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

FDA
FDA Begins Blue Cheese Sampling Assignment
   
The Food and Drug Administration has issued a field assignment requesting that 200 blue cheese samples be collected and tested for Listeria monocytogenes. FDA has already started testing and is planning to collect approximately 200 samples of packaged product from retail stores, as well as from production and storage facilities. This assignment includes both domestically produced and imported blue cheeses, and both raw and pasteurized products. 

FDA has engaged in targeted sampling in recent years of unpasteurized cheese, artisan cheese, and Hispanic styles, which have thus far resulted in finding few problems with contamination. We encourage members to review Chapter 10 of the ACS Best Practices Guide for Cheesemakers for further information on inspections and product sampling. The FDA website also provides information on Sampling to Protect the Food Supply and Microbiological Surveillance Sampling: Testing to Support Prevention Under the FDA Food Safety Modernization Act .
 
Blue Cheese Assignment: Sample Size
  • Less than one-pound retail units: 10 subsamples with each subsample consisting of enough units to make up a one-pound subsample;
  • One pound to five-pound retail units: 10 subsamples consisting of one intact unit each;
  • Wheels, loaves, and bricks weighing greater than five pounds: 2 subsamples consisting of one intact unit each.
For more information on sample sizes for both Domestic and Imported cheeses, see the FDA Compliance Policy Guidance Manual 7303.037.   
 
If you are a producer, it is good practice to hold any lot of cheese that has been collected until results are released, and to take your own sample of the cheese to test for the same pathogens for which FDA is looking. You should tell the investigator that you intend to voluntarily hold the product pending hearing the results from FDA. If you are voluntarily holding your product pending analysis, or if the investigator collected environmental samples, FDA will provide the results of analysis when they are available. If you are holding product pending analysis, be sure to check on the results if they are not provided in a timely manner.

Please note that ACS has launched a partnership with Cherney Microbiological Services, Ltd. to offer discounted testing services to ACS members; see this issue of Traditional Cheese Advocate for more details about this program. 

If you are a retailer, please visit the online Retailers Toolkit within the ACS Safe Cheesemaking Hub for additional resources in the coming week. 
 
Compensation for Samples Taken:
  • The investigator should be communicating with you as to whether you wish to provide the samples to the government at no charge or seek payment, and the amount the samples will cost.
  • Payment may be made by the investigator at the time of collection using a cash advance of government funds that the investigator acquires prior to collecting samples. Another process is that you may submit a request for payment to FDA for the samples collected.
  • FDA will pay the fair, wholesale cost for products sampled when reimbursement is sought.
  • The investigator will provide you with the address of their district office where billing for the samples will be processed. You will submit your invoice and a copy of the receipt the investigator provides to seek reimbursement for samples collected. You may also wish to prepare an invoice for the products sampled by the investigator and provide it to the investigator at the time s/he provides you with a receipt for samples.
If you have any questions about this sampling assignment, please contact the ACS office at 720-328-2788 or [email protected]. We will share additional details if and when they are made available to us.
 
  FarmBill
Peter Welch (D-VT) Works to Highlight Artisan Cheese in Farm Bill
 

At the request of Senator Peter Welch's office, ACS has shared data on the artisan cheese industry, and information on the concerns of industry stakeholders. Based on these ongoing issues of concern, Welch's office has drafted proposed Farm Bill language to urge action on outstanding issues that stymie producers' ability to grow their businesses due to uncertainty on the regulatory front.
 
ACS stressed that l egal artisan raw milk cheese production has been an economic driver supporting struggling dairy farms in rural communities across the United States. These safe, award-winning cheeses are a value-added product that can play a critical role in keeping American dairy farmers in business. The Farm Bill proposal focuses on three areas of importance to artisan producers, echoing ACS's ongoing work with FDA:
(1)  alternative safety methods which FDA might support for the production of raw milk cheeses, while it continues to implement the 60-day aging rule for unpasteurized milk cheeses;
(2)  the feasibility of permanent implementation of the current policy pausing the use of non-toxigenic Escherichia coli testing as an indicator of adulteration in raw milk cheeses;
(3)  identifying methods and tools to train inspectors on proper inspection and use of wooden boards in cheesemaking.
 
Food Safety News  reports on FDA research on the prevalence of Salmonella in dried spices:  FDA Updates Spice Risk Profile; 7,200 Samples Analyzed . 
 
Industry members, especially those using dried spices in their production, should read the research study, published in the Journal of Food Protection:
 
SmallBizFSMA
FDA Defines Small Business as Under 500 FTE Employees
FDA has issued a Draft Guidance better defining and explaining its use of the term "small business". Essentially, a "small business" means a business (including any subsidiaries or affiliates) employing fewer than 500 full-time equivalent employees (21 CFR 117.3 and 507.3). The limit of 500 employees includes all employees of the business and is not limited to the employees at a particular facility (80 FR 55908 at 55962 and 80 FR 56170 at 56200).
 
