Following the release of a surprise statement by the U.S. Food and Drug Administration (FDA) expressing respect for the artisan cheesemaking community and announcing that FDA is “pausing its testing program for non-toxigenic E. coli in cheese,” FDA Deputy Director for Foods and Veterinary Medicine, Michael Taylor, met with raw milk cheese producers on February 12 to learn more about the concerns of the American artisan cheese industry.
This Listening Session was held at FDA’s Center for Food Safety and Applied Nutrition, where Taylor was joined by Dr. Susan Mayne, Director of the Center for Food Safety and Applied Nutrition, and a number of pertinent FDA staff. In opening remarks, American Cheese Society (ACS) Executive Director, Nora Weiser, expressed that “ACS’s desire to preserve and protect traditional cheesemaking practices; ensure safe, diverse products for consumers; and work with regulators to avoid undue and unnecessary barriers to growth are shared by many allied industry groups.” Weiser went on to name over 20 industry groups that support ACS in this direction, including numerous regional cheese guilds, international cheese organizations, and other dairy industry groups.
Seven ACS members, all raw milk cheesemakers from around the country, lent their voices to advance the dialogue and understanding that are needed to ensure continued growth of the artisan cheese sector. Presenting cheesemakers focused on several key issues:
- A need for transparency in rule-making, including the process that leads to policy change, as well as discussion with stakeholders to understand real-world implications early in the rule-making process
- Collaborative engagement between regulators and cheesemakers including sharing of best practices, data, and science-based information
- Concern over the uncertain climate for raw milk cheesemakers, in particular regarding potential changes to the 60-day aging rule for raw milk cheeses
- Building trust after years of interactions that focused on enforcement of rules rather than enhancement of safety outcomes
- Impact of the Food Safety Modernization Act (FSMA) on artisan, farmstead, and specialty cheesemakers
- Recognition of the value and visibility of specialty cheese among consumers; its importance in strengthening rural economies; and its role in growing the entire dairy and cheese sector.
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Taylor emphasized that “we have to work together, and ACS is positioned for leadership in helping FDA understand what works for your product.” He went on to explain that preventive controls (PC) are about industry knowing what is needed and assessing what history has shown is successful. In response to ongoing concerns over changes to the 60-day aging rule, Taylor assured the group that any change to the rule will not be a surprise to stakeholders, and that this open dialogue is a prelude to any future rule-making or comment process. He stated that we must “look at raw milk cheese in [the] context of the PC framework.”
Mayne agreed, stressing the importance of science. She pledged that FDA will seek outside consult from academia and science in approaching artisan cheese safety. She sees moving forward in three steps: dialogue, which was furthered at the Listening Session; data, which must be shared openly; and scientific engagement, with technical discussions informed by what cheesemakers are doing.
Spurred by Taylor and Mayne, those present agreed that the next step is to pull together a group of relevant stakeholders, technical experts, and appropriate FDA staff to convene and discuss what preventive controls might look like for raw milk cheesemaking, and how testing can play its appropriate role in verifying controls. Jeremy Stephenson, cheesemaker at Spring Brook Farm in Vermont and member of the ACS Board of Directors, captured the theme of the meeting when he stated, “Concrete, measurable steps need to be taken on the part of FDA at every level to give the cheesemaking community confidence that regulators are operating in the spirit of FSMA. We need and value good regulation both to protect our customers as well as our collective industry.”
