Author Topic: Use of wood - say goodbye./  (Read 1433 times)

Offline Sailor Con Queso

  • Old Cheese
  • *****
  • Location: Kentucky
  • Posts: 2,525
  • Cheeses: 125
    • Boone Creek Creamery
Re: Use of wood - say goodbye./
« Reply #15 on: June 09, 2014, 09:51:44 AM »
If you want a real eye-opener and a little insight into what the FDA is dealing with, check out this website:

Food Safety News

There are reports EVERY DAY of food contaminated with Salmonella, Listeria, E. coli, etc. that the public often doesn't even hear about. And there is a lot more contaminated cheese and raw milk than you probably think (review their archives). I check this website every morning.

The FDA is not the bad guy. If there is a food borne outbreak in the USA, then the FDA will be blamed for not being tough enough. Given the hostile political climate in Washington, people at the FDA would lose jobs, and even Obama would be blamed for "something" (who knows what). I find that being proactive, and educating inspectors before there is a problem is much more effective than negative blame.

Our national lobbying and advocacy organization is the American Cheese Society. I suggest that everyone join and become a part of the dialog and the solution. Your support goes a long way towards addressing these sorts of problems. Check out their online educational webinars, etc for members only. Here's a web link:

American Cheese Society
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 ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,315
  • Cheeses: 39
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #16 on: June 09, 2014, 10:22:18 AM »
I come from a very different perspective, Sailor.  The site you link to, "Food Safety News," is in fact owned by Bill Marler, partner in the law firm, Marler Clark, which funds the "Food Safety News" website.  Marler Clark is a law firm specializing in foodborne illness litigation.  Its business, in fact, is in the making of money in the foodborne illness trade.  It makes a mint.

The "Food Safety News" is no more a news site than any other site run, maintained, funded by a party with a direct conflict of interest.  To call it "journalism" is in fact, by any standard of journalistic ethics, a complete sham.

My experiences here conclude the FDA has devoted an exceedingly out of proportion stance regarding raw milk.  John Sheehan, man in charge of dairy food safety:

Quote
Raw milk is inherently dangerous and should not be consumed by anyone, at any time, for any reason.


I'd like Mr. Sheehan to address how, if this is the case, our species did so well on raw milk for millenia.  Raw milk produced in crap industrial conditions, yes, he's got a point.  Think the disgusting conditions of food generally at the turn of the Twentieth Century, and one does get a very poor picture of what could otherwise be - and again has been, for thousands of years - an entirely nutritious, safe product.  It's best guarantee of safety, in my opinion, is in regular testing, and - as with all food - lessening the hands involved between producer and final consumer.  You have to pasteurize milk produced in the holocaust that are CAFO operations, especially given that the commodity milk produced there, is blended with milk from sundry other, filthy, remote CAFOs.  It's inherently dirty milk. 

But milk from a grazer, with cows on grass all day?  And tested, regularly?  And you know the milker, and see how she or he produces?

The debate is too lengthy here.  My point in creating this thread was to post the material I received from ACS, the same material Sailor copied, the FDA's crackdown on wood in cheesemaking.  The FDA doing so, while ignoring the science (take a look at Jeff's posts above - and go to his links) promulgated by scientists even as normally "big agribusiness" as UW, who concluded wood can be part of a safe SOP in a cheeseplant. In this study (google "uw pipeline wood", you'll find it.  The study begins on page 8 of this .pdf), they conclude:

Quote
Finally, 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.


As I post above, on a call for clarification, it does not appear the FDA will reconsider, regardless of what science exists.

Given Mr. Sheehan's view, as I said, I have no doubt what he and his FDA colleagues want for our land, the complete outlawing of raw milk and raw milk products.  Good people have lost their entire herds, their entire production, their entire livelihood, based on this ill-founded (but very well funded) zealousness. 

