Author Topic: Use of wood - say goodbye./  (Read 1473 times)

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,333
  • Cheeses: 41
  • Default personal text
Use of wood - say goodbye./
« on: June 06, 2014, 06:33:56 PM »
I'm so angry.  In a continuing testament to the idiocy and crappy science that guides so much of the FDA, this was just sent to me moments ago.

Quote
""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."
- Paul


Guests, join the CheeseForum.org community to remove this ad.


Offline Spoons

  • Sailing The Seas of Cheese
  • Old Cheese
  • *****
  • Location: Ottawa, ON, Canada
  • Posts: 634
  • Cheeses: 47
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #1 on: June 06, 2014, 06:49:44 PM »
It's more and more like this in Europe too. There are a few episodes of 'Cheese Slices' TV show that mention this going on in Italy, of all places.
- Eric

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,333
  • Cheeses: 41
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #2 on: June 06, 2014, 06:52:07 PM »
Wow, Spoons, I didn't realize this.  The morons are opining on what they don't know.  It's damn frustrating.
- Paul

Offline Spoons

  • Sailing The Seas of Cheese
  • Old Cheese
  • *****
  • Location: Ottawa, ON, Canada
  • Posts: 634
  • Cheeses: 47
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #3 on: June 06, 2014, 07:03:22 PM »
Only because a few cheese producers got sloppy all cheese producers must pay. Some traditions will die out. Wood moulds and manchego type woven baskets are next IMO.
- Eric

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,333
  • Cheeses: 41
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #4 on: June 06, 2014, 09:30:01 PM »
That's what's so exasperating.  Pasteurized milk.  Big safeguard. 

I can't use a wooden hoop, I'm almost certain.  I wish I could - I have one plastic Abondance form, and no more are being produced.
- Paul


Guests, join the CheeseForum.org community to remove this ad.


Offline Alpkäserei

  • Old Cheese
  • *****
  • Location: Indiana/Kanton Bern
  • Posts: 600
  • Cheeses: 62
  • Default personal text
    • https://www.facebook.com/Kaesereigrimwald
Re: Use of wood - say goodbye./
« Reply #5 on: June 06, 2014, 09:43:01 PM »
Paul, you should be able to get the hoop passed if you have the cheese bound in cloth in the hoop, which it should be anyway

I've known for some time I can't use wood as a direct contact surface. You can seal it and use it though, because they consider sealed wood to have a plastic contact surface

I'm going to use high density plastic shelves, which I think may end up actually being quite a bit cheaper

the EU has dissallowed wooden shelving for some time, except perhaps for a few specific exceptions for traditional cheeses. Swiss cheese shops that export to the EU always have to remodel their aging rooms with plastic shelves and tile up their make rooms to comply with EU standards. Food standards are extremely loose in Switzerland though (I mean, I can make cheese in a copper vat hung over and open fir with manure caked all over my clothes and dirt on the floor, from milk that has sat out in the open air in shallow pans over night, and have my lunch cooking a few feet away from me while I'm at it)

I am sure the number 1 reason why you don't see many of the best Swiss cheeses in the US, like Berner Alpkäse, is that the facilities could never meet US import standards. Also the fact that 75% is eaten within like 5 miles of where it's made...
Guät git's dr schwiizer Chäser

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,333
  • Cheeses: 41
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #6 on: June 06, 2014, 10:24:11 PM »
Alp, you have a much more reasoned and balanced approach to this news.  I'm afraid I'm spitting angry.  This movement to sterilization is a true March of Folly.  And I sit gape-faced it can't be seen. 

I actually will have a problem with the cheesecloth.  "The cheese is draining whey, which makes contact with the cheesecloth, which makes contact with the wood.  Therefore, it is unsafe." 

That's the reasoning.  A friend points out, it does make sense, given their internal logic.  And he's absolutely right.  But their internal logic has the intelligence of the very microbes they shrink in fear from, everywhere. 

This is just the start of what the FDA has been developing for awhile, a new wave in ill-informed aggressiveness.  Mark my words - raw milk, and cheeses made from it - will be outlawed, expressly.
« Last Edit: June 06, 2014, 10:36:44 PM by ArnaudForestier »
- Paul

Offline JeffHamm

  • Old Cheese
  • *****
  • Location: Auckland, New Zealand
  • Posts: 2,657
  • Cheeses: 159
  • As goes the cheesemaker, so goes the cheese
Re: Use of wood - say goodbye./
« Reply #7 on: June 07, 2014, 02:01:38 AM »
Here's a copy of a post I made on another thread. 

