American Cheese Society Response to FDA

Yesterday we reported on the surprising decision by the FDA to crack down on cheesemakers who use wooden board to age their cheeses. After posting what we had learned about the sudden change in policy, we kept our eyes peeled to see what sort of response would come from the cheesemaking community. The response came in the afternoon from the American Cheese Society. The ACS is a non-profit organization with a mission to “provide the cheese community with educational resources and networking opportunities, while encouraging the highest standards of cheesemaking focused on safety and sustainability.” Here is their position:

For centuries, cheesemakers have been creating delicious, nutritious, unique cheeses aged on wood. Today’s cheesemakers—large and small, domestic and international—continue to use this material for production due to its inherent safety, unique contribution to the aging and flavor-development process, and track record of safety as part of overall plant hygiene and good manufacturing practices. No foodborne illness outbreak has been found to be caused by the use of wood as an aging surface.

The American Cheese Society (ACS) strongly encourages FDA to revise its interpretation of the Code of Federal Regulation (21 CFR 110.40(a)) to continue to permit properly maintained, cleaned, and sanitized wood as an aging surface in cheesemaking as has been, and is currently, enforced by state and federal regulators and inspectors.

It is ACS’s position that:

• Safety is paramount in cheesemaking.
• Cheeses aged on wood have a long track record of safety, and have long been produced meeting FDA standards.
• Woodcan be safely used for cheese aging when construction is sound and in good condition, and all surfaces are properly cleaned and maintained using sanitation steps that assure the destruction of pathogens, including but not limited to:
  • All surfaces are free of defects;
  • Any wood preservatives used are safe and acceptable for direct food contact;
  • Inspection and cleaning proceduresare followed that specify:
    • Frequency of inspection and testing
    • Frequency of cleaning and sanitizing
    • Methods used that adequately clean boards which might include:
      • Kiln-drying
      • Air-drying
      • Heat-treating
      • Sanitizing with acceptable products
      • Inoculation to create and maintain positive biofilm
      • Raising the core temperature of the wood above pasteurization temperatures
    • Ongoing monitoring and verification of the effectiveness of all procedures per the Hazard Analysis and Risk-based Preventive Controls (HARPC) provision of the Food Safety Modernization Act (FSMA)
    • Corrective actions to address any issues
    • Discarding of wood that is deteriorated and/or in poor repair

Furthermore, ACS believes:

• Traditional methods of cheesemaking can and do meet food safety standards.
• U.S. consumers should have access to a wide variety of domestic and imported cheeses, including those safely aged on wood.
• State and federal regulators and inspectors must work collaboratively with cheesemakers to understand how traditional methods and materials can comply with current food safety standards.
• Many of the finest and most renowned cheeses from around the world are at risk of disappearing from the U.S. market if regulatory and enforcement changes under FSMA eliminate traditional materials and methods.
• FDA should provide timely notification, hold proper listening sessions and comment periods, review all available scientific data, and include consideration of industry stakeholders before modifying long-standing interpretation or implementation of its regulations which impact American businesses.

We’re sure this isn’t the end of the story. Stay tuned for more news!

Amy Scheuerman

Amy Scheuerman—culture's former web director—spent eight years in North Carolina where she developed a love of barbecue and biscuits before moving up north to get a degree in nutrition. She now works at the Isabella Stewart Gardner Museum.