Some Things Matter

Volume 140, No. 20, November 6, 2015

The FDA was (through Nov. 2) taking comments on changing the requirements for aged raw milk cheese, and the scuttlebutt is they will change the requirements to more than 60 days aging. This, combined with a recent decision to copy the Canadian standard for Coli count, which is more restrictive than the old standard, will deeply damage artisan cheese production in the US as we know it.

If we allow the FDA to create roadblocks for artisan cheese that are not based on current scientific understanding, it is only a matter of time before a ruling comes down that will affect even the most conventional producers.

So why should a pasteurized milk producer care? When I started working to promote good cheese in the 1990’s, 90 percent of all the sales of specialty cheese was owned by the Europeans. Most specialty cheese counters had no more than one or two American cheeses. Larger producers didn’t even want to compete against them. Commodity cheese was in its heyday and it was too easy to make money selling orange slices.

The world has changed. Artisan, Farm, Farmhouse and Specialty cheese have become a sizable niche, and American consumer tastes have moved away from inexpensive orange colored slices. Many of the kings of 30 years ago are no longer with us, or in deep trouble. Abandoning the specialty niche to the Europeans again would be a foolish, painful choice.

But even more important goes back to the advice my father gave me about dating. My best friend’s girlfriend was flirting with me, and she was very attractive, so I asked my father’s advice. He told me that if they would abandon your friend for his best friend it is only a matter of time before they would do the same to you.

If we allow the FDA to create roadblocks for artisan cheese that are not based on current scientific understanding, it is only a matter of time before a ruling comes down that will affect even the most conventional producers.

And the US has signed treaties. In those treaties it states that no country can pass restrictions unless they are proven science. The use of coliform counts in milk is not good science, it is a convenience, allowing us to feel like inspection has taken place when it hasn’t. The correlation between higher coliform counts and foodborne disease is not necessarily causal.

What matters is not how rich the milk is in bacteria, but how many disease causing bacteria are in it. There are only a few bacteria that can make people sick compared to the billions that do nothing, including those that improve the flavor and digestibility of cheese. We have the technology to test for those bad bacteria. Doesn’t testing make more sense? Right now it is expensive for the producer, but stop the coliform tests, and apply some American know-how and resources and in short order, reliable and affordable tests could be made available almost over night.

There was discussion going on a few years back to change the requirement for pasteurization, given new technologies of milk production like micro-filtration. We are arguing over 19th century solutions.

With technology and computers, and a little foresight, testing could be done on every batch of cheese, or milk, until a producer proves they are reliable. Then random testing could be continued, which is scientifically and pragmatically more effective than taking a shot in the dark with coliform counts. You don’t need to believe me, look at the body of scientific literature, in particular in food microbiology.

The same applies to the 60-day rule. I say, test for disease-causing bacteria, focus on improving process, and sell any clean cheese or milk product without restriction. Don’t laugh, tomorrow they may pass a rule based on murky science that could potentially hurt your business.

Some Things Matter, and this does. What follows is an excerpt of the comments I left for the FDA in their request for public comment on potential changes to the 60 day rule.

“To whom it may concern,
I am sure you will agree that finding solutions that make a difference should be the focus of any public policy. Limited resources need to be applied in the most effective manner. Raw milk cheese is polarizing and there is little middle ground. What is needed is a more pragmatic approach.

No sickness is the right amount. But major changes are being called for, up to and including rules that could put an end to the economic viability of what small family farms depend on for their livelihood: aged raw milk cheese, based on a throw of the dice? (probability statistics improperly applied).

The actual data tells a different story:
It is fundamentally unfair to include commercially produced with non-commercial product in the same analysis, and then draw conclusions affecting both. The largest number of commercial outbreaks were in Restaurants, Schools and Camps. The overwhelming majority of actual incidents involve food handling, rather than the innate integrity coming from the factory.

By Germ
While most reported outbreaks are caused by Campylobacter, the most illnesses were caused by Salmonella, by a large margin. While it is true that Campylobacter and Raw Fluid Milk have a causal connection, only a tiny number of this germ are linked to cheese, and that homemade cheese. Most incidents of Salmonella are secondary processing meaning after the product leaves the manufacturer. Listeria is environmental and can effect both raw and pasteurized milk if in the environment, but it is fairly easily prevented through good practice.

Though it may sound logical to increase the time of aging for aged raw milk cheese from 60 to 90 days before it can be sold, and to lower the count of non disease causing coliform as a “marker” of sanitation, will that solve the problem?

Where is the empirical science supporting levels of non pathogenic coliform as a marker of sanitation. Doesn’t testing for the actual disease causing bacteria make more sense? Money invested developing rapid testing for pathogens would make the food supply safer.

Towards Real Safety
The cure is in continual improvement of process. Most pathogens get into milk from contact with feces from infected animals. Careful monitoring of the animals, good manufacturing and agricultural processes, and fore-stripping has the potential to diminish or eliminate them.

Developing affordable rapid tests for pathogens like E. coli, Salmonella, Campylobacter and environmental tests for listeria in dairy plants, and an public/private industry wide effort to install continual improvement would be more effective than increasing the burden on producers based on dicey probability calculations, and half science. DS

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Dan Strongin runs a training and consulting company focused on delivering affordable online solutions to everyday business problems, including his udemy course: Understand Your Business, Earn More Money. Dan can be reached via email at or by phone at (408) 512-1086, or you can visit and blog or get discounts on his courses on his site:

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


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