A "full-time equivalent employee" (FTE) is a term used to represent the number of employees of a business entity for the purpose of determining whether the business qualifies as a small business. The number of FTEs is determined by dividing the total number of hours of salary or wages paid directly to employees of the business entity and of all of its affiliates and subsidiaries by the number of hours of work in 1 year, 2,080 hours (i.e., 40 hours × 52 weeks). If the result is not a whole number, you should round down to the next lowest whole number. (21 CFR 117.3 and 507.3).  

Review the full Guidance to learn more about why these definitions matter, and how they impact a business's compliance requirements and deadlines.

Standards
Standards of Identity Under Review by FDA
 
FDA has released its  2018 Strategic Policy Roadmap , which identifies priority
areas that will be the focus of additional policy activity in 2018. Read more about how the Roadmap addresses Standards of Identity in the National Law Review's, FDA to 'Modernize Certain Standards of Identity' as Part of Strategic Policy Roadmap .
 
You can read IDFA's and NMPF's  comments urging FDA to reform areas of dairy product manufacturing including:
  • Modernize outdated standards of identity for dairy products
  • Revise overly burdensome FSMA regulations
  • Extend the compliance date for revised Nutrition Facts labeling (currently January 1, 2020 for producers with over $10M in annual sales; January 1, 2021 for producers under $10M.)
CherneyBenefit
New ACS Member Benefit: Discounted Testing via Cherney Microbiological Services, Ltd.
 
Monitoring and regular testing, whether of your milk supply, production environment, or finished product, are important parts of any good food safety plan. The ACS Best Practices Guide for Cheesemakers outlines a baseline of what and how often you should be testing based on the types of products you make and the size and location of your facility.
 
Small producers have told ACS that they struggle with the high cost of testing, and they lack the skills, tools, and know-how to regularly and properly collect and submit samples. After much research on pricing, testing services, and member needs, ACS is pleased to announce its new partnership with Cherney Microbiological Services, Ltd. This partnership provides discount testing services to ACS members; simply-designed, all-inclusive testing packages to suit your size and needs; and the support and training of a family-owned lab that understands the challenges of artisan producers.
 
Below are some highlights of the program. We will share more information in the coming months.
  • ACS members will save 10% on a wide range of testing services offered by Cherney. As more members participate, the discount may increase, potentially as high as 30% with broad participation.
  • If you are already a Cherney customer, let them know you are an ACS member -- they'll extend the discount to existing customers!
  • Cherney has customized all-inclusive packages for Listeria genus environmental testing to make it easy for ACS members to get started. These include all packaging materials, collection supplies, training, and shipping costs, scaled to fit your testing frequency needs. As an example, a producer who collects and ships 10 (ten) L. genus environmental samples per month would spend around $3,900 annually for its testing program. This expenditure is all-inclusive, and billed monthly, allowing for ease of planning and budgeting to accommodate cash flow and business needs. If a member experiences positive results during sampling, additional work can be completed at the request of the member. Cherney also works diligently in providing education behind results; therefore, additional testing services (investigation work) may be proposed to quickly determine root cause and severity of the issue.
  • Should a problem ever be detected, Cherney provides a full range of additional services to help members address and implement appropriate next steps and corrective measures.
If you'll be attending the International Cheese Technology Expo (ICTE) in Milwaukee from April 18-19, stop by to see Cherney at booth 1725 to learn more, or contact Cherney at 920-406-8300 . Their team of account managers are skilled and knowledgeable in their offerings and are excited to work with ACS members.

This spring, U.S. cheesemakers will receive ACS's 2018 State of the U.S. Artisan/Specialty Cheese Industry Survey. This survey is conducted every two years, with resulting data providing critical information about the shape, scope, economic impact, practices, trends, and challenges of the industry. The survey also provides benchmarking information and key data to inform your own business, the media, and ACS's engagement with regulators and elected officials.
 
The 2018 survey will be conducted in conjunction with a team from the University of Missouri's Division of Applied Social Sciences, a unit in the University's College of Agriculture, Food, and Natural Resources. The survey is funded by the nonprofit American Cheese Education Foundation.
 
Check out our Report of Key Findings from the inaugural 2016 State of the U.S. Artisan/Specialty Cheese Industry Survey for a snapshot of the small businesses that make up our community of American producers. It is only through cheesemakers' participation in the 2018 survey that we can continue to fill the void of data available about the industry, and grow stronger as a community. Please set aside some time to participate when you receive a link to the survey in the coming months!
 
Would you like to support this important research? Consider making a gift to the ACE Foundation to help advance our knowledge of the artisan and specialty cheese industry.
 
This January, the Journal of Food Protection published a study based on data from a 2013 study related to a 2013 outbreak of E. Coli linked to raw milk Gouda produced in Canada. Food Safety News reported on the latest study last month:  Scientists Urge Regulators to Revisit 60-Day Rule for Raw Gouda . Cheese Market News also reported on it, and included comments from ACS Executive Director Nora Weiser and John Allan, VP of Regulatory Affairs and International Standards at IDFA:
Study examines E. coli outbreak, casts doubt on raw milk cheese 60-day aging policies .

