Wow. Talk about a groundswell. This is the kind of issue that scares the cheese world because, while crucial to us, the surface a cheese is aged on might be seen as too esoteric or boring to draw public attention. Clearly this has not been the case here.
I feel like it may be important here to rehash the chronology since, suddenly, my blog is being read outside the insular world of the cheese-obsessed. First, who uses wood to age cheese? The answer is more cheesemakers than you probably think.
According the the American Cheese Society, almost 75% of cheese producers in the three largest American producer states age at least some of their cheese on wood. Wisconsin alone ages almost 30 million pounds of cheese on wood. Over 60% of cheese makers surveyed use wood boards for aging. In Europe, 1 billion lbs. of cheese a year are aged on wood boards including some of the most popular in the US like Parmigiano Reggiano and Comte.*
So, why did this become an issue? Recently the FDA cited three New York cheesemakers for using wooden boards to age cheese. Since the advent of the FSMA,** the FDA has been more active in regulatory activities relating to food production. The NY State Department of Agriculture asked the FDA for clarification since they approve of the use of wood under the right circumstances– like all other states I know of that produce large amounts of cheese. (see Gianaclis Caldwell’s great piece on this here)
An official at the FDA replied that since “Wooden shelves or boards cannot be adequately cleaned and sanitized” their use for cheese ripening or aging is considered an unsanitary practice by FDA, and a violation of FDA’s current Current Good Manufacturing Practice regulations. Furthermore they consider this an existing policy, not a new one that would need public comment and review. (See this article by Greg McNeal for an opinion on whether this should be considered a change of policy)
Let us pause for a second and ask, how many food borne pathogen issues have there been where the culprit was wooden aging boards? The answer: none. Indeed, food safety-wise, especially when one excludes cheese that would never be aged on wood, cheese has a very good track record for food safety.
The opposition to the prohibition of wooden boards does not mean that cheesemakers are against Good Manufacturing Practices or regulation. Indeed, as evidence of the seriousness with which it is taken, I am including the entire ACS press release below. ***
Due to the hard work of affected cheesemakers and the American Cheese Society, the FDA released a new statement today:
“ The FDA does not have a new policy banning the use of wooden shelves in cheese-making, nor is there any FSMA requirement in effect that addresses this issue. Moreover, the FDA has not taken any enforcement action based solely on the use of wooden shelves. In the interest of public health, the FDA’s current regulations state that utensils and other surfaces that contact food must be “adequately cleanable” and properly maintained. Historically, the FDA has expressed concern about whether wood meets this requirement and has noted these concerns in inspectional findings. FDA is always open to evidence that shows that wood can be safely used for specific purposes, such as aging cheese.
The FDA will engage with the artisanal cheese-making community to determine whether certain types of cheeses can safely be made by aging them on wooden shelving.”
*according to “Wooden Tools: Biodiversity Reservoirs in Cheesemaking” (a chapter in Microbes and Cheese edited by Catherine Donnelly of the University of Vermont) 500,000 tons = 1 billion lbs, right?
** Here is a good background piece on the FSMA, which, btw, came out of Bush administration anti-terrorism policies.
***AMERICAN CHEESE SOCIETY
POSITION STATEMENT ON THE SAFETY OF AGING CHEESE ON WOOD Issued in Response to the Recent Food & Drug Administration (FDA) Statement on the Use of Wooden Shelves for Cheese Aging
Released June 10, 2014
For centuries, cheesemakers have been creating delicious, nutritious, unique cheeses aged on wood. Today’s cheesemakers—large and small, domestic and international—continue to use this material for production due to its inherent safety, unique contribution to the aging and flavor-development process, and track record of safety as part of overall plant hygiene and good manufacturing practices. No foodborne illness outbreak has been found to be caused by the use of wood as an aging surface.
The American Cheese Society (ACS) strongly encourages FDA to revise its interpretation of the Code of Federal Regulation (21 CFR 110.40(a)) to continue to permit properly maintained, cleaned, and sanitized wood as an aging surface in cheesemaking as has been, and is currently, enforced by state and federal regulators and inspectors.
It is ACS’s position that:
• Safety is paramount in cheesemaking.
• Cheeses aged on wood have a long track record of safety, and have long been produced meeting FDA standards.
• Wood can be safely used for cheese aging when construction is sound and in good condition, and all surfaces are properly cleaned and maintained using sanitation steps that assure the destruction of pathogens, including but not limited to:
o All surfaces are free of defects; o Any wood preservatives used are safe and acceptable for direct food contact; o Inspection and cleaning procedures are followed that specify:
•Frequency of inspection and testing
•Frequency of cleaning and sanitizing
•Methods used that adequately clean boards which might include:
• Sanitizing with acceptable products
• Inoculation to create and maintain positive biofilm
• Raising the core temperature of the wood above pasteurization temperatures
• Ongoing monitoring and verification of the effectiveness of all procedures per the Hazard Analysis and Risk-based Preventive Controls (HARPC) provision of the Food Safety Modernization Act (FSMA)
• Corrective actions to address any issues
• Discarding of wood that is deteriorated and/or in poor repair Furthermore, ACS believes:
• Traditional methods of cheesemaking can and do meet food safety standards.
• U.S. consumers should have access to a wide variety of domestic and imported cheeses, including those safely aged on wood.
• State and federal regulators and inspectors must work collaboratively with cheesemakers to understand how traditional methods and materials can comply with current food safety standards.
• Many of the finest and most renowned cheeses from around the world are at risk of disappearing from the U.S. market if regulatory and enforcement changes under FSMA eliminate traditional materials and methods.
• FDA should provide timely notification, hold proper listening sessions and comment periods, review all available scientific data, and include consideration of industry stakeholders before modifying long- standing interpretation or implementation of its regulations which impact American businesses. ####