Cheesemakers, especially artisan producers, have suggested that the FDA is applying safety criteria to raw milk cheese production that limits producers without benefitting public health. Raw milk cheeses have been linked to recalls and food poisoning outbreaks in the past several years.
Raw milk cheese produced by Family Cow in Pennsylvania caused Campylobacter illnesses in 2013, and there have been dozens of recalls of raw milk cheeses over the years. Raw milk cheese has been recalled for Campylobacter, Salmonella, E. coli, and Listeria monocytogenes contamination in all of the four years Food Poisoning Bulletin has been published.
Some studies have concluded that aged raw milk cheeses are safe to eat, since the aging process changes the composition of the cheese. Aging reduces the pH, reduces water activity, and increases the salt content. All of these factors can help prevent bacterial growth in the cheese.
The FDA’s role is to be sure that science-based, prevention-oriented standards and safety criteria are in place when it comes to raw milk foods. Some producers are questioning the FDA’s stance on testing raw milk cheese for the presence of non-toxigenic E. coli bacteria. But this test indicates fecal contamination. And bacteria above a certain level could indicate unsanitary conditions in a processing plant.
The FDA is going to re-evaluate its criteria “in the context of the overarching framework for the oversight of food production provided by the 2011 FDA Food Safety Modernization Act (FSMA). The Preventive Controls for Human Food rule mandated by that Act requires that producers must identify hazards in their product and operations and have controls in place to prevent or minimize those hazards. The FDA will study the role non-toxigenic (non disease-causing) E. coli should have in identifying insanitary conditions.
The compliance guide issued by the FDA in 2010 reduced the amount of non-toxigenic E. coli that can be in a product to 10 most probable number (MPN) per gram, from 100 MPN per gram in two of five samples, a 90% reduction. This standard does limit production of raw milk cheeses.
The FDA is also planning on updating the 2010 Compliance Policy Guide that outlines safety criteria. And the agency will continue to inspect cheese-making facilities and test for pathogenic in both domestic and imported cheese, but it will pause the testing program for non-toxigenic E. coli in cheese.