Dairy Sheep Symposium - the Department of Animal Sciences ...

Dairy Sheep Symposium - the Department of Animal Sciences ... Dairy Sheep Symposium - the Department of Animal Sciences ...

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eview of the literature relating to the potential for growth of pathogens in hard cheeses that are aged for at least 60 days shows that such growth is not likely to occur because of the combined effect of decreased pH, decreased water activity, and possibly other factors inherent to these cheeses” (USFDA, 1999). However, in the recently released HHS and USDA Listeria risk assessment and Listeria action plan, USDA and FDA advise pregnant women, older adults and people with weakened immune systems that “cheeses that may be eaten include hard cheeses; semi-soft cheeses such as Mozzarella; pasteurized processed cheeses such as slices and spreads; cream cheese; and cottage cheese.” However, persons residing in these risk groups are advised “do not drink raw (unpasteurized) milk or eat foods that contain unpasteurized milk.” (USDA, 2001). Following are potential regulations that may be proposed: Full pasteurization of all cheese milk This was the first fear that most cheesemakers had when the question of safety of raw milk cheeses was first raised in 1995-96. However, with the statement made in 1999 concerning the safety of hard cheeses (listed above, USFDA, 2001) and the dialogue going between the FDA and American Cheese Society, indications are that FDA may be willing to accept raw milk hard cheeses that are aged for 60 days. FDA will most likely require some additional regulations concerning the potential presence of pathogens in raw milk used for cheesemaking. Soft ripened and semisoft ripened cheeses will be required to be manufactured from pasteurized milk. Raw milk hard cheeses with HACCP at the farm (Amer. Cheese Soc. Plan) This is the current recommendation for future production of raw milk hard cheeses being proposed by the Cheese of Choice Coalition. Critical control points in the HACCP program at the farm would include antibiotic testing, temperature requirements on cooling and holding of the raw milk and routine testing of incoming lots of raw milk for pathogens to ensure safety of raw milk cheeses. The difficult aspect of this proposal involves the cost and time of analysis for pathogens in the raw milk. What pathogens do you test for and do all lots of milk have to be tested for pathogens? Assuming that you get some reduction of pathogens during the 60 day aging period, will FDA allow a minimum level of pathogens (for instance,

testing on raw milk at the farm. This may give us some measure of the safety potential for E. coli but other pathogens, e.g., Listeria do not necessarily correlate with coliform counts (C.W. Donnelly, personal communication). Other microbiological hurdles would have to be in place. Heat treatment of all milk for aged cheeses Johnson et al. (1990) proposed a heat treatment of milk for cheesemaking of 148°F for 16 sec or equivalent to reduce the potential for pathogens in milk used for cheese. Many of our commercial plants are producing “raw milk cheeses” using heat treatments of 154-158°F for 15 sec on their milk for cheesemaking. This heat treatment eliminates most of the potential pathogens and yet does not eliminate all the secondary microflora in the milk that contribute to the full flavor of raw milk cheeses. Over 95% of raw milk aged cheeses in Wisconsin are produced from heat-treated milk. There is some concern that the current labeling of raw milk cheeses does not differentiate between heat-treated milk and true raw milk cheeses. This may be addressed in future labeling requirements for true raw milk cheeses, similar to unpasteurized fruit juices (Anonymous, 1998). Warning label on all raw milk cheeses In 1996, severe outbreaks of E. coli 0157:H7 in fruit juices and apple cider prompted FDA to establish requirements for warning labels on unpasteurized juices. This label is required on all juices not produced under a system validated to reduce E. coli 0157:H7 by 5 logs (Anonymous, 1998). The warning label must state: “WARNING: this product has not been pasteurized and, therefore, may contain harmful bacteria that can cause serious illness in children, the elderly, and persons with weakened immune systems”. This warning label on unpasteurized juices has established a president that FDA could follow on raw milk cheeses. The cider makers have found that most of the supermarkets and chains now handle only pasteurized juices. Smaller cider makers selling at farmers markets, etc, have found that their customers have adjusted to the warning labels and markets have stabilized. Within the next couple years, FDA will require all cider makers selling product wholesale to pasteurize their cider. Small processors will be allowed to sell unpasteurized juices, with warning labels, to retail customers only. Some version of this labeling requirement may be proposed for raw milk cheeses by FDA. The question will be what cheeses FDA may allow to be produced from raw milk. Since the Cheese of Choice Coalition is concentrating on preserving raw milk hard cheeses, I would anticipate that FDA may propose that soft ripened and semisoft ripened cheeses would be required to be produced from pasteurized milk. If somehow, FDA would allow raw milk to be used for soft or semisoft cheeses, there would definitely be a requirement for warning labels to protect the consumer. Conclusion FDA is responsible for overseeing the safety of our food supply. They are aware that the 60 day aging period does not effectively eliminate pathogens from all varieties of cheese. There have been numerous recalls of soft and semisoft cheeses in the past few years due to presence of pathogens, e.g., Listeria and E. coli 0157:H7. In the next 2 years, FDA will be revising the regulations covering the potential production of raw milk cheeses. What the final regulation will look like is hard to guess at this point. However, with the fruitful discussions that are ongoing between the Cheese of Choice Coalition and FDA, there is hope that there may be some allowance for raw milk hard cheeses. In the end, FDA will still want to ensure the safety of all cheeses consumed by U.S. consumers.