That's my perspective.  I'd encourage anyone interested in the subject to watch the film Fresh, as a start; to read Raw Milk Revolution and other related books; as well, read the books and materials taking an adverse position on raw milk; what the FDA and other prosecuting agencies have to say, all with an open mind.  Investigate and form your own opinions. 

Mine couldn't be clearer.
« Last Edit: June 09, 2014, 11:40:58 AM by ArnaudForestier »
- Paul

Offline FictionalCheese

  • Young Cheese
  • **
  • Location: Colorado
  • Posts: 7
  • Cheeses: 1
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #17 on: June 09, 2014, 06:33:07 PM »
Can anyone confirm that this is even real? I've been trying to find something well reported or official looking for a while now, and all I can find is that everyone talking about it points back either to Cheese Underground  to the ACS or to the alleged FDA statement (which the ACS links to).

I say alleged FDA statement, because it isn't formatted like a formal government document (no author is mentioned, it's not in a formal letter format, etc), and it's not hosted by the government.

Quite possibly I'm missing something, but I can't see anything that says that the FDA really is banning wooden aging boards, so I thought I'd ask if anyone here has anything definitive.

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,315
  • Cheeses: 39
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #18 on: June 09, 2014, 10:20:36 PM »
Fictional, you raise a valid point.  I suppose if this is specious, it will show itself within a day or two, because as it stands, Monica Metz is the putative FDA drone responsible for this bizarre action.  She was QC at Leprino Foods - the world's largest producer of mozzarella cheese. 

The world's largest producer of mozzarella cheese.  No, I don't see an issue here.  As I don't see it countless times.  (See Michael Taylor - cute that a former Monsanto executive is Favored Son for the FDA). 

Sailor, I couldn't disagree more.  The FDA is very much "the bad guy."  Here, it has grossly overreached its position, with poor science (and ignoring good science), and no public input on this decision.  (My only hope that it will get trounced in judicial review, actually). 

Yeah, I get seriously pissed when 1000's of years of history as data point are ignored; when regulators supposed to regulate our food supply come from global food behemoths whose interest is very much in squeezing niche competitors out of business. 

This isn't conspiracy theory.  Beyond the sheer idiocy of such a sweeping decision, this is simple conflict of interest, folks.  And because it irrationally (at best; or unfairly, more likely) screws a practice very much a core component of a tradition I believe in, I cry foul.  Insanity.
« Last Edit: June 10, 2014, 04:51:45 AM by ArnaudForestier »
- Paul

Offline Sailor Con Queso

  • Old Cheese
  • *****
  • Location: Kentucky
  • Posts: 2,525
  • Cheeses: 125
    • Boone Creek Creamery
Re: Use of wood - say goodbye./
« Reply #19 on: June 09, 2014, 10:23:18 PM »
This was not the first run-in with the FDA for at least one of the cheese companies recently cited in New York. One company was inspected multiple times in 2012 and environmental swabs showed the presence of Listeria on the aging boards and in their brine tank. Further testing showed that Listeria was actually present in a Brie style cheese and high levels of E. coli was found in their Gouda. E coli is a fecal contaminant, so this suggests a problem with basic sanitation. They were sent this warning letter In October 2012:

FDA Warning Letter

One of the comments says: "You failed to clean and sanitize all of the wooden boards used to hold your Gouda-style cheese in the large aging cave even after FDA informed you of positive L. monocytogenes results found on one of these boards."

So at that point, the FDA did NOT demand that they stop using wooden aging boards. And they said nothing negative about their use of raw milk. But they did insist that they clean and sanitize all ongoing problem areas identified during multiple inspections. The FDA gave them written warnings and plenty of time (almost 2 years) but they ultimately failed to comply, so on April 28th a District Judge in New York issued a Consent Decree of Permanent Injunction against the company and shut them down, at least temporarily.

