CheeseForum.org » Forum
GENERAL CHEESE MAKING BOARDS (Specific Cheese Making in Boards above) => EQUIPMENT - Aging Cheese, Everything Except Caves => Topic started by: ArnaudForestier on June 06, 2014, 11:33:56 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.
""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."
-
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.
-
Wow, Spoons, I didn't realize this. The morons are opining on what they don't know. It's damn frustrating.
-
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.
-
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, 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...
-
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.
-
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 (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 (http://www.treenshop.com/Treenshop/ArticlesPages/SafetyOfCuttingBoards_Article/CliverArticle.pdf)
-
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.
-
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.
-
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.
-
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 (https://www.youtube.com/watch?v=9BZEy6dSY6Q)
-
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
-
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.
-
More. The FDA was asked for a clarification. Read on:
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.
-
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 (http://www.foodsafetynews.com/)
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 (http://www.cheesesociety.org/)
-
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 (http://www.marlerclark.com/practice_areas) 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:
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:
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.
-
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 (http://cheeseunderground.blogspot.com/2014/06/game-changer-fda-rules-no-wooden-boards.html) to the ACS (http://campaign.r20.constantcontact.com/render?llr=458zumcab&v=001vuCdHl1qDg49MaVQQkBDB2U1fQy1iYWvtTEIv2ojcRlNeet7ikyvhqBTEmBeHoM81MmgqdAv0qGg0-gP-nXrn5BzPvSkolJ5gdKkDdOhSBVIQa15R9josWdBQVthAlP3t9VRmob5xKSxixn5fS-TRHu891BVCTB9uXdHUtZLegrAybFEy4TvcByUFu7AsFSdXB1q0NXom79Kmq8QSC2-25e4WSC6A5etOXDeZ8xyjfVZgaKQySKDbKIwSt84YdUZL-HQf1T0uW9Jiv18XzFXDARn7tYPDDW3JNF8BYF3u0r_pr312cgYfQ%3D%3D) or to the alleged FDA statement (http://origin.library.constantcontact.com/download/get/file/1102083583967-704/Use+of+wooden+shelves+for+cheese+aging.pdf) (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.
-
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 (http://en.wikipedia.org/wiki/Michael_R._Taylor) - cute that a former Monsanto executive is Favored Son for the FDA (http://www.huffingtonpost.com/jeffrey-smith/youre-appointing-who-plea_b_243810.html)).
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.
-
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 (http://www.fda.gov/iceci/enforcementactions/warningletters/2012/ucm325714.htm)
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 (http://www.fda.gov/newsevents/newsroom/pressannouncements/ucm395339.htm)
-
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:
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.
-
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.
-
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.
-
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.
-
I just found this wood and the FDA (http://reason.com/blog/2014/06/11/wood-aged-cheese-is-ok-says-fda)
-
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
-
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.
-
;D YESSSSS!!!
-
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.
-
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.
-
Check this out...
http://www.forbes.com/sites/gregorymcneal/2014/06/10/fda-backs-down-in-fight-over-aged-cheese/ (http://www.forbes.com/sites/gregorymcneal/2014/06/10/fda-backs-down-in-fight-over-aged-cheese/)
-
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.
-
my state guy says, wood with a food grade oil sealant is fine.
raw wood is not.
i can live with that
-
Sorry if this is too sententious or sentimental. Just want to say, I've a lot of respect for all here. I know we're all trying to do good work - and any disagreements are within that context.
-
What happens when they tell Jack Daniels they can't age their whisky in oak barrels???