Q & A on Cheese Safety

A reader asks: Why don’t cheesemakers do their own testing for Listeria, E. coli and Salmonella so they won't get caught flat-footed by FDA inspectors?

I asked cheesemaker Andy Hatch of Uplands Cheese Company to reply. Andy makes Pleasant Ridge Reserve, a three-time winner of the American Cheese Society’s Best of Show.

“At Uplands we test every single batch of cheese for all of the major pathogens (Listeria, Salmonella, E. coli and Staph aureus), and I think it's reasonable to expect that this should be the case for all cheesemakers, as just one of the components of a food safety plan.”

Alongside testing the finished product, we also run pathogen tests on raw materials (every load of milk) and the production and ripening facilities (with environmental swab samples).

Taken together, testing the raw materials, facilities and the finished product is a time-consuming and expensive practice.  Each year we spend between 1-2% of our sales on testing costs, which doesn't account for the labor, materials or shipping costs associated with those tests.  1-2% of revenue sounds like a small number until you recognize the slim profit margins that most cheese producers work with. It's a major cost.

Cost is probably the major reason more cheesemakers don't do more testing (the cost of testing, the cost of the time it takes and the cost of sacrificed product). We're lucky in Wisconsin to be surrounded by dairy labs. One of the labs we work with sends a van to our farm every day to pick up that day's fresh milk sample, at no extra charge. Our other samples are sent to local labs via UPS Ground. This certainly isn't the case in most (any?) other parts of the country.

Only very large cheesemaking companies have their own pathogen labs, which require expensive equipment.  And still, many large companies who do their own technical product testing (i.e. fat content, pH, etc.) choose to outsource the pathogen work, simply because they don't want to deal with it in their sanitary environments.

Incidentally, and only a little outside the point, is the fact that it takes several days to run a Listeria test and analyze the results. This is one important food safety advantage that raw milk cheese has over fluid raw milk, which should be consumed within a day or two, and thus can't be held while waiting for those test results.  This difference, along with the inherent protections built into the cheesemaking process (i.e. water removal, pH and salt) mean that raw milk cheese should be treated entirely differently than fluid raw milk. Unfortunately, too many sloppy journalists simply refer to "raw milk dairy products" as a single, homogenous group.

Last point here is that there isn't an agreed upon protocol for the testing I described above (i.e. what percentage of pieces or volume in a batch need to be tested in order for the test to be statistically meaningful?). This is something our industry should work on, and perhaps it's something we should work on together with the FDA. Many people are hoping that the FDA will change its raw milk cheese regulation from an age requirement to a testing-based requirement. In that case, the industry should expect some guidance on testing.  But in any case, and despite the high costs, it's the responsibility of all cheesemakers to test their own raw materials, facilities and finished products.

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