No burdensome regulations on raw milk cheese

November 2, 2015

Dr. Stephen Ostroff, M.D., FDA Commissioner
Division of Dockets Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852

Docket # FDA-2015-N-2596

Dear Dr. Ostroff,

On behalf of the 56,000 member-owners of PCC Natural Markets in Seattle and four adjacent cities, we’re writing to support the continued availability of raw-milk cheeses in American markets. We urge FDA not to impose burdensome regulations on artisan raw-milk cheesemakers.

PCC is the largest consumer-owned and operated grocery retailer in the United States, with 10 retail stores in the greater Seattle area and more than $230 million in annual sales.

We’ve cultivated strong relationships with raw-milk cheese producers — many of them local, farmstead cheesemakers — and feel a responsibility to support their livelihoods. We also accept responsibility to provide the best cheeses available to our shoppers, many of whom believe raw-milk cheeses are exceptional both in taste and health benefits.

Health and cleanliness considerations

PCC Natural Markets opted several years ago not to sell fluid raw milk for safety reasons. We acknowledge risk from consuming raw fluid milk, but illness from commercially sold raw-milk cheese is extremely rare. Experts agree that fluid raw milk and raw-milk cheese have categorically different food safety profiles.

The Centers for Disease Control (CDC) reported 122 incidents of dairy-related illness from 1993-2006 ¹. Only 27 of those 122 incidents involved raw-milk cheese, while 38 were from pasteurized cheeses. This reflects the fact that most contamination occurs post-processing. According to the CDC report, only two fatalities were linked to unpasteurized dairy products over the 14-year span.

Current scientific research regarding raw-milk cheese increasingly suggests that the benign microbes found in unpasteurized cheese may have an anti-pathogenic effect. A study conducted at the French National Institute for Agricultural Research (INRA) suggests the rich microbial environment of raw-milk cheese inhibits growth of pathogens ². Similar conclusions were found in a study published in the International Journal of Food Microbiology ³. In other words, the good microbes in raw-milk cheese seem to win out over bad pathogens.

Also, “Mandatory pasteurization of milk may increase the susceptibility of cheese to growth of pathogens introduced via post-processing contamination,” says Dr. Catherine Donnelly, Professor in the Department of Nutrition and Food Sciences at the University of Vermont ⁴. Konrad Dunhem of the French Dairy Interbranch Organization (CNIEL), the umbrella organization for France’s dairy industry, has noted that when produced under strict quality controls “raw milk cheese is self-protected against major pathogens and is less exposed to recontamination by major pathogens”. ⁵

Like the Oldways Cheese Coalition, we at PCC Natural Markets believe it’s important to recognize that before the advent of pasteurization in the 1850s, all cheese was raw. Pasteurization brought in a new era of commercial cultures, processing technology, and advanced modes of transportation. “American cheese making increasingly moved off of the farm and into the factory,” says Oldways. It became less common for cheese to be made from the milk of a farmer’s own herd and more common to be from pooled milk from numerous farms.

The centralization of cheese making expanded considerably in the last century to the point that, by the 1980s, there was hardly a farmstead or raw-milk cheesemaker to be found, according to Oldways. Concerns about the safety of raw-milk cheese have emerged from this move of cheese making off the farm and into the factory. Why?

To ensure quality, milk must be fresh and clean. That’s why there’s a close relationship between a dedicated farmstead production and raw-milk cheese. It’s harder to control hygiene when the milk comes from a pooled source or is produced on a large scale.

The presence of naturally occurring ambient microflora means raw milk is highly perishable and is a particularly suitable medium for bacterial growth. When conscientiously controlled, this fact is beneficial — if not essential — to cheese making. Because the good bacteria outcompetes undesirable bacteria, they render cheese a preserved product that’s safe for human consumption months and even years after the animals are milked.

The FDA’s own data backs up the efficacy of good practices on the farm and the safety of raw-milk cheeses. The Food Safety Modernization Act prompted the FDA throughout 2014 to implement a pilot testing program. Imported and domestic raw-milk cheeses were tested routinely for pathogens of concern. The results overwhelmingly pointed to the safety of raw-milk cheese. ⁶

The importance of using exceptionally clean raw milk in cheese making cannot be underestimated. Artisan, farmstead raw-milk cheese vendors for our stores emphasize the safety of their cheese depends 100 percent on the strict hygiene measures in place on their farms and in their creameries.

Scientists at the University of Vermont have shown that small-scale artisan cheese making firms that use milk from well-treated animals produce cheese of high microbial quality with very low incidence of pathogenic contamination ⁷.

That data was reinforced in a second, broader-scope study ⁸. One important reason for this is that artisan and raw-milk cheesemakers generally maintain fastidious sanitation regimens and pay exceptional attention to the health of their animals and the hygiene of their milk and equipment. As Dr. Donnelly noted, “Artisan cheesemakers are unequivocally committed to the safety of the products they produce … regulatory attempts to ban the use of raw milk in cheese making … [is] not supported by the large body of science surrounding these issues.”