I know there is work that shows that wood has natural antibacterial properties.  At the Auckland Science Fair last year, one of the entries (that won a 1st place, and a special prize) was called "Killer Woods", and she compared contamination found on cutting boards, 3 made from different types of wood, and 1 made of plastic.  The wood boards were all below measurable amounts of pathogens (so she couldn't rank which wood was 1st, 2nd, and 3rd most effective), but the "anti-bacterial plastic" one was measurable, and therefore the worst.  She did the testing in the School of Biology at the University (a lab there assisted her), and there was some background literature to go with it. 

- Jeff

Just did a quick search and found this page: http://faculty.vetmed.ucdavis.edu/faculty/docliver/Research/cuttingboard.htm

And here's a link to a published paper by Cliver (who has passed away now, but who contributes to our conversations today): http://www.treenshop.com/Treenshop/ArticlesPages/SafetyOfCuttingBoards_Article/CliverArticle.pdf
The wise do not always start out on the right path, but they do know when to change course.

Offline Alpkäserei

  • Old Cheese
  • *****
  • Location: Indiana/Kanton Bern
  • Posts: 600
  • Cheeses: 62
  • Default personal text
    • https://www.facebook.com/Kaesereigrimwald
Re: Use of wood - say goodbye./
« Reply #8 on: June 07, 2014, 12:51:17 PM »
My guy over at the IN BOAH told me, they didn't have a problem with wood contact surfaces as long as there was SOMETHING between the cheese and the wood, things he mentioned included: wood sealer (for shelves, countertops, etc.), butcher paper (for aging shelves), cheesecloth (for forms, counter tops, etc.), mats, and so on.

I specifically asked, because I assumed they would have a problem with bare wood shelves for aging.
I have found, though, that in our climate it can be difficult to control the rind growth on bare wood, because it does absorb and foster fungal growth here far more so than in the Alps.

Now actual experience has made me not so sad about not being able to use wood as a direct contact surface. Now I can use inferior materials for my shelves and put paper on it. I can actually simplify my washing regiment by having disposable contact surfaces. So if you look, you can usually find the benefits of these things.

As for the move to ban raw milk cheese. Here's the kicker there, the FDA actually can't do that, it's outside of their jurisdiction. They might say that, but it is impossible to enforce, at least within state boundaries. So I can make cheese according to Indiana standards and sell it within Indiana no matter what the FDA says, so I really don't care what silly rules they pass. Indiana will not go along with such a law, it is not going to happen at this point. It's this very fact that many states have used to legalize raw milk sales -the FDA has absolutely 0 authority within any given state, they can only claim authority on interstate trade, and even then it's pretty questionable.
So I talk to my state guys, I work with them. I don't give an ounce of concern to the FDA because they simply don't matter.
Guät git's dr schwiizer Chäser

Offline Sailor Con Queso

  • Old Cheese
  • *****
  • Location: Kentucky
  • Posts: 2,534
  • Cheeses: 126
    • Boone Creek Creamery
Re: Use of wood - say goodbye./
« Reply #9 on: June 07, 2014, 04:33:47 PM »
This has been building and getting uglier for several years.

2 days ago from The American Cheese Society - A Warning To Members

The FDA recently 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 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.
 
CFSAN's response indicates 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.
 
"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."   
 
FDA does not consider this to be a new policy, but rather an enforcement of an existing policy. FDA has reiterated that it does not intend to change this policy.
 
Cheesemakers importing cheese to the United States are subject to the same rules and inspection procedures as American producers. FDA has stated that it will be consistent in its application of the policy to both domestic and foreign producers.
A moldy Stilton is a thing of beauty. Yes, you eat the rind. - Ed
www.boonecreekcreamery.com


Guests, join the CheeseForum.org community to remove this ad.