Here is the Consent Decree
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 ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,315
  • Cheeses: 39
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #20 on: June 09, 2014, 10:39:17 PM »
Sailor, I'm aware of the background.  You're pointing up the very flaw in all of this.  You can't be told to clean and sanitize something that is inherently impossible to clean and sanitize. You can't cite a company for failing to clean something you also rule, cannot be cleaned.

To quote:

Quote
You failed to clean food-contact surfaces as frequently as necessary to protect against contamination of food as required by 21 CFR 110.35(d).  You failed to clean and sanitize all of the wooden boards used to hold your Gouda-style cheese in the large aging cave even after FDA informed you of positiveL. monocytogenes results found on one of these boards.

OK, fine.  The question must then be asked - if wood cannot be used safely in a cheesemaking operation, as this FDA action has stated, how can you then be cited for "failing to clean...." that same material?  The FDA warning letter you cite, and which is widely available, doesn't say wood cannot be made safe, only that the firm in question did not properly clean the wood. 

How did we go from this, to a blanket prohibition on wood, as inherently unsafe?  In a word, how the hell can you clean something that cannot be made clean?  Do you not see the huge logical gap being played out here?  And by a regulator, once again, in bed with a global food behemoth?

This is fundamentally ludicrous.  All cheeses?  Only high Aw cheeses?  What? 

Ludicrous, but it has a devastating impact on an important tradition.  If this stands, we will not be able to import Beaufort.  Comté.  We cannot make cheeses on wood, which is an integral part of the process of many cheeses. 

The FDA is not friend to artisanal food producers.  And I reiterate, this is part of a larger design to eliminate all flora in the production of foods.  Raw milk is on the list.  Just ask the guy from the FDA responsible for "dairy food safety," as stated above.

« Last Edit: June 09, 2014, 10:51:48 PM by ArnaudForestier »
- Paul

Offline Sailor Con Queso

  • Old Cheese
  • *****
  • Location: Kentucky
  • Posts: 2,525
  • Cheeses: 125
    • Boone Creek Creamery
Re: Use of wood - say goodbye./
« Reply #21 on: June 09, 2014, 11:21:32 PM »
OK, so I want you to play the role of the inspector for a few moments. Put yourself in their shoes.

During your routine inspection your swabs detect Listeria in various locations, including wooden aging boards. Other testing reveals the same strain of Listeria in a finished cheese destined for human consumption. Even more testing shows clinically significant levels of pathogenic E. coli in yet another cheese.

So, what do you do?

Well a really hard azz inspector could have demanded a complete recall and destruction of all existing cheeses. After all, Listeria was found in multiple locations in the aging environment. And E coli is a definite sign of fecal contamination and generally unclean conditions. So it could have easily been argued that every cheese in the place posed a public health risk. But the inspectors didn't. Why?

OK, let's take the good cop approach. The level of Listeria on the aging boards is "probably" not a problem. WAIT. There is actually Listeria in one of the cheeses ready to ship out. No big deal. Chances are that nobody will get sick. Hmm.. so how many other contaminated cheeses HAVE been shipped out before now? And don't forget the Gouda with the E coli. Maybe this place has bigger problems than I thought. But let's let them just keep on doing what they have been doing and hope for the best???

Let's take a fair and balanced approach. You write them up and outline the problems, giving them ample time to come up with a game plan and solve the problems. However, follow up inspections show the same ongoing problems. How long do you let that keep going on? Wait until somebody gets sick?

You're right, the FDA did NOT say that wood cannot be made safe, but corrective action is not the responsibility of the FDA. In this case, the cheese company did NOT demonstrate that wood can be used safely.
A moldy Stilton is a thing of beauty. Yes, you eat the rind. - Ed
www.boonecreekcreamery.com

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,315
  • Cheeses: 39
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #22 on: June 09, 2014, 11:52:27 PM »
Sailor, I'm not sure how any of that relates.  We grant that the plant in question was rightly cited.  But that's not what's at issue. 

