cheeseunderground Andy Hatch, bleu mont dairy, cheese, fda, raw milk cheese, uplands cheese, willi lehner, Wisconsin cheese

The Beginning of the End of Raw Milk Cheese in Wisconsin?

Wheels of Bleu Mont Bandaged Cheddar, once made
exclusively from raw milk, are now pasteurized
because Cheesemaker Willi Lehner can’t find a cheese
plant that will today allow raw milk through its doors.

I have been exceptionally lucky to have been in the right place at the right time most of my life. But no luckier than in 2003, when I took a job at the Wisconsin Department of Agriculture and got drafted into a small team that would go on to help artisan cheesemakers launch a dairy renaissance in America’s Dairyland.

Since then, I’ve been privileged to watch dozens and dozens of artisan cheesemakers start-up and craft what have become national and international award-winning cheeses, and many of those cheeses have been made from raw milk.

That’s why it’s particularly painful for me to put the last part of that sentence in past tense: “have been made from raw milk.” Because whether the American consumer is aware of it or not, many Wisconsin-made artisan cheeses that were only a year ago made from raw milk, are now pasteurized.

Last week, I got lucky again – this time I was in the right place at the right time to escort a leading French scientist to visit Wisconsin cheesemakers making raw milk cheeses. Christine de Sainte Marie is a senior research fellow at the French Institute National Institute for Agricultural Research. Her current research is on the political economics of reconnecting farming, food and the environment. Instead of slow food or fast food, she is studying people who are “farming in the middle” e.g. farmers using sustainable farming methods or cheesemakers making artisan cheese, but who are not certified organic. And she came to Wisconsin to study raw milk cheese.

So you can imagine my surprise when we arrived at Bleu Mont Dairy for our pre-arranged tour with one of Wisconsin’s original raw milk cheesemakers, Willi Lehner – once described by the New York Times as an “off the grid rock star” – only to find out he hasn’t made a raw milk cheese in months. Why? With no creamery of his own, he relies on renting space at other Wisconsin cheese factories to make his award-winning creations. And now, because of increased scrutiny and inspection protocols from federal inspectors, none of those factories will allow raw milk cheese out their doors.

“I feel there is an underlying fear in the whole cheese industry, that drains away the passion of our craft. And one of the results will be less and less real raw-milk cheese,” Willi said.

Brenda Jensen, cheesemaker and owner at Hidden Springs Creamery near Westby, agrees. Brenda makes more than a half dozen different cheeses, all made from pasteurized milk. She makes one cheese from raw milk: Ocooch Mountain, an alpine-style beauty that many have compared to a sheep milk’s salute to Gruyere.

Last week, this 50-time ACS award winner for farmstead sheep milk cheeses had a FDA inspector come to her door and ask for 20 wheels of ONLY her raw milk cheeses for testing. The inspector wanted the chain of ingredients, where they came from, all lots associated from them and a make sheet with all info. None of those requests are out of line, so Brenda spent several hours reviewing what was needed. But she kept thinking: “Why just the raw milk cheese?”

“Instead of the intimidation, I would rather have the inspectors help train me on what issues they are seeing with raw milk cheeses, and how better to safeguard against having these become a problem,” Brenda said. She is now considering stopping raw milk cheese production.

Bruce Workman, at Edelweiss Creamery in Monticello, decided last year that making raw milk cheese was no longer worth the risk or the headache of increased FDA scrutiny. His Edelweiss Emmentaler, traditionally made with raw milk, is now pasteurized.

Meanwhile, some cheesemakers, such as Andy Hatch at Uplands Cheese, remain committed to making raw milk cheese. With no pasteurizer in the plant, Andy crafts the thrice-awarded ACS Best in Show Pleasant Ridge Reserve on a seasonal schedule, making cheese only when cows are grazing on fresh pasture.

On our visit to his farm last week, Andy told Christine he plans on making his raw-milk Rush Creek Reserve this year (last year, he suspended production, because of uncertainty in forthcoming FDA regulations). But he admits, his passion for making cheese is now coated by anxiety.

“What’s different now is that the decision-making behind creating a new cheese is laced with an apprehension over unclear and changing regulations,” Andy said. “Whereas before my first instinct was always towards developing something unique and expressive, now I instinctively worry first about making an acceptable product, and then second about making it delicious.”

Despite uncertainty over FDA’s potential changes with regulating raw milk cheeses, Andy hopes cheesemakers will stay the course. In an update to ACS members today, it was noted that the FDA is embracing an approach in regulating raw milk cheese that will “involve continuing outreach to stakeholders and expanding the conversation” – especially about the aging process for soft-ripened cheeses – before making any decisions on next steps in changing the 60-day rule for raw milk cheese in the United States.