Offline JeffHamm

  • Old Cheese
  • *****
  • Location: Auckland, New Zealand
  • Posts: 2,657
  • Cheeses: 159
  • As goes the cheesemaker, so goes the cheese
Re: Use of wood - say goodbye./
« Reply #10 on: June 07, 2014, 05:33:42 PM »
The Clive paper I linked to above actually tests Listeria monocytogenes and basically found wood was better than the plastics.  Again, we're talking cutting boards here, so the food source is not sitting on the surface the whole time.  They would be looking at how long things last once the product is removed from the surface (and they seem to be showing that by 3 minutes after removal the wood surface showed reduced contamination compared to the plastic surfaces).  This is well outside my area of expertise, so I can't evaluate the methodology, and I've not spent a lot of time on reading the article (skimmed to find the results section, etc), but at first blush it seems pretty clear that this evidence (i.e. this one paper) would suggest wood is superior at least to plastic.  I would think the cheese industry, if they were concerned that this regulation is negatively influencing product quality and putting consumers at greater risk, could request independent reseach from Universities into best practice.  The funding, if any, would have to be given in a way that keeps the University free from influence of either the FDA or the cheesemaking industry (i.e. we'll financially support a PhD or two on this topic, but other than indicating the area of interest, the research and IP that results remains with the University and the PhD, so publish no matter what you find). 

Also, the differences we're talking about with cutting boards, at least, are not just differences in the lab but the effects are big enough to suggest differences in actual health risks (which the FDA is concerned with).  Note the first link I included above ends by mentioning a consumer risk study where they found people with wooden cutting boards were at 1/2 the risk of salmonella poisoning compared to those using plastic ones.  Meaning, the plastic boards are potentially a greater health risk than the wooden ones.  It's possible the same could be true for cheese aging shelves, or there might be no difference, or the wooden ones might be worse, without proper study, it's all just guess work.  Guess work is a pretty expensive way to make decisions.

If the study found the wooden shelves provided protection, the Cheese Industry could then push for clarification on why the FDA is pressuring them to put consumer's at risk.  This is harder to argue if there is no difference (a possible outcome), and obviously, if the study were to show that wooden shelves were a risk, then the FDA is right to prevent an industry from putting people at unnecessary and measurable risk. 
The wise do not always start out on the right path, but they do know when to change course.

Offline Al Lewis

  • Old Cheese
  • *****
  • Location: Port Orchard Washington
  • Posts: 1,126
  • Cheeses: 38
Re: Use of wood - say goodbye./
« Reply #11 on: June 07, 2014, 06:40:43 PM »
Seems I watched a video on parm production in Italy a couple of years ago and they had about 24,000 parm wheels on wooden shelves.  Been doing it that way since they started back in the day.  They don't seem to have a problem.  Just saying.  :o

https://www.youtube.com/watch?v=9BZEy6dSY6Q
« Last Edit: June 07, 2014, 06:47:15 PM by Al Lewis »

Offline Alpkäserei

  • Old Cheese
  • *****
  • Location: Indiana/Kanton Bern
  • Posts: 600
  • Cheeses: 62
  • Default personal text
    • https://www.facebook.com/Kaesereigrimwald
Re: Use of wood - say goodbye./
« Reply #12 on: June 07, 2014, 06:48:51 PM »
Be sure to work with your guys on the state level, if you deal within state boundaries then the state organization with jurisdiction over you WILL go to bat for you, if you establish good relations with them.

FDA ONLY has jurisdiction in a few select cases, and where the trade occurs across state lines. If I am certified in compliance with Indiana State law, as a business operating within the State of Indiana I have the right to forcibly evict FDA inspectors who demand compliance with laws that do not agree with the State of Indiana, or government agents who seeks to confiscate my property or shut down my facilities when I have not infringed on Indiana State law, and I am not participating in business that falls outside of Indiana's jurisdiction (i.e. my company sells directly to entities out-of-state)
By Indiana state law, inspectors, agents, etc. of the federal government can be arrested for attempting to enforce laws that are not recognized by the State of Indiana, and I have the right to treat them as illegal trespassers on my property (that is, by Indiana State law I can go so far as to shoot them).
Indiana recognizes the attempts of the FDA, USDA, ATF, and other federal agencies to enforce laws not recognized by the State to be an infringement on the rights of the State and its sovereignty. The state a few years ago took drastic measures in this regard, granting to all of its citizens (legally, a business is a citizen of the state in which it does its primary business)the right to take drastic measures against the federal government and its agents.

