Ch-Ch-Ch-Changes, But Not Always For the Better!

Volume 140, No. 35, February 19, 2016

In the last month, two seemingly unconnected things were reported in the media: Cowgirl Creamery sold to the American subsidiary of the Swiss cheese giant, Emmi; and the FDA suspended tests of non-disease causing bacteria as an indicator of the sanitary conditions on a dairy farm.

Congratulations to Sue Conley and Peggy Smith! You’ve done incredible things for cheese, and particularly for artisan cheese in the United States. You deserve to do well. I’m jubilant for you.

But I’m concerned in a way that has nothing to do with Cowgirl Creamery, Cypress Grove, or Redwood Hill, or Roth Kase, all now Emmi America. Why do artisan cheese companies have trouble surviving intact into the next generation? Why do the companies who purchase them consistently come from beyond our borders?

What is there about the current system in the dairy industry that leads to this troubling outcome: some of the top award winners at the annual American Cheese Society competition will now no longer be American. I’m not talking about turning our back on great European and Canadian companies. But what holds our American companies back? Why have none risen high enough to be able to, or have an invest in purchasing these beautiful little gems?

And then there is this little folderol with the FDA over lower density standards for non-disease causing coliform bacteria counts long used as an “indicator” of the general sanitary conditions on a farm. So, following the logic that these bacteria come from the same source as some of the worst disease-causing bacteria, it makes sense, logically, that a high incidence of them probably signifies unclean conditions in the milking parlor. Anyone in the industry for any length of time knows that that isn’t always so.

Some microbiologists question the reliability of using bacteria that don’t make you sick to “indicate” for bacteria that do; why not test for the bacteria that make you sick directly?
“The FDA’s reason for testing cheese samples for non-toxigenic E. coli is that bacteria above a certain level could indicate unsanitary conditions in a processing plant.”


Yeah, and then? If you don’t find out the cause, here it comes, back at you again! I’ve seen with my own eyes tested and inspected dairies run by capable people so caught up in the game of passing the test and filling out bureaucratic forms; their milking parlors were a mess.

Pull the valve on the bulk tank and find four feet of yogurt inside. Take the cap off the mixing tank, and find biofilm city. Biofilm breaks away, intermittent high coliform count. In fact, a few years ago, a mutation occurred in bacteria hiding in biofilms in milk tanks across the northern US and Canada that led to exploding cheeses, even though the milk had been pasteurized. Since bacteria counts are a result of something, the count can only be lowered by fixing the something; only good process can lead to a good result.

Ironically, because it is human beings who do the testing, and people who react to the testing, focusing on results has been proven to rob resources away from what makes a difference, improving the process. The road to hell is paved with good intentions.

Could it be that the problem is not the testing, but how the test is being used? In 1930, Dr. Walter Shewhart introduced the idea that quality cannot be inspected into a product, as, duh, an inspection takes place after the product is already made. His ideas became known as the Quality discipline, and it has revolutionized modern manufacturing.

The electronics industry was plagued for decades by quality problems, expensive inspection schemes, tons of rework, and huge losses. They turned to Shewhart’s system of continuous quality improvement, revolutionized their method of manufacture away from inspection after the fact to the better work processes, and saw a dramatic drop in the number of defects, rejects, returns, and failures, and an amazing rise in profits. Think about it; chips are produced at thousands per second; you snooze you lose.

The problem with tests based on an adversarial relationship between the authorities and the producer, the boss and the worker, the public and the industry, is that everyone becomes focused on passing, not necessarily on making things better.

Why test for what doesn’t matter, when you can test for what does, and use the results pragmatically? Why not build quality into the process rather than wait to catch it after the fact? We have a machine we hold in our hand that has all our music, streams movies, lets us talk to anyone in the world practically for free. The government invented and gave us the internet, for free. Is it so difficult to imagine that instead of spending so many resources in a game of cat and mouse, the government could invest in developing affordable, reliable and rapid tests for the bacteria that make us sick?

And if those tests were used as key process indicators in a program of continual improvement rather than a gotcha, they could help farmers better understand their process and how to improve it. Like many different industries around the world, food safety and product quality would improve forever, and dramatically.

And then this giant step backward appeared on my Facebook timeline: Recently, “a U.S.-Canada Regulatory Cooperation Council [was set up– d.s.] to help the two countries “better align their food safety regulatory systems, reduce unnecessary duplication, enhance information sharing, and to the extent possible, leverage resources so that the agencies can better meet their public health objectives.”


Will this accord lead to more testing, stricter testing, and more resources spent on the wrong things? Canada has even more rigorous standards for non-disease causing bacteria counts than the United States. In fact, the changes that got suspended suspiciously matched the Canadian standard.

Artisan cheese depends on raw milk having enough bacterial diversity to ensure a uniquely rich and rewarding flavor. That flavor comes from non-disease-causing bacteria. Lowering the counts makes the milk poor in microbial richness, zapping the flavor. The FDA knows this, which is why they suspended their program for further review. This is good news. But the fact remains, Canada is even more control crazy than the US and the stricter they are the harder for them to compromise.

Artisan cheese depends on raw milk having enough bacterial diversity to ensure a uniquely rich and rewarding flavor. Lowering the counts makes the milk poor in microbial richness, zapping the flavor.

The discipline of Continuous Process Improvement, as taught by Shewhart and Deming, could greatly improve the safety, quality and profitability of Dairy Products, fundamentally shifting the relationships from “us against them” to “we are in it together so we better understand just what’s happening here.”

Developing rapid testing for known disease causing bacteria makes more sense than using indicators. Only a coordinated effort from farm to table can ultimately make a difference! Why limit ourselves to 19th-century solutions in the 21st century?

Dan Strongin is a former president of the American Cheese Society, chef and business coach for small to medium value added businesses, and the owner of the sites, and the Facebook group Enjoy Cheese. His online course: “Cheese: How to Buy, Store, Taste, Pair, Talk About and Serve”, is available at Dan can be reached via email at

Dan Strongin encourages your comments regarding this column. Comments can be made anonymously to


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