FDA ruling — what to do?


I was working all day yesterday selling cheese so I didn’t have a chance to write anything about the FDA ruling that has the cheese world on fire right now. That’s probably for the best since Jeanne Carpenter – one of our community’s best assets (and the person who gave me the “Barbara Mandrell of the Cheese Counter” nickname) – posted a great piece on her site detailing what this ruling means to us as a community. I reposted in its entirely below but please go to her site and subscribe to her blog. It is a must-read for cheese folks.

This is a big deal.

I have gotten questions from a few folks who love cheese but don’t know why the use of wood aging boards is such a big issue for us. Fair enough… if one is not a cheese professional or a science geek it is not likely they have had the opportunity to think about the surface that a cheese is aged on rather than its flavor, texture, melting ability, cheesemaker story, animal treatment etc. For most consumers, this part of the cheesemaking equation is well down the list of things they would ever ask about. Yet, some name-controlled cheeses have a specific requirement that cheese, to be called by the protected name, must be aged on wood. Indeed, a cheese like Comte — required to be aged on wood due to their PDO — which by law have some of the most sustainable practices in the world (must be made by local co-ops, limit of cow/hectare etc.) would be hurt while the largest, most automated, least special cheese corporations would benefit.

Most makers of traditional-style cheeses believe wood creates a beneficial environment for cheese. After all, what is cheese but a great achievement of the microbe community? To be sure, not all microbes are beneficial or created equal, but a greater appreciation and understanding of this would benefit us all, both to create better – and safer – foods but also to release us from the fear of food that is part of the American social fabric.

Over the last 30-40 years cheesemakers here in the states have been trying to use the best practices of traditional cheesemakers to give smaller scale production a taste/quality advantage over the larger (now almost completely automated) factories that dominate the market. These folks have sunk their livelihoods on practices and recipes that rely — in part — on wood aging. It could be devastating for some, not just for replacement costs, but also for the lack of the special difference in flavor and quality that allows them to sell their products at a price that — theoretically — allows them to survive as small players in an agribusiness world.

We are all upset and angry at this ruling. However, let’s be careful about what we say to the press (including public social media posts) right now. We need a coherent strategy to fight this. Let’s re-group and come out focused and strong with an idea of how we can win, stressing the safety of cheese made with traditional methods. Talk to ACS folks, your fellow guild members, other cheese workers, and people who buy cheese for sure… but we will need a concrete plan of action to change the policies of a bureaucracy like the FDA. Remember too — though this is a hard thing to remember when one’s life work is being threatened — that from the FDA’s perspective, they are trying to protect lives of US citizens. Any argument to them that does not take into account that point of view is doomed, even in a case like this where we feel the decision is clearly wrong.

Hopefully we can come out of the ACS conference with a plan of action that enlists everyone in this fight.

Please read Jeanne’s piece below:

Game Changer: FDA Rules No Wooden Boards in Cheese Aging

A sense of disbelief and distress is quickly rippling through the U.S. artisan cheese community, as the federal Food and Drug Administration (FDA) this week announced it will not permit American cheesemakers to age cheese on wooden boards.

Recently, the FDA inspected several New York state cheesemakers and cited them for using wooden surfaces to age their cheeses. The New York State Department of Agriculture & Markets’ Division of Milk Control and Dairy Services, which (like most every state in the U.S., including Wisconsin), has allowed this practice, reached out to FDA for clarification on the issue. A response was provided by Monica Metz, Branch Chief of FDA’s Center for Food Safety and Applied Nutrition’s (CFSAN) Dairy and Egg Branch.

In the response, Metz stated that the use of wood for cheese ripening or aging is considered an unsanitary practice by FDA, and a violation of FDA’s current Current Good Manufacturing Practice (cGMP) regulations. Here’s an excerpt:

“Microbial pathogens can be controlled if food facilities engage in good manufacturing practice. Proper cleaning and sanitation of equipment and facilities are absolutely necessary to ensure that pathogens do not find niches to reside and proliferate. Adequate cleaning and sanitation procedures are particularly important in facilities where persistent strains of pathogenic microorganisms like Listeria monocytogenes could be found. The use of wooden shelves, rough or otherwise, for cheese ripening does not conform to cGMP requirements, which require that “all plant equipment and utensils shall be so designed and of such material and workmanship as to be adequately cleanable, and shall be properly maintained.” 21 CFR 110.40(a). Wooden shelves or boards cannot be adequately cleaned and sanitized. The porous structure of wood enables it to absorb and retain bacteria, therefore bacteria generally colonize not only the surface but also the inside layers of wood. The shelves or boards used for aging make direct contact with finished products; hence they could be a potential source of pathogenic microorganisms in the finished products.”

The most interesting part of the FDA’s statement it that it does not consider this to be a new policy, but rather an enforcement of an existing policy. And worse yet, FDA has reiterated that it does not intend to change this policy.

In an email to industry professionals, Rob Ralyea, Senior Extension Associate in the Department of Food Science and the Pilot Plant Manager at Cornell University in New York, says: “According to the FDA this is merely proper enforcement of the policy that was already in place. While the FDA has had jurisdiction in all food plants, it deferred cheese inspections almost exclusively to the states. This has all obviously changed under FSMA.”

Ah, FSMA. For those of you not in the know, the Food Safety Modernization Act is the most sweeping reform of American food safety laws in generations. It was signed into law by President Obama on January 4, 2011 and aims to ensure the U.S. food supply is safe by shifting the focus from responding to contamination to preventing it.