ALl I have to do to shut the FDA is to site the applicable Indiana law

The law in question being Indiana SR0042, passed in 2009
« Last Edit: June 07, 2014, 06:57:40 PM by Alpkäserei »
Guät git's dr schwiizer Chäser

Offline Alpkäserei

  • Old Cheese
  • *****
  • Location: Indiana/Kanton Bern
  • Posts: 600
  • Cheeses: 62
  • Default personal text
    • https://www.facebook.com/Kaesereigrimwald
Re: Use of wood - say goodbye./
« Reply #13 on: June 07, 2014, 06:53:45 PM »
regarding whether or not it is safe,

I see no reason personally to abandon wood. It is good, etc.
But if the state tells me to not use it, end of story. I won't argue with them, not in my position. It's not worth it for me. I would much rather establish and maintain good relationships with the officials, and hope for the possibility of working with them toward changing that standard (which is not expressly in the law, just in the doctrine which is always open to reinterpretation) or a least develop a set of exemptions. FOr now though, I must abide by the standards handed down to me.

I'd be more than happy to support an effort to drive change, but I can't be at the front of that effort.

This position is based on what I see as sound business practice. Because I am an artisan, I am a cheesemaker, a cheese lover, and a strong traditionalist who longs for the traditional ideal, but at the same time I am a businessman. I can draw the distinction between business and private practice. I'll be satisfied if I can set aside a few wheels for myself, family, and friends and age them on wood and do all the 'bad' things that I can't otherwise do.
Guät git's dr schwiizer Chäser

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,333
  • Cheeses: 41
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #14 on: June 08, 2014, 06:59:22 AM »
More.  The FDA was asked for a clarification.  Read on:

Quote
Hi everyone,
 
I am sending this e-mail to bring everyone on the same page with regard to the current situation on the use of wooden boards for aging cheeses.  FDA has recently inspected some artisan cheese makers who were using wooden boards for aging and has cited these establishments for this practice. On the other hand, the NY State Department of Agriculture and Markets (NYSDAM), Division of Milk Control and Dairy Services (who has regulatory authority for public safety over dairy processors) has allowed wooden boards for aging of cheeses as long as they are maintained in a clean and sanitary condition (and so has pretty much every other state in the union).  To get an official interpretation from the FDA on this issue, a request for interpretation was submitted to the FDA for a clarification and regulatory interpretation.  This was submitted to the Regional FDA, who sent it to CFSAN, as the interpretation would have national implications.   I have attached the document (Use of wooden shelves for cheese aging as attachment 1) that was sent to NYSDAM, Division of Milk Control and Dairy Services Director Casey McCue along with this text:
 
Hi (Name withheld),
Several weeks ago you had asked about our policy on aging cheese on wooden shelves and scientific references that you could  refer to; and I promised that we’d get it sent to you.  It has just been cleared and is attached.  I hope you find this helpful.  If you should have any further questions, please don’t hesitate to ask.
 
Sincerely,
 
 (Name withheld)
 
 
It has since been reiterated that the FDA will not change their policy and that it is based on science (the two papers cited are also attached as Attachments 2 and 3).
 
Addressing Imports
 
According to the FDA and in accordance with FSMA, a cheese maker importing cheese to the United States is subject to the same rules and inspection procedures that an American cheese maker is subject to.  Therefore, 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.    FDA states that it will be consistent in its application to both domestic and foreign producers.  Health Canada has stated that using wood boards for aging is not an issue to them, wood boards are allowed for aging cheeses and that their policy is not being reviewed nor is it being changed.  The European Union authorizes and allows the use of wood boards as shown by attachment 4 (Use of Wood by European Cheese Makers is Authorized by EU).  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.
 
Finally, according to the FDA this is not a change in policy, 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.
 
In short, it has according to the FDA always been the policy that wood is not allowed and they are not changing that policy in any way.
 
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.
 
 
(Name withheld)
(emphasis mine)

Yes, Alp, you're right - it is a business.  But I believe this is merely the first serious blow in a longer desire by the FDA to achieve sterilization - that only sterile food products can be safe.  And I believe, raw milk and its products are the greater goal.  Aside from the fact it will affect the cheeses we can get in the U.S. - my favorites, speaking personally - this effort will ruin the distinctive qualities that can only be achieved with raw milk.  You and I are but two people, with a lot more on this board using raw milk to make cheese.  It's a serious struggle ahead.

« Last Edit: June 08, 2014, 07:04:33 AM by ArnaudForestier »
- Paul