Safe And Sane Food Policy:
Fix The Causes To Fix The Results

Volume 141, No. 26, December 16, 2016

In my last column I shared how changes in food policy at the FDA are laying the foundation for a safer food supply. Science, prevention, managing risks, and improving processes, is the right path. We have been snookered by specifications, arbitrary targets, and homespun solutions for too long. We pay too much attention to the noise, and not enough to what is really going on. We need to stop chasing phantoms, and focus on what is, as I advise in my book, “REAL.”

The “method” I have used to do this, Continual Improvement, adapted for farm work using little more than a pencil and paper, teamwork and some horse sense, solves sticky problems our current food safety system finds difficult to address.

I was consulting with a cheese factory whose raw milk cheeses began to explode. The milk came from a single farm who had sought the help of the authorities, but were refused. The farm was meeting all of its required standards and had passed their inspections so until someone got sick, there was no obvious threat to public health. (A bit like waiting until the heart attack to cut back on using salt.)

Working with a cheese technologist and a professor in the hope of finding the cause, I applied tools of Quality Improvement, in which I am trained. Other cheese plants, who worked with pasteurized milk, were having the same problem.

The professor formed a hypothesis, after testing did not reveal the usual suspects: the germ causing the cheese to explode was a mutation, either a coliform or a fecal strep and had developed the ability to survive pasteurization. Since the problem was widespread, it had nothing to do with using raw milk. The question was, at what stage of their process was the mutation contaminating the milk? “Fix the Cause, Change the Result.”

Natural processes normally are stable and predictable. If you take their results in sequence time and plot them on a simple line graph, what you will see is a wavelike form softly undulating around a line that represents the average, like waves lapping the shore on a calm day.
In the diagram above, the red line represents the results, the blue line represents the average and the arrowhead shows that the results are plotted in sequence in time.

The first step in Continual Improvement is to figure out if the process is behaving normally. If not, then something untoward is messing around with it. Because it is untoward it will be easy to see in a chart; it can and must be found and eliminated or the process will continue to be unpredictable, and probably get worse..

I used the available data, the counts of non-pathogenic coliform bacteria that the FDA uses as a measure of the relative hygiene, perhaps better said, “misuse.” (as pointed out in my last column, which appeared on Oct. 28, recent research has shown it to be ineffective). It would tell me if the output of the production process was normal, or under the influence of something untoward.
(From the point of view of process improvement it doesn’t really matter what the outputs are so much as whether they are predictable over time.) I plotted the counts on a line graph (see page 14) in sequence in time and had a look. What I found was anything but normal.

As you can see on the graph on page 14, there were a couple small peaks and one that is off the charts, almost literally. I was dealing with a process that was unpredictable. My next step was to identify the source of the problem as fast as I could.

The 30 minutes I spent plotting the results in sequence in time with a pencil and paper paid double. I was able to isolate the days in which the high bacteria counts showed up (Day 2, 10, 11 and 17).

If it was a mutated gut bacteria, it first had to get into the milk. We made a checklist of every way we could think of that a bit could get in the milk. Most of them involved feces. We went to the milking parlor and observed, on the days when the people who had been working when the problem last occurred.

Sure enough, we saw two workers using more water pressure in the hose than they needed to clean the legs and rear end of the cows and prepare them for milking. Our theory evolved. This could expel small bits of feces into the air which could then fall on the teats, to be pulled into the milking machine.

We talked to the workers, delicately, so as not to instill fear. They agreed to use lower pressure. This helped. But, intermittent peaks in the counts of bacteria continued. We had made an improvement, but had not rooted out the cause. We dug deeper.

It seemed that the problem could be occurring after the milking parlor, in the pipes, valves and holding tanks. So the dairy tech took the tops off to visually inspect.

What we found was a meter or more (39 inches) of a yogurt like substance in the pipe behind the valve on the storage tank.

When asked the last time it had been cleaned, an employee responded, “It must’ve been five years ago.” Seeing the shocked look on our faces, he continued “we never thought to pay attention because, until recently, we pasteurized all our milk.”

When we asked the state inspector why they never inspected inside the machinery, he responded that the indicator bacteria counts were okay, the milk was being pasteurized, and nothing stood out to him during his inspections. “There is no room in the budget for inspecting inside equipment. Too many farms and too few inspectors. We have to wait for an obvious threat to public health, and there are legal considerations.”

Our hypothesis evolved: small amounts of feces entering the milk had contaminated the inside of the equipment allowing biofilms to form. From time to time these biofilms would dislodge, enter the flow of milk, collecting behind the valve, making the yogurt like clods. Intermittently, varying amounts of it would enter the flow of milk, creating the peaks in bacterial counts.

As biofilms cannot be seen, the only way to test was to close down the milking parlor for a day and thoroughly sanitize. Afterwards, the bacterial counts returned to normal. The problem had gone away. But was this the root cause?

The dairy technologist, the professor and I felt that without knowing the source of contamination, the problem would return. How did this mutant bacteria get into the digestive system of the cow in the first place? The obvious answer is the food. We made checklists, put on our rubber boots and observed.

We discovered they were cutting the silage crops too close to the ground to maximize yield. This was picking up bits of manure. That manure was probably fermenting in the silage. It was not possible to test because it would require an atomic microscope. Neither the farmer nor the factory could afford to, and the state had no interest.

The professor made a frightening point. Fermenting silage is an ideal medium for coliforms to mutate. It was lucky the mutation was not pathogenic.

The current food safety system, with its magic pill mentality of “we weren’t worried because the milk would be pasteurized,” allows bacteria to multiply between the stage of contamination and when milk is pasteurized, leaving the door open for mutations to evolve that survive pasteurization, and could be pathogenic. With delays between contamination and correction, we leave the door open for the creation of super germs. E. coli 0.157 and Mad Cow. Though from different processes, both came from a misguided attempt to control rather than work with nature.

Our aim should be to make better milk. We need to stop depending on magic pills. We need more empirical data about what is happening on the farm, in context. (Data collected for a large farm will not share the same context as that collected for a small farm). We need training on the farm in how to use that data, not only to eliminate problems, but for the third step of Continual Process Improvement, improving the process to improve outputs.

The best method to find and eliminate the causes of unwanted effects is continual improvement (CQI), created by Dr. Walter Shewhart eight decades ago. There is a small group of trained people with experience in the food and dairy industries. I’m one of them. We are waiting for a call.

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


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