Dairy Marketing Practice | Contributing Columnist


Artisan Cheese, The FDA, And The New Administration

Dan Strongin ASQ CMQ/OE Uncorporate Consultant

October 21, 2017


A couple of decades ago the debate over raw milk and cheese consisted of those who thought raw milk was a miracle cure for every disease known to man, a group of academics convinced that producers of raw milk cheese were brazen killers, and the rest of us, who like the flavor of raw milk cheese and hoped it wouldn’t hurt us.

Before the internet made misinformation easier to find, there was not much information ava
ilable from the Food and Drug Administration. However, there was some available from the Centers for Disease Control. Unfortunately, they were squarely in the camp that the producers of raw milk cheese were brazen killers.

They were not without historical precedent, as in the 1920s, after 80 years of mass production of dairy products, some very nasty outbreaks happened related to the consumption of dairy products. One out of every four children born in the city of New York, for instance, was dying.

Let’s stop and think about this. Look around your neighborhood at all the people you know that have kids, including your own, and count how many there are. Imagine that for every four kids one of them died during the last year due to drinking milk.

Imagine your city required that all milk be pasteurized and overnight the numbers of children dying dropped dramatically.

In one of the most significant public health achievements to date, infant mortality rates dropped from 240 in a thousand births to only 71 in a thousand in one year, and the only change was the pasteurization of milk. It is easy to understand the force behind a strict adherence to pasteurization.

But science has evolved since 1920. We know that much of the problem was related to poor hygienic processes and barbaric treatment of animals in urban farms. Unlike today’s well maintained dairies and cheese production facilities, in the early days of mass production large numbers of cows were fed the swill left over from whiskey distilleries, and maintained in the most horrific of conditions, all to meet the demands of low price and mass production.

Times have changed a lot since those early less than savory days, but one thing has not changed: the fact that most of these problems were related to mass-produced dairy products and not products made on the farm. How do we know that? Because, between 1840, when the mass production of milk began, and 1903, almost all small family farm producers of cheese went out of business, buried by the lure of easy money from milk processors.

In 1949, when under pressure from Congress and industry to create new milk regulations, the FDA sent people out into the fields to try and find artisan producers of cheese from raw milk and study them to use the findings in developing regulations over cheese production.

The FDA knew that the universe of making small lots of cheese on the farm was a very different universe than industrial production and that cheese had been made exclusively with raw milk since 8000 years BC, without the kinds of outbreaks they had seen since industrialization.

But, alas, they couldn’t find any, so they did
the best they could, requiring that all cheese aged less than 60 days must be made with pasteurized milk.

What happened in the intervening years is that some studies showed that aging for 60 days did not affect some pathogenic bacteria if they are present in the milk or cheese. As more studies were done, and there were very few resources available to support these studies since there are so few commercial interests willing to finance them, it has begun to become clear that time of aging of cheese may have a great deal to do with the quality of the flavor, but is not a reliable control for preventing the growth of pathogens.

To comply with the new recommendations for food safety regulations of the World Health Organization and the WTO, which require a scientific basis for any food safety regulation used in international trade, the FDA sent some of its top advisors in search of the science behind the 60-day rule. They couldn’t find any. I know, hard to believe, but they couldn’t.

The closest they got was that it was some comments made by public health officials in the 1920s about never seeing a person who is sick after consuming cheese aged for 60 days or more. (To their credit, this has inspired an internal dialogue within the FDA about whether to abandon the 60-day rule as a guarantee of food safety.)

Through the hard work of the American Cheese Society and the Raw Milk Cheese Coalition, we have evolved into a more collaborative conversation with the FDA about how best to ensure the safety of the cheeses Americans eat without also compromising the ability of the small producer to survive in a very competitive market.

During the previous administration, the FDA clarified or changed its stance on some gnarly issues like:

The use of wooden shelves and aging cheese,
— Approving it for small artisan cheese makers,

— Changed the rules on the use of nonpathogenic coliform counts as a measure of the relative hygiene in the make room,

— Suspending it indefinitely for artisan cheese makers, ending a study of over 1,500 raw milk artisan cheeses collected from the shelves of stores in the marketplace. No credible risk to public health was found.

This was a sea change in the relationship between small producers of raw milk cheese and the FDA, bringing it more in line with its relationship with producers of fermented foods in other industries like pickles, a longstanding collaborative relationship.

So I was wondering if and how things had changed under the new administration, which has developed quite a reputation for radically altering how other government organizations function. I asked two people who should know, Nora Weiser, the executive director of the American Cheese Society, and Carlos Yescas, program director of the Oldways Cheese Coalition.

Nora Weiser wrote me: “To date, where FDA is concerned, we have not seen a dramatic change based on a new administration. We continue to focus on open communications with FDA, and making sure artisan producers have a voice as stakeholders when regulations impact their businesses.”

Carlos Yescas echoed what she said, adding that, at the level at which he communicates with the FDA, the veterinarians who have responsibility for animal products, they have always been willing to engage. He too sees no change.

I find it encouraging, as there remains a great deal of work to do before the US and other nations have achieved the recommendations of the WHO and WTO:
• Farm to table solutions
• Quantitative microbiological risk analysis (QMRA)
• 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.

See my column on a Sane and Safe Food Policy

The views expressed above do not necessarily reflect those of Cheese Reporter.



Dan Strongin

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 learn.managenaturally.com, and the Facebook group Enjoy Cheese. His online course: “Cheese: How to Buy, Store, Taste, Pair, Talk About and Serve”, is available at enjoycheese.net. Dan can be reached via email at dan@danstrongin.com.

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