“We, as cheesemakers can’t allow those concerns to trump our efforts to make expressive, distinctive cheese. If we’re given a chance to prove with testing that our cheeses are safe, than those goals need not be mutually exclusive,” Andy said.

cheeseunderground fda, raw milk, raw milk cheese, regulations, rush creek reserve, uplands cheese, Wisconsin cheese

Rush Creek Reserve Production Stopped By FDA Rule Uncertainty

Andy Hatch with one of his first experimental batches of
Rush Creek Reserve on May 20, 2010. The cheese was
officially released that fall to great acclaim. Photo by
Jeanne Carpenter

Uncertainty over how the U.S. Food and Drug Administration will rule in regards to a number of pending raw milk cheese regulations has claimed its first official victim: Rush Creek Reserve by Uplands Cheese near Dodgeville, Wisconsin.

In an email to industry professionals this morning, Uplands co-owner and lead cheesemaker Andy Hatch broke the sad news that he will not be making Rush Creek this year.

“It’s disappointing news, I know, and we hope that it’s not permanent. Food safety officials have been unpredictable, at best, in their recent treatment of soft, raw-milk cheeses, and until our industry is given clear and consistent guidance, we are forced to stop making these cheeses,” Andy said.

Andy added it’s not a decision he and his team came to easily. “Hopefully, our government officials will soon agree on how to treat traditional cheesemaking, and we can all return to the cheeses that are so important to us.”

So what would make one of America’s most awarded cheese companies stop production of a cheese that debuted four years ago to great acclaim and that the New York Times described as “fluent and satiny, with a rich, slightly grassy aroma and a mild flavor that hints of smoke and pork.”?

Let us count the ways:

1. The FDA is currently reviewing the 60-day aging rule it imposed in 1949 on American cheesemakers making raw milk cheeses, with many academics speculating the rule will be increased to 90 or 120 aging days within the next year. For an excellent recap and history of how the current 60-day raw milk cheese rule came into being, check out this article by Bill Marler. Remember, Rush Creek Reserve is a raw milk cheese aged 60 days. It is patterned on the magnificent Vacherin Mont d’Or, of which I consumed an entire wheel at one sitting while in London on April 4. No regrets.

2. The newest focus of FDA food safety officials appears to be enforcement of non-toxigenic E.Coli levels in raw milk cheese. Unbeknownst to almost anyone in the industry, in 2010, the FDA changed the standard (see top of page 7) for non-toxigenic, E.Coli in raw milk from  less than 10,000 to  less than 10 MPN per gram. This happened even after the FDA’s own policy review team (see top of page 7) in 2009 suggested lowering it to only “100 MPN per gram in two or more subsamples or greater than 1,000 MPN per gram in one or more subsamples.” The FDA has begun to enforce this new policy by purchasing raw milk cheeses from distributors, testing them for pathogens, and then showing up at cheese factories for a 3-day investigative inspection. Every cheesemaker I talked to says it is virtually impossible to consistently produce a raw milk cheese with less than 10 parts of non-toxigenic E. Coli per gram. Goodbye, raw milk cheese.

3. Aging cheese on wooden boards may or may not be a dead issue. Two months ago, after a mid-level FDA bureaucrat declared the agency would no longer permit American cheeses to be aged on wooden boards, the entire U.S. cheese eating population erupted in an uproar that made the FDA back down just three days later. In Wisconsin alone, 33 million pounds of cheese are aged on wooden boards, including Rush Creek Reserve.

So to recap, between raw-milk aging rules, new pathogen policies, and the threat of whether the FDA is really backing down on the use of wooden boards, one of America’s great cheeses is no more. The death of Rush Creek Reserve should act as the canary in the coal mine for all American raw milk artisan cheeses, because just as our great American artisan cheese movement is in serious full swing, the FDA has basically declared a war on raw milk cheese.

P.S. Mind you, of course, the FDA pubicly insists they have nothing against raw milk cheese. At the American Cheese Society conference in Sacramento in July, a total of seven – yes seven – officials from the FDA politely attended a public luncheon after meeting privately with the ACS board of directors. Their fearless leader, Mike Taylor, FDA Deputy Commissioner for Foods and Veterinary Medicine, spoke to us industry professionals for 45 minutes at the luncheon. What he said can best be summed up with his opening words: “We are from the government and we’re here to help you.”

cheeseunderground aging, cheese, fda, Wisconsin cheese, wooden boards

FDA Further "Clarifies" Stance on Aging Cheese on Wooden Boards

After dozens of U.S. major news outlets did an outstanding job of reporting news on the FDA clarifying its position on the use of wooden boards when it comes to aging cheese, the agency today further clarified its earlier clarification.

Here is the FDA Statement:

“The FDA does not have a new policy banning the use of wooden shelves in cheese-making, nor is there any FSMA requirement in effect that addresses this issue. Moreover, the FDA has not taken any enforcement action based solely on the use of wooden shelves.