What's at issue, I think I've laid out fairly well, above.   
- Paul

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,315
  • Cheeses: 39
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #23 on: June 11, 2014, 11:59:51 AM »
For what it's worth:  The FDA, I think, has been hammered by this decision.  It is now inviting a "dialogue" with artisanal makers. If this is something that matters to you, I'd urge all to contact your legislators and seek their support.  I do not like posting political topics on a public forum; but this feels germane, and important.  (I did check the forum's SOP to make sure I wasn't breaking rules...as far as I can tell, I'm OK in doing this.  If any know differently, please let me know and I'll gladly ask the thread's removal).  I also invite a dialogue amongst us - I'm perfectly open to talking about this and invite disagreement, where it exists.

If this helps, here's a possible boilerplate for others to use:

(Senator) (Representative ___), etc., I'm a constituent in your district - my family and I reside in (   ).

I write to you with serious concern about the FDA's grossly overreaching and exceedingly ill-founded position on the banishing of wood in making and aging artisanal cheeses.  The action contains language in part, saying:

"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 FDA, in its action, has taken a kind of cleaver approach to what can be dealt with in a more reasoned, responsible fashion.  In doing so, the FDA ignores good science showing exactly that not only can wood be used in a responsible way, but how to maintain wood in a creamery environment, in a safe, clean, and sanitary way.

A study from Journal of Food Protection 57:1, pp. 16-22 (.pdf) shows, in part that wooden cutting boards, inoculated with one or more of E. coli (including the pathogenic O157:H7), Listeria, and Salmonella, were in fact safer than the plastic cutting boards of the study's samples.

Another report from UW Madison (See Pipeline 25:1, pp. 8-9) (.pdf),evaluating studies on the safety of wooden shelving in traditional, artisanal creameries, concludes with:

"The present study shows that the use of wooden shelves does not affect the hygienic safety of cheeses if such shelves are in good repair and are thoroughly cleaned and sanitized by heat treatment."

Finally, adding to the experimental science supporting the notion that wood in the use of cheese manufacture and aging can be a safe, sanitary medium, history alone speaks strongly in support of the practice.  Cheese has been made this way, with the use of wood, for 1000's of years - chronicling reports of French alpine cheeses go back as far as Caesar's time.  That alone is considerable "anecdotal" evidence, to support the practice.

Aside from this science deserving at least a considered review, the FDA made this action, unilaterally; it did not take public commentary nor follow other proper protocol in coming to this draconian decision.  This simply cannot stand by any reasonable evaluation.

Artisanal cheesemakers in America represent the best of entrepreneurial spirit, integrity to craft, and concern for the good health and pleasure of their end-point consumers.  Those with established practice in the use of wood did so, and do so, under considerable cost and care.

This decision is simply a bad decision.  I strongly urge you to evaluate the seriousness of the issues involved, and do what you can, in as determined a manner as your office permits, to right this unjust and ill-founded wrong.  I thank you for taking the time to evaluate my request, and the request of my fellow cheesemakers and our supportive customers.

Sincerely,

(    )

-thanks, all.
- Paul

Offline H-K-J

  • Old Cheese
  • *****
  • Location: South-east ID
  • Posts: 1,300
  • Cheeses: 81
  • By failing to prepare, you are preparing to fail.
    • Cookin with uh dash dogs hair
Re: Use of wood - say goodbye./
« Reply #24 on: June 11, 2014, 05:37:16 PM »
I just found this wood and the FDA
act as if it were impossible to fail.


