Bumper response to FDA request for comments on raw milk cheese
When announcing the notice in the Federal Register in August, the agency said it was taking action due to data on potential health risks associated with cheese made from unpasteurized milk.
It added it wanted to learn more about the standards and practices by producers, including the artisanal cheese manufacturing community.
A 2012 review of outbreaks of foodborne illness between 1993 and 2006 attributed to dairy products determined more than 50% involved cheese, with the remaining being attributable to fluid milk.
Pathogens associated with these outbreaks included Listeria monocytogenes, E. coli O157, Salmonella and others.
Comments came from agencies including the International Dairy Foods Association (IDFA), National Milk Producers Federation, Western A. Price Foundation (WAPF), the Specialist Cheesemakers Association, UK and the European Commission.
Burden on producers
IDFA said industry recognizes the seriousness of Listeria.
“We believe it is important that any future changes to the current regulatory provisions requiring a 60‐day minimum aging period for cheese made from unpasteurized milk, should consider a performance objective or standard for L. monocytogenes that is based on sound scientific evidence and can accommodate both traditional cheese making practices and new technologies.”
IDFA also submitted comments to FDA’s Food Advisory Committee (FAC), meeting this week to review and make recommendations regarding policies and guidance related to Listeria monocytogenes (“Lm”) in food.
WAPF urged the FDA not to place unnecessary burdens on producers of raw milk cheeses.
Sally Fallon Morell, president of WAPF and a cheesemaker, said the FDA is starting with an incorrect assumption that more regulations would benefit consumers of raw milk cheeses.
“But the government’s own data shows that there have been very, very few outbreaks from raw milk cheeses produced under the current regulations.
“Imposing additional testing or lengthening the aging period would simply drive many artisan producers out of business and reduce consumer choices. Cheese in general is a relatively low-risk product, and the majority of the foodborne illness outbreaks that do occur are caused by post-process contamination. ”
Most outbreaks attributed to raw milk cheeses have come from fresh (unaged) cheeses, which are illegal to sell in the US. New regulatory requirements would be futile in addressing risks from fresh cheeses, said WAPF.
Need more than end product testing
NMPF said it would support FDA in developing a performance objective or standard as a replacement for the 60-day aging requirement for cheeses manufactured from unpasteurized milk.
However, it does not support finished product testing as a control measure citing reasons such as false-negative rates.
This message was echoed by the European Commission who said safety for consumers cannot be guaranteed by isolated measures or controls only at the end of the production chain.
“The manufacture of dairy products made from raw milk requires an integrated control approach to the entire production chain, i.e. from the milk-producing animal (animal health, the food control) until the delivery of the milk to the consumer.
“The procedures based on HACCP principles identify any specific risks associated with raw milk production in order to identify effective preventive control measures which are proportionate and targeted.
“The ripening period is considered as one of the elements allowing the provision of a reasonable protection for the consumer vis-à-vis some pathogens (i.e. Listeria and Brucella). However, the duration of ripening is not a sufficient element by itself to provide all the guarantees of product safety.”
