Quarterly updates on ACS's efforts to promote, preserve, and protect traditional cheesemaking.

In this Issue of The Traditional Cheese Advocate... 
FDA Shares Update at ACS 2016 in Des MoinesFDANews

Dr. Nega Beru, Director, FDA CFSAN Office of Food Safety , shared an update with ACS Conference attendees in Des Moines this summer. The full presentation is available at ACS Education on Demand. The session addressed key stakeholder concerns including:
  • Results of the Raw Milk Cheese Testing Pilot Program which showed that of 1,600 cheeses made from unpasteurized milk which were sampled, less than 1% tested positive for pathogen contamination
  • The status of FDA's pause in testing for non-toxigenic E. coli as an indicator organism
  • Potential direction for the 60-day aging rule
  • Conclusions drawn from the Risk for Listeriosis from the Consumption of Soft-ripened Cheese Risk Assessment
  • Preventative Controls for raw milk cheesemaking
 News from DC: IDFA 2016 Regulatory RoundUpIDFARoundup 

Bob Wills of Cedar Grove Cheese and Clock Shadow Creamery serves as co-chair of the ACS Regulatory & Academic Committee. He filed this report for ACS from the International Dairy Foods Association's (IDFA) Regulatory Roundup this summer which includes updates on: 
  • FDA Sampling
  • FSMA and Food Defense Plans
  • GMOs and litigation
  • USDA nutrition guidelines and dairy fats
  • FDA Dairy Foods Safety Update, including the Raw Milk Sampling Survey
  • Whole Genome Sequencing and Traceability
Across the Pond: Member Insights from the UK's 2016 Science of Artisan Cheese ConferenceSOAC 

Eric Rector of Monroe Cheese Studio, and President of the Maine Cheese Guild, attended the Science of Artisan Cheese conference August 23 and 24 at North Cadbury Court in Somerset, UK. This year's conference focused on topics related to farmstead cheese production, and Eric filed this report for ACS about his experience. You can read Eric's detailed recap on the Maine Cheese Guild's website.
 
Preventive Controls for Raw Milk Cheese: Do They Exist?PCGroup 

On Wednesday, July 27, leading academics, retailers, producers, and distributors met in Des Moines at the invitation of ACS to participate in a Preventive Controls Working Group. Under the Food Safety Modernization Act (FSMA), FDA considers not only Critical Control Points, but broader risk-based Preventive Control (PC) steps as part of a food safety plan. To this end, these industry stakeholders met to discuss what such PCs might look like for cheeses made with unpasteurized milk. Key findings were:
  • Whether made with pasteurized or unpasteurized milk, PC steps are the same.
  • As FDA found from its extensive pilot testing program of 1,600 raw milk cheeses, the risks are low for raw milk cheeses, and are similar to those of pasteurized milk cheeses.
  • Environmental hazards during and post-production are the most common source of contamination for all cheeses. 
  • Not all cheeses are the same. FDA and industry should look at such aspects as water activity, pH, salt content, moisture, etc. as variables in determining risk and related PCs.
  • Treat milk as a raw ingredient like any other, and put emphasis on quality, pathogen-free milk by looking at supplier controls, on-farm protocols, and testing.
  • Consider the role of testing as a control rather than merely as a verification/validation step.
  • A series of steps, or hurdles, which a cheesemaker meets during production can, in aggregate, form a food safety plan that enhances the safety of raw milk cheese.
ACS Meets with FDA to Provide Direction on Preventive Controls for Raw Milk CheeseFDAPCMeeting

A report of outcomes from ACS's July 27 Preventive Controls Working Group meeting was shared by ACS representatives at a September 16 meeting with FDA  . FDA was receptive to the approach presented by ACS. All who attended the meeting agreed that these points offer a valid direction. While FDA made it clear that they do not feel raw milk as an ingredient can ever achieve the validated safety of pasteurized milk, they were open to the idea that a set of steps, or hurdles, taken in aggregate might form a food safety plan for raw milk cheese . FDA also emphasized the importance they place on ACS's Best  Practices Guide for Cheesemakers , and to that end, the ACS Regulatory & Academic Committee is incorporating FDA's technical comments into the Guide. In addition, the chapter of the Guide focused on Preventive Controls will be revamped to better reflect the Food Safety Modernization Act. The updated edition of the Guide will be available in March, 2017.
 
In addition, the Wisconsin Center for Dairy Research shared a sample preventive control template for cheesemaking that can serve as an industry teaching tool for producers as they update their written food safety plans to meet new FSMA guidelines.
 
Letters to FDA Keep Artisan Cheese Top of MindLettersFDA
 
With non-toxigenic E. coli testing currently suspended by the FDA while it reviews its guidance on the matter, Dr. Stephen Ostroff, FDA's Deputy Commissioner for Food and Veterinary Medicine, heard from a bi-partisan group of legislators. A letter penned by Senator Peter Welch (D-VT) with the support of a dozen colleagues on the Hill was sent to Dr. Ostroff on September 15. The letter urged FDA to continue to work collaboratively with industry, and to reach a final decision on the non - toxigenic E. coli standards so that producers can move forward with clear, science-based regulations. It also raised concerns about potential changes to the 60-day aging rule. On both matters, the legislators warned against changes that have no real impact on public health but could have grave economic impacts on producers.
 
Dr. Susan Mayne, Director of FDA's Center for Food Safety and Applied Nutrition, received a letter September 20 from Dr. Martin Wiedmann of Cornell University, Dr. Catherine Donnelley of the University of Vermont, and ACS cheesemaker member Mateo Kehler of Jasper Hill Farms. The letter shares information on non-toxigenic E. coli testing results and their associated financial costs. Additionally, the letter includes the group's conclusions, consistent with those of FDA's own testing program, that non-toxigenic E. coli has no correlation to the presence of pathogens in cheese and is not meaningful as indicator organism.
 