In the interest of public health, the FDA’s current regulations state that utensils and other surfaces that contact food must be “adequately cleanable” and properly maintained. Historically, the FDA has expressed concern about whether wood meets this requirement and has noted these concerns in inspectional findings. FDA is always open to evidence that shows that wood can be safely used for specific purposes, such as aging cheese.

The FDA will engage with the artisanal cheese-making community to determine whether certain types of cheeses can safely be made by aging them on wooden shelving.”

This back-stepping in both tone and message is welcome news for the hundreds of cheesemakers across the country who have invested their life savings in making premium artisanal cheese and aging it on wooden boards.

I want to give a special shout-out to every consumer who wrote a letter, signed a petition, left a comment on a blog or Facebook page and generally made standing up for artisan food a main-stream American issue. In the end, everything is politics. Thank you for taking a stand. We will most certainly need you in the future.

Cheese for life!

cheeseunderground aging, cheese, fda, wooden boards

Game Changer: FDA Rules No Wooden Boards in Cheese Aging

A sense of disbelief and distress is quickly rippling through the U.S. artisan cheese community, as the federal Food and Drug Administration (FDA) this week announced it will not permit American cheesemakers to age cheese on wooden boards.

Recently, the FDA 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 (like most every state in the U.S., including Wisconsin), 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.

In the response, Metz stated 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. Here’s an excerpt:
  
“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.”  

The most interesting part of the FDA’s statement it that it does not consider this to be a new policy, but rather an enforcement of an existing policy. And worse yet, FDA has reiterated that it does not intend to change this policy.

In an email to industry professionals, Rob Ralyea, Senior Extension Associate in the Department of Food Science and the Pilot Plant Manager at Cornell University in New York, says: “According to the FDA this is 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.”

Ah, FSMA. For those of you not in the know, the Food Safety Modernization Act is the most sweeping reform of American food safety laws in generations. It was signed into law by President Obama on January 4, 2011 and aims to ensure the U.S. food supply is safe by shifting the focus from responding to contamination to preventing it.

While most cheesemakers have, perhaps, begrudgingly accepted most of what has been coming down the FSMA pike, including the requirement of HACCP plans and increased federal regulations and inspections, no one expected this giant regulation behemoth to virtually put a stop to innovation in the American artisanal cheese movement.

Many of the most awarded and well-respected American artisan cheeses are currently aged on wooden boards. American Cheese Society triple Best in Show winner Pleasant Ridge Reserve from Uplands Cheese in Wisconsin is cured on wooden boards. Likewise for award-winners Cabot Clothbound in Vermont, current U.S. Champion cheese Marieke Gouda, and 2013 Best in Show Runner-Up Bleu Mont Bandaged Cheddar.

Wisconsin cheesemaker Chris Roelli says the FDA’s “clarified” stance on using wooden boards is a “potentially devastating development” for American cheesemakers. He and his family have spent the past eight years re-building Roelli Cheese into a next-generation American artisanal cheese factory. Just last year, he built what most would consider to be a state-of-the-art aging facility into the hillside behind his cheese plant. And Roelli, like hundreds of American artisanal cheesemaekrs, has developed his cheese recipes specifically to be aged on wooden boards.

“The very pillar that we built our niche business on is the ability to age our cheese on wood planks, an art that has been practiced in Europe for thousands of years,” Roelli says. Not allowing American cheesemakers to use this practice puts them “at a global disadvantage because the flavor produced by aging on wood can not be duplicated. This is a major game changer for the dairy industry in Wisconsin, and many other states.”

As if this weren’t all bad enough, the FDA has also “clarified” – I’m really beginning to dislike that word – that in accordance with FSMA, a cheesemaker importing cheese to the United States is subject to the same rules and inspection procedures as American cheesemakers.

Therefore, Cornell University’s Ralyea says, “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. The European Union authorizes and allows the use of wood boards. 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.”

Ralyea continues: “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.”

In fact, many research papers do in fact conclude that wooden boards are safe. In 2013, the Wisconsin Center for Dairy Research published a paper on the subject, concluding: “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.” You can read the whole report on pages 8-9 by clicking on this link.

Interesting side note: Health Canada does not currently have any regulations prohibiting aging and ripening cheese on wood, so apparently if we want to eat most American or European artisan cheeses, we’ll need to drive across the border to do so.

So what’s next? The American Cheese Society has mobilized its Regulatory & Academic Committee to learn more about this issue, and to ensure its members’ interests are represented. The ACS promises to keep us apprised of developments. In the meantime, if you are a cheesemaker, and your operation is inspected and cited for the use of wooden surfaces, please contact the ACS office (720-328-2788 or info@cheesesociety.org).