Thanks Roux. The article writes persuasively what I was trying to say. There are some key things Professor Neal said, that I think bears emphasizing here:
Good for the FDA for backing down. Although it’s unfortunate that they are dodging accountability by claiming they did not change their policy. The American Cheese Society released a .PDF version of the statement by FDA’s Branch Chief Monica Metz, the chief official responsible for food safety issues involving cheese. In that document she stated
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.
So let’s consider this a clarification, of their earlier clarification, which improperly characterized their official policy. Either way it’s good news.
This is also a lesson for people in other regulated industries. When government officials make pronouncements that don’t seem grounded in law or policy, and threaten your livelihood with an enforcement action, you must organize and fight back. While specialized industries may think that nobody cares, the fight over aged cheese proves that people’s voices can be heard, cheese expert Gordon Edgar summed it up nicely here:
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.
While this is clearly a victory for the cheese industry, nothing is stopping the FDA from promulgating new regulations, so cheese makers will need to stay pay attention to what the FDA does next. FDA spokesperson Lauren Sucher signaled as much when she stated the agency would “engage with the artisanal cheese-making community to determine whether certain types of cheeses can safely be made by aging them on wooden shelving.” That sounds like the FDA is planning to make some new regulations, and the engagement will likely come through the notice and comment rule-making process I described here.
(Emphasis mine). The two key things here for me, anyway, are: (1) Were it not for pressure, the FDA, and Monica Metz's blindsiding of the artisanal cheese industry, wouldn't have budged an inch; and (2) This "victory" is really a call for vigilance.
In my opinion, the FDA believes food safety cannot be secured absent complete sterility in food operations. Guided by Pasteur's Germ Theory of Disease, it sees all microbes as enemies, and can never accept a notion where environmental conditions can actually utilize
microbes to better aid in food safety; where organisms in good health can actually live with "germs," and thrive. So this wood issue, as precipitously as the cleaver fell, is but one action in a long strategic view taken as gospel on the part of the FDA. And that, I would argue, is why we should remain ever vigilant. In my opinion, anything else is naïveté, risking serious consequences.