testing on raw milk at <strong>the</strong> farm. This may give us some measure <strong>of</strong> <strong>the</strong> safety potential for E.<br />

coli but o<strong>the</strong>r pathogens, e.g., Listeria do not necessarily correlate with coliform counts (C.W.<br />

Donnelly, personal communication). O<strong>the</strong>r microbiological hurdles would have to be in place.<br />

Heat treatment <strong>of</strong> all milk for aged cheeses<br />

Johnson et al. (1990) proposed a heat treatment <strong>of</strong> milk for cheesemaking <strong>of</strong> 148°F for 16 sec<br />

or equivalent to reduce <strong>the</strong> potential for pathogens in milk used for cheese. Many <strong>of</strong> our commercial<br />

plants are producing “raw milk cheeses” using heat treatments <strong>of</strong> 154-158°F for 15 sec<br />

on <strong>the</strong>ir milk for cheesemaking. This heat treatment eliminates most <strong>of</strong> <strong>the</strong> potential pathogens<br />

and yet does not eliminate all <strong>the</strong> secondary micr<strong>of</strong>lora in <strong>the</strong> milk that contribute to <strong>the</strong> full<br />

flavor <strong>of</strong> raw milk cheeses. Over 95% <strong>of</strong> raw milk aged cheeses in Wisconsin are produced from<br />

heat-treated milk. There is some concern that <strong>the</strong> current labeling <strong>of</strong> raw milk cheeses does not<br />

differentiate between heat-treated milk and true raw milk cheeses. This may be addressed in<br />

future labeling requirements for true raw milk cheeses, similar to unpasteurized fruit juices<br />

(Anonymous, 1998).<br />

Warning label on all raw milk cheeses<br />

In 1996, severe outbreaks <strong>of</strong> E. coli 0157:H7 in fruit juices and apple cider prompted FDA to<br />

establish requirements for warning labels on unpasteurized juices. This label is required on all<br />

juices not produced under a system validated to reduce E. coli 0157:H7 by 5 logs (Anonymous,<br />

1998). The warning label must state: “WARNING: this product has not been pasteurized and,<br />

<strong>the</strong>refore, may contain harmful bacteria that can cause serious illness in children, <strong>the</strong> elderly, and<br />

persons with weakened immune systems”. This warning label on unpasteurized juices has<br />

established a president that FDA could follow on raw milk cheeses.<br />

The cider makers have found that most <strong>of</strong> <strong>the</strong> supermarkets and chains now handle only<br />

pasteurized juices. Smaller cider makers selling at farmers markets, etc, have found that <strong>the</strong>ir<br />

customers have adjusted to <strong>the</strong> warning labels and markets have stabilized. Within <strong>the</strong> next<br />

couple years, FDA will require all cider makers selling product wholesale to pasteurize <strong>the</strong>ir<br />

cider. Small processors will be allowed to sell unpasteurized juices, with warning labels, to retail<br />

customers only.<br />

Some version <strong>of</strong> this labeling requirement may be proposed for raw milk cheeses by FDA.<br />

The question will be what cheeses FDA may allow to be produced from raw milk. Since <strong>the</strong><br />

Cheese <strong>of</strong> Choice Coalition is concentrating on preserving raw milk hard cheeses, I would<br />

anticipate that FDA may propose that s<strong>of</strong>t ripened and semis<strong>of</strong>t ripened cheeses would be required<br />

to be produced from pasteurized milk. If somehow, FDA would allow raw milk to be<br />

used for s<strong>of</strong>t or semis<strong>of</strong>t cheeses, <strong>the</strong>re would definitely be a requirement for warning labels to<br />

protect <strong>the</strong> consumer.<br />

Conclusion<br />

FDA is responsible for overseeing <strong>the</strong> safety <strong>of</strong> our food supply. They are aware that <strong>the</strong> 60<br />

day aging period does not effectively eliminate pathogens from all varieties <strong>of</strong> cheese. There<br />

have been numerous recalls <strong>of</strong> s<strong>of</strong>t and semis<strong>of</strong>t cheeses in <strong>the</strong> past few years due to presence <strong>of</strong><br />

pathogens, e.g., Listeria and E. coli 0157:H7. In <strong>the</strong> next 2 years, FDA will be revising <strong>the</strong><br />

regulations covering <strong>the</strong> potential production <strong>of</strong> raw milk cheeses. What <strong>the</strong> final regulation will<br />

look like is hard to guess at this point. However, with <strong>the</strong> fruitful discussions that are ongoing<br />

between <strong>the</strong> Cheese <strong>of</strong> Choice Coalition and FDA, <strong>the</strong>re is hope that <strong>the</strong>re may be some allowance<br />

for raw milk hard cheeses. In <strong>the</strong> end, FDA will still want to ensure <strong>the</strong> safety <strong>of</strong> all cheeses<br />

consumed by U.S. consumers.

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