Cheese Reporter. Strongin can be reached via phone at (510) 224-0493, or via e-mail at dan@danstrongin.com. You can visit and blog with Dan at www.managenaturally.com.

Other Strongin Articles written for Cheese Reporter

A Story For The Holiday Season, Part II A Story For The Holiday Season Truth In Labeling This Too Shall Pass or "What were we thinking?" Marketing Language That Resonates When Will We Ever Learn? Cheese Competitions In The Context Of Marketing Economy Even The Best Laid Plans Go Astray Root Causes: Communication Partners Diamond Cutting: It's What You Don't Know That Can Hurt You Integrity and Ethics Pricing:  The Perceived Value Designing the Effective Sell Sheet Common Sense It All Begins in The Mouth Of Cars... The Gathering Storm As Our Industry Evolves, So Should Our Terminology:

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