Lexicon ACS Cheese and Dairy Product Lexicon and Glossary
  
ACS has released the  ACS Cheese and Dairy Product Lexicon and Glossary (ACS Lexicon & Glossary). This lexicon was developed with the understanding that assessing, grading, judging, evaluating, marketing, and socializing with cheese (and the contexts in which these activities happen) require different types of terminology -- and a resource was needed to help facilitate conversations across the supply chain of cheese. The goal for the ACS Lexicon & Glossary is to allow industry members to communicate more readily, clearly, and consistently about cheese and dairy products.
 
The ACS Lexicon & Glossary includes vetted definitions and explanations of more than 120 different terms that are critical to the work of cheese professionals. Terms are listed in alphabetical order for ease of use, and information about each term includes: the definition, the reference point, styles where it occurs, attribute/defect, possible causes, synonyms, and related terms. Download your copy today!
 
This summer in Pittsburgh, ACS will launch its newest certification exam, the
ACS T.A.S.T.E. Test™ . The exam will take place on July 25, immediately prior to the 35th Annual ACS Conference . The T.A.S.T.E. Test™ (Technical, Aesthetic, Sensory, Tasting Evaluation) is the second certification exam offered by ACS. While the ACS CCP ® Exam, launched in 2012, evaluates candidates' understanding of core competencies common across the majority of cheese industry jobs, the wholly separate ACS T.A.S.T.E. Test™ is a hands-on exam that evaluates cheese professionals' knowledge and skills in the assessment and identification of cheese. Individuals who pass will earn the credential of ACS Certified Cheese Sensory Evaluator™ or ACS CCSE™.
 
The ACS CCSE™ credential is valuable for anyone whose work in the cheese industry relies on their expertise in assessing and evaluating cheese, from cheesemakers and buyers to trainers and chefs. Applications for this exam close on April 30; space is limited, and we encourage interested candidates to apply soon  to ensure their spot.
 
SafeCheesemakingPRNewsSafe Cheesemaking Hub Named PR News 2018 Best Nonprofit Website

ACS's Safe Cheesemaking Hub was recently honored with a 2018 PR News Nonprofit Award, winning the Website category. The PR News Nonprofit celebrate nonprofit campaigns and communicators making a positive, lasting impact on the world. The  winners  are judged on the impact of the communications campaigns they've led in the last 18 months, and on the positive influence they've had on society at large. ACS's collaborative approach to incorporating broad industry resources, creative use of a software platform developed for libraries, and the industry's strong usage of the site since it launched in February 2017, made the site stand out.
 
This is the second award for The Safe Cheesemaking Hub; in 2017, the site was honored with a Silver "Power of A" Award from the American Society of Association Executives for "The Power to Prepare for the Future."
 
Kudos to Sarah Spira, ACS Content Manager, for her work in developing and managing this site, which serves as a valuable "one-stop shop" for resources, research, training, and tools to enhance industry food safety practices.
 
FSMA
September FSMA Deadlines are Coming: Are You Ready?

The Artisan Cheese Food Safety Advisory Team, a collaboration between the Innovation Center for U.S. Dairy, the American Cheese Society, University of Connecticut, Cornell University, the Center for Dairy Research, North Carolina State University, Clock Shadow Creamery, Dairy Connection Inc., The Ice Cream Club, Jasper Hill Farm, Marketing Concepts Inc., SYSCO Food Service, and Whole Foods Market, was formed in May of 2016, as an outcome of the Artisan Food Safety Forum held at the ACS Conference in Providence, RI in August 2015.
 
The group identified three objectives:
  1. Identify and consolidate existing resources into a "one stop shop" website.
  2. Create an online food safety training class.
  3. Create direct, hands-on resources to support small processors utilizing University, extension, and industry resources. 
The first objective was achieved in the form of ACS's award-winning  Safe Cheesemaking Hub website, launched in early 2017.
 
The second objective was achieved with North Carolina State University's development of the  Online Food Safety Basics for Artisan Cheesemakers in June 2017. This course is free for ACS Members with code ACS-FREE. 
 
The third objective, hands-on training with food safety plan coaching and support, is intended to build on current dairy education programs to support and provide training on a national level. The primary goal of the training is to help attendees complete their own food safety plan with support from the class and instructors. This effort started with financial support from the Innovation Center for U.S. Dairy and was supplemented by a three-year, $400,000 USDA NIFA grant, to be coordinated by Cornell University.
 
ACS is working with Cornell to offer a condensed, one-day version of the course in conjunction with the 2018 ACS Conference this summer in Pittsburgh, PA. This training will be offered to ACS members at a deeply discounted rate, and will include hands-on, small group coaching to ensure producers leave with their food safety plan in hand. Look for more information on the ACS website as the 2018 Conference schedule is finalized.

American Cheese Society | 720.328.2788 | [email protected]  | www.cheesesociety.org
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