 
Advisory Group Continues Efforts to Enhance Resources for Artisan CheesemakersACFSAG 
 
The Artisan Cheese Food Safety Advisory Group met on September 21 to focus on how identified gaps in education, information, and outreach might be filled for artisan producers. ACS will take the helm on one initial project, the creation of a website that will serve as a free, robust portal accessing important food safety resources for cheesemakers. The site, to be launched next year, will consolidate the most current and up-to-date links to resources, extension and on-line learning, research, and local/regional support. If you have food safety resources upon which you rely, and which you feel can help other producers enhance their food safety efforts, please share them with ACS Content Manager, Sarah Spira, at sspira@cheesesociety.org.
Responding to a Member's Comment from the ACS Town Hall MeetingTownHall
 
At the ACS Town Hall Meeting in Des Moines, ACS member Jessie Dowling commented: 
"I make cheese in Maine at Fuzzy Udder Creamery, and I'm also the Vice President of the Maine Cheese Guild. I just wanted to raise some concerns that some of the Maine cheesemakers have about the changes in rules on the Judging & Competition this year. One of the issues is, the new regulations that you guys decided on as a board made it so there was a number of cheesemakers that weren't able to submit their cheeses for this competition, but they were only notified about a month ago. That was very problematic. A lot of folks lost a lot of money. I understand that you wanted to level the playing field and that was an important thing in your mind, but it's also important to know that in Maine, we have more cheesemakers per capita than any other state because people can make cheese legally in our state, because the regulations don't require you to have a pasteurizer. You are required to read a temperature and thermometer gauge, and you can have safe sanitation practices without having a $20,000 piece of equipment. It's really nice to be able to be judged amongst a nation, amongst our peers, and there's a number of cheesemakers in our guild that wanted me to express their discontent with the decision."
 
We appreciate members sharing these types of concerns with us, and ACS Vice President, and Chair of the 2016 Judging & Competition, John Antonelli of Antonelli's Cheese Shop, offers this video response to clarify the addition of the Code for Federal Regulation requirement for entries.

 
 
Cheesemakers, Advance the Industry! This is Your Last Day to Participate in the 2016 State of the Artisan/Specialty Cheese Industry Survey!Survey

Today is the last day to be included in the first survey of its type that will shed light on the unique characteristics that make our industry strong and keep it growing. See why these great cheesemakers took the survey , and click here to take it yourself . Four cheesemakers who complete the survey by September 30, 2016 will be drawn at random to receive a $100 Amazon Gift Card! This brief guide will let you know what information to have on hand, and will ensure you can complete the survey in under 20 minutes.
 
Regulatory & Academic Committee Membership ChangesCommittee

The Regulatory & Academic Committee would like to thank Marianne Smukowski of Wisconsin CDR for her service as Co-Chair 2014-2016. Marianne remains a valuable member of the committee, as well as the ACS Board of Directors. Co-Chair Dennis D'Amico, PhD, of the University of Connecticut will complete one more year in this role and is joined by new Co-Chair Bob Wills, of Cedar Grove Cheese and Clock Shadow Creamery.
 
The committee also thanks these departing members for their service:
  • Jeff Bloom, Dairy Practices Council
  • Ranee May, Ranee May Consulting
The committee welcomes the following new members:
  • Jeanne Carpenter, Wisconsin Cheese Originals
  • Michael Kalish, Food Safety Guides
  • Ron Tanner, Specialty Food Association
Thank you to these volunteers who are so generous with their time and expertise. ACS values the contribution of all of our many volunteers, and expresses this through the ACS Volunteer Statement of Philosophy .
 
FDA Draft Guidance on Preventive Controls for Human Food under FSMAFSMAGuidance
 
On August 25, the FDA posted its draft guidance  for Preventive Controls for Human Food to the Federal Register. The comment period to share your thoughts on the proposed rules is open through February 21, 2017. ACS will submit a comment to express appreciation that FDA is currently working with stakeholders to draft the controls for cheese with industry input, and to stress that any proposed regulations must be science-based, offer real enhancement to public safety, and reflect the diversity of size and scale of producers in our industry.
 
FDA presented three webinars on the subject this month.  Slides and recordings of these webinars are available for download. 
 
In addition, on October 14, the FDA Foods and Veterinary Program will hold a webinar to discuss FDA's recent announcement of the FSMA draft guidance for current good manufacturing practices requirements for food for animals and the human food by-products for use as animal food.
 
What Do FDA's Proposed Sodium Reduction Guidelines Mean for Cheese?Sodium
 
FDA is seeking public comment on its proposed voluntary sodium reduction guidelines . The comment period is open through October 31, 2016. ACS will submit comments on behalf of the cheese industry to address its concerns. Salt contributes much more than just sodium to cheese, it is an important ingredient and processing agent that can enhance the safety of cheese as well as its quality, taste, and texture.
FDA will present a webinar for ACS members on October 11 from 12:00 - 1:00 pm MST to address the new proposed guidelines and how they might impact cheese and cheese production. ACS webinars are free for all ACS members thanks to the generous support of the American Cheese Education Foundation, register now! Have specific questions you'd like addressed? Send them in advance to Eliza Wetherill, ewetherill@cheesesociety.org. 
 
Shop AmazonSmile to Support Industry Education, Research, Scholarships, and MoreAmazonSmile
 
Start all your Amazon shopping with AmazonSmile and select the American Cheese Education Foundation as your designated charity. No matter what you buy, for business or personal use, you'll be helping grow and advance our industry! 
American Cheese Society | 720.328.2788 | info@cheesesociety.org  | www.cheesesociety.org
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