There’s controversy brewing in the cheese world, and it could turn into something big. This particular issue may seem a bit esoteric, but it’s part of a larger trend that may have some serious implications for small food producers in the United States.
The FDA recently cited some cheesemakers in New York State for what it claims are violations of “Good Manufacturing Practice” regulations. The violations? The practice of aging cheese on wooden boards, which the FDA says cannot be adequately sanitized. The citations are an interesting new twist on existing regulations, and are surprising in light of the fact that state regulatory boards have allowed this traditional practice in cheesemaking for years.
Monica Metz, Branch Chief for FDA’s Center for Food Safety and, perhaps worth noting, a former quality control manager for Leprino Foods (which calls itself the “world’s largest mozzarella cheese manufacturer”), is the author of the FDA’s position statement. Click here to read the full text of the FDA’s justification for its position, if you want to indulge your inner cheese geek. The upshot is that the FDA claims to be worried about wood as a breeding ground for listeria. It’s important to note that the regulation in question – part of the 2011 Food Safety Modernization Act – does not specifically prohibit the use of wood shelving, nor does it mandate the use of any particular material in shelving. It requires that “all plant equipment and utensils shall be so designed and of such material and workmanship as to be adequately cleanable, and shall be properly maintained.” 21 CFR 110.40(a). Now the FDA says that wood cannot be adequately cleaned. The cheese lover in me wants to shout, “You have NO IDEA what you’re talking about. You’ll ruin the cheese!” The lawyer in me wants to ask a thousand questions: “What does “adequately cleanable” mean? Is this a prohibition on all wood, or just certain types or ages? Does this apply to every style of cheese, or only to cheeses with a certain moisture content? Are you aware that non-porous shelving might actually encourage the growth of harmful bacteria?” You get the point – there’s a lot of room for interpretation here.
Listeria is not something to mess around with. But we actually do a pretty good job of avoiding listeriosis in this country, and the CDC’s statistics on outbreaks demonstrate that. I spent some time searching for information about documented cases of listeriosis from cheese aged on wood, and found…nothing. I’m not saying that there is zero risk. I am saying that cheesemakers seem to be successfully managing the risk.
So what’s the problem, you ask? Why not just use non-porous shelving and be done with it? First of all, aging cheese on wood is not only a common practice, it’s a critical one. The flavor of a cheese is affected by humidity, air circulation, and the development of (safe, friendly) bacteria, and wood shelving influences all of those things. If you drink wine or whisky, or if you like to use a charcoal grill, you understand how significant wood can be to the development of flavor. Second, many artisan cheesemakers in the U.S. have significant investments in aging rooms fitted with wooden shelving, and if it weren’t enough that a change in shelving material might well ruin their finished product, the cost of rebuilding all of those structures would be prohibitive for many small producers.
And while this policy shift could be devastating for some of our best domestic cheeses, it could also mean that the U.S. market would be closed to some of the best cheeses in the world. Lots of great classic European cheeses, including Comte and Beaufort, must be aged on wood for a certain period of time in order to meet AOC standards (these European regulations come from a completely different perspective than the FDA’s – the rules are in place to guarantee quality and flavor, and to protect artisans from bad imitators). We’ve already lost wonderful cheeses like raw milk Camembert and Reblochon that can’t be imported because of FDA regulations, and shops in the U.S. can’t sell Mimolette because of the dreaded cheese mite, but if the FDA takes away the great Alpines, too, it will be a sad day for turophiles.
This latest regulatory announcement highlights what, for me, is an example of one of the many flaws in our growing food system. While I’m not at all opposed to government regulation of food production, that regulation needs to address real risks and to recognize the differences presented in different types of operations. There are significantly different risk profiles for large industrial livestock producers and small farms raising grass-fed cows. Similarly, large-scale producers of shredded cheese packed in plastic may not care much about aging on wooden boards, but artisan cheesemakers may depend on it. The American Cheese Society hasn’t issued an official statement about this regulatory development yet, and neither have many cheesemakers or other trade associations, but there are rumbles out there. I find myself hoping that someone, somewhere, can better enlighten the FDA and save our cheese.
In the meantime, I’ll leave you with a very pretty picture from (yes, really) the USDA’s Flickr collection. Hmmm.
UPDATE: The American Cheese Society has issued a position statement on the safety of aging cheese on wood. Visit the ACS website for the full text.