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FDA Discussing a Change to the Regulations for Raw Milk Cheese

March 4, 2011

There are some potentially large changes afoot in the landscape of American cheese as the FDA re-examines the regulations regarding raw milk cheese production.  Most artisanal cheesemakers here in the United States swear by the quality and unique character that raw milk provides their cheese.  The inherent “good” bacteria, according to the cheesemakers, imparts a depth of flavor that is unique to the farm, the cows, the milk, the place…   Unfortunately for the cheesemakers, the FDA views these pathogens as a  potential health threat involving e.coli, salmonella and listeria.

This is not a new argument.  The benefits and risks of raw milk is an existing debate that will continue long after you and I are here.  Even though it is illegal for most states to buy or sell raw milk, cheese made from raw milk is legal for sale as long as it is aged a minimum of 60 days.  Why 60 days? The idea is that the harmful pathogens will no longer be a threat after this time frame, which makes it acceptable for human consumption.  Now the government questions if that is long enough.  With the recent seizures and closures that have been in the news as of late (I mention one of the largest here), the government is forced to take another look at this issue.  Perhaps it would be better to increase this from 60 to 120 days? The worst case scenario, of course, is to ban raw milk cheeses altogether.

I don’t think the all out ban is a reality, so let’s focus on the other scenario.  Aging beyond 60 days.  What would that mean to the cheesemaker, and what would it mean to the consumer?  Now some might say that extending this timeframe wouldn’t be a problem.  Cheese gets better as it ages, right?  The older, the better…  Now in some cases, that might be true.  A raw milk cheddar, Gouda, or Gruyère is not ready after 4 months anyway.  No impact.  Those cheeses and operations would not miss a step.  On the other hand, what about Rush Creek Reserve from Uplands Cheese?  Winnimere from Jasper Hill?  Gone… That’s right.  These 2, and many other cheese like it, would either irrevocably change or disappear.

Winnimere and Rush Creek are special cheeses.  By design, these cheeses achieve a specific flavor profile, texture and consistency at the 60 day mark.  In actuality, these cheeses are ready before that, but the cheesemakers must comply with the law.  If forced beyond 60 days, everything would change.  These young and washed-rind cheeses have an incredibly luscious and spoonable paste that points in part with a short aging time.  By extending that timeframe, the paste would break down, ripen too early, and the cheese would spoil.  It would never make it out of their cave and into the shop and markets.

Why can’t they pasteurize?  That would alleviate the problem, right?  That’s a fair question, but not feasible.  The entire character of the cheese would change.  Everything… The flavor, consistency, aroma, texture…

Imagine that you are making guacamole (I know this is a strange example, but bear with me).  You have worked on your recipe using Haas avocados.  The fat content and buttery flavor and texture using these avocados is absolutely perfect!  You add just the right amount of ingredients, and it is a huge hit! Everyone asks you to make it and bring it to parties, family functions, etc…  You are the Guac King/Queen.  Now imagine that Haas avocados are no longer available, and you can only get those large Florida avocados.  They are hard, watery, and that buttery texture that you love is replaced by something “green”, vegetable, and bland.  You make everything exactly the same, add the same amount of ingredients, but it tastes completely different.  You add more of this and that, but it isn’t the same. People don’t ask you to bring your “famous guacamole” any more.  It changed…

See what I mean?  We all have that secret ingredient that makes our recipes “work”.  For cheesemakers, that special ingredient is their milk.

What are the solutions?  Should cheesemakers increase their testing parameters and measures in order to satisfy the FDA requirements?  Increase the number and frequency of inspections?  Perhaps this will satisfy all parties in order to keep the 60 day timeframe in place, and keep raw milk cheeses in the markets.  All avenues deserve exploration because the alternative is devastating.  Raw milk cheeses are integral to the burgeoning American artisanal cheese movement.  We must do what we can to try and preserve this culture that we are creating.

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