Conversely, cows and other animals in large, industrial scale “factory-farm” systems where they’re kept in confined conditions, are much more likely to develop udder infections or other illnesses that contaminate milk.

Consumer choice, producer livelihoods

At PCC we have robust cheese departments, featuring both pasteurized and raw-milk cheeses. Some are local and some are international. Many of our shoppers choose raw-milk cheese because they prefer whole foods that are as close as possible to their natural form. They believe raw-milk cheeses offer more health benefits and are more delicious than pasteurized cheeses because pasteurization kills not only potentially harmful bacteria, but also other bacteria that are responsible for infusing cheese with deep, rich, savory, novel flavors.

“Some raw-milk cheeses tend to have a more complex flavor profile — they’re more earthy and a bit more flavorful with a stronger lingering finish,” says PCC’s cheese expert, Sylvie Koester. Heating milk to high temperatures changes its composition and that affects taste.

We urge you to review the results of Oldways survey of consumer sentiment about raw-milk cheese.

We urge you to create a system to evaluate raw-milk cheeses that reward farmstead, artisan raw-milk cheese makers for producing cheese with utmost care and attention to cleanliness. Consider how these operations differ from industrial-scale operations where cheese is produced from pooled milk often sourced from factory-farm-raised animals that are more susceptible to illnesses that can contaminate milk. A “one-size-fits-all” approach to regulation poses undue burden on the food producers who are doing things right.

According to one of our local raw-milk cheese producers, Tieton Farm & Creamery, one constructive step FDA could take is to fund quickswab testing. Currently, testing for pathogens is costly, consisting of someone taking swabs and sending them to a lab to be incubated, which takes days — or destructive testing, which also is very costly for small businesses, such as Tieton. “If we had inexpensive quick swab testing,” says Tieton owner Lori Babcock, “we could prove that our small, sustainable, pasture-based operations are pathogenic-free.”

We appreciate that FDA is open to input from retailers such as PCC Natural Markets and we encourage you to protect the interests of raw-milk cheese producers and consumers alike.

Thank you for the opportunity to comment.

Sincerely,

Eli Penberthy

PCC quality standards

Editor of Sound Consumer

Citations:

1. Centers for Disease Control and Prevention (CDC) Emerging Infections Diseases (2012) Unpasteurized Dairy Products, Disease Outbreaks, United States, 1993 – 2006. Available online at: Centers for Disease Control and Prevention (CDC) Emerging Infectious Diseases 2012 Unpasteurized Dairy Products, Disease Outbreaks, United States, 1993 – 2006
2. Microflore du lait cru | Vers une meilleure connaissance des ecosystems microbiens du lait et de leurs facteurs de variation (Conseil National des Appellations d’Origine Laitieres – July 2011) by Cécile Laithier (ed.) Available online at:
   
3. Survival of Listeria monocytogenes during manufacture, ripening and storage of soft lactic cheese made from raw goat milk (International Journal of Food Microbiology, Vol. 64, 2001) by F. Morgan, V. Bonnin, M-P. Mallereau, G. Perrin. Available online at: http://media.wix.com/ugd/76ddc6_6592cf72c09f499686e4a636a286a51c.pdf
   
4. The Pasteurization Dilemma by Donnelly, C., in American Farmstead Cheese: The Complete Guide to Making and Selling Artisan Cheeses, Vermont Cheese Council 2005, P. Kindstedt (ed.) 1
   
5. The Benefits and Risks to the Producer and Consumer of Cheese made from Raw (Unpasteurized) Milk, ACS Conference 2011 by Carol Terracine Hartman, Ryan Fewins-Bliss, Brigitte Balogh, and Ewen C.D. Todd. Available online at: http://media.wix.com/ugd/76ddc6_1eef5f23f3bf4f48961825a744b68c01.pdf
6. Letter to American Cheese Society (ACS) with an Update on What Has Been Done with Respect to Non-toxigenic Escherichia coli (E. coli) in Raw Milk Cheese (Deparment of Health and Human Services, FDA) Letter to American Cheese Society (ACS) with an Update on What Has Been Done with Respect to Non-toxigenic Escherichia coli (E. coli) in Raw Milk Cheese
7. Low Incidence of Foodborne Pathogens of Concern in Raw Milk Utilized for Farmstead Cheese Production (Journal of Food Protection, Num. 8, 2008) by D’Amico, D., Groves, E., Donnelly, C.W. Available online at: Low Incidence of Foodborne Pathogens of Concern in Raw Milk Utilized for Farmstead Cheese Production (last visited May 7th, 2015).
8. Microbiological quality of raw milk used for small-scale artisan cheese production in Vermont: Effect of farm characteristics and practices (Journal of Dairy Science, Vol. 93, Issue 1, 2010) by D’Amico, D.J., Donnelly, C.W. Available online at: Microbiological quality of raw milk used for small-scale artisan cheese production in Vermont: Effect of farm characteristics and practices(last visited May 7th, 2015).