Sane, Safe & Effective Food Policy

Volume 141, No. 19, October 28, 2016

On the counter in front of you are two kinds of carrots, one washed and packed neatly in a clear plastic package, the other still covered in dirt. Which would you choose to buy?

To my surprise, I learned from a microbiologist many years ago that the best method to assure that vegetables are safe in the markets most flavor is to get a shovel to dig them up, put them in a pot, and deliver them as is. Take a carrot from the ground, and clean it, or worse, sanitize it before you display on the shelves, you eliminate a whole community of protective microbes.

So it comes as no surprise to me that a few years ago FAO, the United Nations Food and Agriculture Organization, became preoccupied with dependence of global agriculture on large producers. Wanting to strengthen the food chain through supporting small family farms, they began to look beyond just food security to food safety, as many of the current requirements worldwide place a heavy financial burden on small producers.

What they found was food safety laws that, where they existed, were not in tune with modern science. So in 2000 they joined forces with the World Health Organization and brought world-class experts from around the world to develop a more modern and scientific system to assess germ risk in food. In 2009, they published guidelines (Codex 1999) which are bringing fundamental changes to how governments approach food safety, especially in the United States.

there are concerns that new requirements being considered will be slanted towards large producers and create economic hardship for the small ones.

Last month I wrote about some of those changes. I wanted to share what is driving them. For many decades some scientists and many of us in the food industry have known that there are some things in current food safety law that are suspect.

And there’ve been some spectacular failures. Everyone is concerned, and we have seen the rise of the Global Food Safety Initiative (GFSI).

For many of those, like me, coming out of a three-decade effort to bring product diversity back into the cheese market to help stem the rapid loss of family farms in the US, there are concerns that new requirements being considered will be slanted towards large producers and create economic hardship for the small ones. What’s interesting is that FAO seems to agree with us, based on a number of reports, white papers and guidelines they have produced over the last few years.

The most exciting of all for the revolutionary impact it seems to be having on food safety policy. In the 2009 guidelines are some pretty amazing and encouraging things. The debate on food safety policy is moving in the direction of:
• farm to table solutions
• quantitative risk analysis
• with risks prioritized by comparing the calculations to epidemiological data, in other words, what happens,
• with the focus on prevention through better process, not policing,
• while ensuring that any and all requirements have a basis in science
• and taking into account the impact those procedures may have on small producers,
• finally, recognizing that the control and prevention of risks in the food chain is a responsibility widely shared and requires positive interaction between all of the interested parties

For someone who has dedicated their professional life for the last decade and a half to trying to get value-added producers to stop chasing results and learn how to continually improve their processes to improve their performance in the quality of the product and service they provide, this is like manna from heaven; it’s about time.

But will the entrenched authorities and special interests allow the food world to evolve from police work to collaboration in continual process improvement? It looks like they may!

The new Food Safety Modernization Act was written in part to ensure the United States compliance with these new international agreements. In implementing the Act, the FDA has begun a review of many of its current policies and procedures to see if they are based on science.

In particular, two longstanding policies that are of particular concern for small producers are under scrutiny: as reported in this journal, the use of nonpathogenic bacteria as indicators of the relative sanitary conditions on the farm, and the 60-day rule for raw milk cheeses.

In September, a group of influential senators and House members sent a note to the FDA congratulating them on their decision to suspend the use of counts of nonpathogenic bacteria for artisan cheese makers. In it, they mentioned that this could be an opportunity to develop an approach to the regulation of raw milk cheese production based on science and that they continued to be preoccupied with the lack of evidence that some practices improve the results of public health.

As reported in this journal, the FDA, in September, cut short a two-year research project analyzing samples of raw milk cheeses taken from the shelves in markets around the country because no threat was found.

Also, recent research was done by microbiologists and others to find the scientific basis for the 60-day rule have come up short. In fact, no one seems to be able to nail down the original research. Emperor’s New Clothes syndrome?

In fact, results are all over the place, and the FDA itself is questioning the value of these kinds of arbitrary rules when the solution to safe food lies in safe process. Wow! In my line of work, helping companies optimize their organization through quality, we teach that you are better off solving the problem upstream than trying to fix it downstream. Seems they agree.

To me and others, including many microbiologists, despite what an excellent tool it is, the way we have used and are using pasteurization may have become part of the problem. Reliance on inspecting for a problem after the fact and trying to fix it is a disincentive to improving the process. In my next column, I will share a case study which illustrates this, while of course, changing the names to protect the innocent.

Dan Strongin is a former president of the American Cheese Society, chef and business coach for small to medium value added businesses, and the owner of the sites, and the Facebook group Enjoy Cheese. His online course: “Cheese: How to Buy, Store, Taste, Pair, Talk About and Serve”, is available at Dan can be reached via email at

Dan Strongin encourages your comments regarding this column. Comments can be made anonymously to


Other Strongin Articles written for Cheese Reporter

dot A Ray Of Hope For A More Effective Food Safety Policy

In Her Own Words - Linnea Burnham
dot The American Cheese Society: 32 And Aging Well

dotCh-Ch-Ch-Changes, But Not Always For the Better!
dot Loyal Customers
dot On Customers, Guests & Winners!
dot Another Year, Another Cheddar...the Book
dot Some Things Matter
dot The Future is Social!
dotAll That Glitters: Social Media Marketing Frenzy
dot An Interview With Artisan Cheese Pioneer: Neville McNaughton
dot End of Another Year
dot On Mushrooms, Cheese, Management And Marketing
dot Don’t Waste Your Time With Big Data
dot LaClare Farms
dot Collaborationists in our Industry!
Risk Management vs. Risk Prevention
dot Jack Booted Cheese Thugs
dot Towards a Safer Food Supply
dot Lies, Damned Lies and Dairy Safety: How Poorly Applied Statistics Could Lead to the Worse Public Policy
dot Is Dairy Safe Is The Wrong Question, Part 1
dot Not All Data Is Information
dot Start From Where You Are
dot Learning About Your Customer
dot The Vision Thing
dot Customer Service? NOT!
dot Collaboration: The Road To A Better Future
dot Resolution
dot Water

dot In Memoriam: Ignazio Vella 1928-2011
dot Of Cheese, Seals, And Deming
dot In Their Own Words: Lettie Kilmoyer
dot In Their Own Words: Fritz Maytag
dot In Their Own Words: Paula Lambert
dot Show Me the Money: Cost Accounting
dot Cost Accounting Chokes, Part 2: Inventory

dot Cost Accounting Is Choking Your Business, Part 1
dot It Ain’t Over ‘til It’s Over
dot Raw Reason
dot A Story For The Holiday Season, Part II
dot A Story For The Holiday Season
dot Truth In Labeling
dot This Too Shall Pass or "What were we thinking?"
dot Marketing Language That Resonates
dot When Will We Ever Learn?
dot Cheese Competitions In The Context Of Marketing

dot Economy
dot Even The Best Laid Plans Go Astray
dot Root Causes: Communication
dot Partners
dot Diamond Cutting:
It's What You Don't Know That Can Hurt You
dot Integrity and Ethics
dot 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:

Other Cheese Reporter Guest Columnists
Visit John Umhoefer
Visit Neville McNaughton

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