While most cheesemakers have, perhaps, begrudgingly accepted most of what has been coming down the FSMA pike, including the requirement of HACCP plans and increased federal regulations and inspections, no one expected this giant regulation behemoth to virtually put a stop to innovation in the American artisanal cheese movement.

Many of the most awarded and well-respected American artisan cheeses are currently aged on wooden boards. American Cheese Society triple Best in Show winner Pleasant Ridge Reserve from Uplands Cheese in Wisconsin is cured on wooden boards. Likewise for award-winners Cabot Clothbound in Vermont, current U.S. Champion cheese Marieke Feonegreek, and 2013 Best in Show Runner-Up Bleu Mont Bandaged Cheddar.

Wisconsin cheesemaker Chris Roelli says the FDA’s “clarified” stance on using wooden boards is a “potentially devastating development” for American cheesemakers. He and his family have spent the past eight years re-building Roelli Cheese into a next-generation American artisanal cheese factory. Just last year, he built what most would consider to be a state-of-the-art aging facility into the hillside behind his cheese plant. And Roelli, like hundreds of American artisanal cheesemaekrs, has developed his cheese recipes specifically to be aged on wooden boards.

“The very pillar that we built our niche business on is the ability to age our cheese on wood planks, an art that has been practiced in Europe for thousands of years,” Roelli says. Not allowing American cheesemakers to use this practice puts them “at a global disadvantage because the flavor produced by aging on wood can not be duplicated. This is a major game changer for the dairy industry in Wisconsin, and many other states.”

As if this weren’t all bad enough, the FDA has also “clarified” – I’m really beginning to dislike that word – that in accordance with FSMA, a cheesemaker importing cheese to the United States is subject to the same rules and inspection procedures as American cheesemakers.

Therefore, Cornell University’s Ralyea says, “It stands to reason that if an importer is using wood boards, the FDA would keep these cheeses from reaching our borders until the cheese maker is in compliance. The European Union authorizes and allows the use of wood boards. Further, the great majority of cheeses imported to this country are in fact aged on wooden boards and some are required to be aged on wood by their standard of identity (Comte, Beaufort and Reblochon, to name a few). Therefore, it will be interesting to see how these specific cheeses will be dealt with when it comes to importation into the United States.”

Ralyea continues: “While most everyone agrees that Listeria is a major concern to the dairy industry, it appears that some food safety agencies interpret the science to show that wood boards can be maintained in a sanitary fashion to allow for their use for cheese aging, while others (e.g., the US FDA) believe that a general ban of any wooden materials in food processing facilities is the better approach to assure food safety. At this point, it seems highly unlikely that any new research data or interpretations will change the FDA policies in place.”

In fact, many research papers do in fact conclude that wooden boards are safe. In 2013, the Wisconsin Center for Dairy Research published a paper on the subject, concluding: “Considering the beneficial effects of wood boards on cheese ripening and rind formation, the use of wood boards does not seem to present any danger of contamination by pathogenic bacteria as long as a thorough cleaning procedure is followed.” You can read the whole report on pages 8-9 by clicking on this link.

Interesting side note: Health Canada does not currently have any regulations prohibiting aging and ripening cheese on wood, so apparently if we want to eat most American or European artisan cheeses, we’ll need to drive across the border to do so.

So what’s next? The American Cheese Society has mobilized its Regulatory & Academic Committee to learn more about this issue, and to ensure its members’ interests are represented. The ACS promises to keep us apprised of developments. In the meantime, if you are a cheesemaker, and your operation is inspected and cited for the use of wooden surfaces, please contact the ACS office (720-328-2788 or info@cheesesociety.org).

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9 responses to “FDA ruling — what to do?

  1. Argh. Please do keep us cheese devourers informed on how we can help support y’all.

  2. Excellent distillation of a huge challenge.

  3. Well said Gordon … with a rational voice which is what we need here now .. these folks write the rules … it should be very interesting to watch them put out fires when the American public realizes that they can no longer get their Parma-Comte-Roquefort-etc and many of their favorite US Award winners

  4. Well said. I think arguing with science, channeled lobbying, and a stress on food safety is what can influence the argument. Though it is hard not to have a knee-jerk frustration with this type of blanket, Band-Aid policy that is not a solution.

  5. You have to wonder what did they see/find/test in New York that was a trigger to this action. In such a highly regulated industry there is no bar to entry. Anyone can buy a vat and make cheese.

    There is sound logic behind wood/wooden instruments but there can unfortunately be downsides too if not properly used, treated and maintained. Not to mention stylistically there were hard cheeses aged directly on wood and softer cheeses on matting that helped regulate moisture on the surfaces. I’ve seen several new cheese makers age soft cheese directly on wood which can be an issue as oxygen does not reach the bottom of the cheese for yeast and mold to grow allowing contaminants to take hold.

    I believe as an industry we can overcome this with good tactics described in your post. Bravo.

  6. Pingback: FDA May Destroy American Artisan Cheese Industry | infoscape.com

  7. Pingback: FDA May Destroy American Artisan Cheese Industry | daily1.com

  8. Gordon, Thank you for your insight and advice for us all to just wait to see how to respond to this. I think as cheese makers, we have a responsibility to not get emotional and sling accusational slander. We wait for our milk to ripen, our curds to form, and our cheese to age. We can certainly wait for the cheese mite dust to settle here and be proactively cooperative with the process instead of throwing our politically slanted opinions in a vacuum package bag and expect the end product to come out tasting fresh and edible.

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