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


Offline Alpkäserei

  • Old Cheese
  • *****
  • Location: Indiana/Kanton Bern
  • Posts: 598
  • Cheeses: 62
  • Default personal text
    • https://www.facebook.com/Kaesereigrimwald
Re: Use of wood - say goodbye./
« Reply #25 on: June 11, 2014, 06:22:44 PM »
I'm going to email my State guy, see what they say

He told me, it is Indiana's policy to disallow wood as a direct contact surface, I'm going to cite this, and see if perhaps now would be an appropriate time to review this policy, in light of all of this recent attention
Guät git's dr schwiizer Chäser

Offline Alpkäserei

  • Old Cheese
  • *****
  • Location: Indiana/Kanton Bern
  • Posts: 598
  • Cheeses: 62
  • Default personal text
    • https://www.facebook.com/Kaesereigrimwald
Re: Use of wood - say goodbye./
« Reply #26 on: June 11, 2014, 06:34:12 PM »
We should be happy for our victory

and in the interest of good relations, we should be satisfied and I suggest we don't push the idea that the FDA is backpedaling. We got our way, we should be happy about that. 
Guät git's dr schwiizer Chäser

Offline H-K-J

  • Old Cheese
  • *****
  • Location: South-east ID
  • Posts: 1,300
  • Cheeses: 81
  • By failing to prepare, you are preparing to fail.
    • Cookin with uh dash dogs hair
Re: Use of wood - say goodbye./
« Reply #27 on: June 11, 2014, 07:33:25 PM »
 ;D YESSSSS!!!
act as if it were impossible to fail.

Offline WovenMeadows

  • Mature Cheese
  • ****
  • Location: Saranac, NY
  • Posts: 160
  • Cheeses: 5
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #28 on: June 11, 2014, 08:27:26 PM »
New England Cheesemaking just posted about this too, and linked to a petition beginning to go out - H-K-J's link links to it as well.

Offline ArnaudForestier

  • Old Cheese
  • *****
  • Location: Madison, Wisconsin
  • Posts: 1,315
  • Cheeses: 39
  • Default personal text
Re: Use of wood - say goodbye./
« Reply #29 on: June 11, 2014, 10:15:12 PM »
We should be happy for our victory

and in the interest of good relations, we should be satisfied and I suggest we don't push the idea that the FDA is backpedaling. We got our way, we should be happy about that.

Alp, I'm not sure we've achieved a victory, so much as a momentary pause.  I do not believe even this would have come about except for a tremendous outpouring of public pressure coming to bear on this. 

I hope this is illustrative.  We had a restaurant.  Though our county was known to be among the most stringent in Michigan for their interpretation (and let us not believe it's all crystal clear, uninterpretable statutory law) of regulatory laws, we wanted to open, and, yes, it's of no use to take an unnecessarily adversarial stand, even on many of the overreaching things we were asked to do. 

We were, at one point, told our hot water capability was insufficient.  The cause?  Our lettuce rinsing sink did not have hot water supplied to it, and if it were, our water heater was of insufficient volume and recovery to supply the total required water at peak capacity - supply the water as if every hot water tap was on full volume, for a sustained period. 

Lettuce rinse sink - with hot water?  Had I not fought this, we were looking at close to a major, $15,000-$20,000 rehaul of our entire heating system, to accommodate this request - a small rinse sink; it tripped the peak load switch.  I fought like hell - that was money directly out of my family's coffers over a ridiculous requirement.  But that's what the letter of the law said, so it was insisted, and so, by god, that was what we were going to do.  It took my securing the Governor's office's help (the Governor at the time had a special fondness for the Upper Peninsula), and getting the State-level office to tell the county level office to calm down, to win this one, small fight - with pretty substantial consequences. 

Here, with wood, I think of how easily the hundreds of cheesemakers with tens of 1000's of dollars invested in their aging facilities were being told, in no uncertain terms, that wood is impossible to clean and keep sanitary, and, by god, the FDA was going to enforce its policy.  In a recent class at UW, we were in fact warned, this action was coming. 

I don't think we need maintain an adversarial tone.  But neither do I think we can afford to do anything but stay vigilant to actions such as these.  In my opinion, the FDA moved, or more likely, this one office of the FDA moved, because the issue was brought to the glaring light, and pressure was applied.  Nothing less.
« Last Edit: June 11, 2014, 10:25:39 PM by ArnaudForestier »
- Paul