BRATTLEBORO — The United States Food & Drug Administration (FDA) recently caused a near panic among cheese industry professionals - and among plenty of people who love good cheese and who would like to continue eating it.
The FDA said that “wood is no good.”
Or did it?
Two years ago, the agency found Listeria monocytogenes (the bacterium that causes the potentially fatal infection listeriosis) on multiple surfaces during an inspection of a cheesemaking facility in the Finger Lakes region of New York. One of those surfaces was a wooden board upon which cheese was aging.
The cheesemaker thoroughly cleaned her entire facility, but a year later, the FDA again found Listeria monocytogenes and shut her down.
After much back and forth between the two parties, the FDA informed the cheesemaker that she needed to get rid of her wooden aging planks.
New York's Department of Agriculture's Dairy Services Division stepped in and asked the FDA for clarification, to ensure New York's policy of allowing cheesemakers to age cheese on wooden planks did not violate federal regulations.
In response, Monica Metz, branch chief of the FDA's Center for Food Safety and Applied Nutrition (CFSAN) Dairy and Egg Branch, informed the state agency that the “use of wooden shelves, rough or otherwise, for cheese ripening does not conform to cGMP [current good manufacturing practice] requirements, which require that 'all plant equipment and utensils shall be so designed and of such material and workmanship as to be adequately cleanable, and shall be properly maintained.'”
As the American Cheese Society (ACS) reported in a member alert, “FDA does not consider this to be a new policy, but rather an enforcement of an existing policy. FDA has reiterated that it does not intend to change this policy.”
This came as quite a surprise for domestic artisan cheesemakers, many of whom age their cheese on wooden planks, conforming to industry standards spanning approximately seven millennia. (Cheesemaking predates recorded history, and archaeological projects continue to dig up ever-older evidence of cheese production, so any claim of the provenance and “start-date” of cheesemaking are really guesses at best.)
* * *
The FDA's position also presented an expensive dilemma for cheesemakers across the country: replace the wooden planks and bear the cost (if possible), or continue and risk being shut down and having all cheese seized and dumped.
For Greensboro cheesemaker Jasper Hill, the estimate for replacing its wooden aging planks is about $20 million. With the tight profit margin in cheesemaking, this change is simply not feasible.
Domestic cheeses (and the people who make and love them) would not be the only victims of this “enforcement of existing policy.”
As the ACS reminded its members, “Cheesemakers importing cheese to the United States are subject to the same rules and inspection procedures as American producers. FDA has stated that it will be consistent in its application of the policy to both domestic and foreign producers.”
In that scenario, the FDA would be able to tell makers of such cheeses as Comté and Parmigiano-Reggiano that if they age their cheeses on wooden planks, those cheeses would be illegal to import into the United States.
Cheese export is a huge business, especially in the trade route from Europe to the United States. According to figures provided by Iowa State University's Agricultural Marketing Resource Center, “U.S. imports of cheese were 142,146 MT [metric tons] valued at $1.07 billion. Top sources for importing cheese were Italy and France.”
There's one other problem - a big problem - with that requirement, and it has nothing to do with the expense of new equipment.
PDO (Protected Designation of Origin, or name-protection) regulations demand very specific conditions for the entire cheesemaking process.
Depending on the cheese, these specifications might range from defining the breed of animal milked and exactly where and when it is allowed to graze, to the type of surface upon which a cheese may age for it to be known legally by a deeply traditional name. And for many cheeses, that surface is wood.
Brand recognition is crucial to marketing. How shall a cheesemaker successfully sell all that “Comté-like” cheese?
More likely is European cheesemakers would refuse to eschew wood, and probably laugh at us (as usual), prompting the European Union to engage in a trade war with the United States.
* * *
Meanwhile, back in the States, the collective rage of the cheese-frenzied reached the legislative branch of our federal government.
On June 11, 2014, Vermont's own U.S. representative, Peter Welch, distributed an open letter to his colleagues entitled “Cheese Lovers of the House Unite!”
The subhead of the letter implored the House of Representatives to “Stop the FDA from Banning Centuries-old Cheese Making Practice” and “Support the Welch/Ribble/Kind/Ryan/Duffy/Defazio/Pocan/Gibson/Pingree/Huffman/Hanna/Courtney/Owens/Kuster/Petri/Walberg/Weber Amendment.”
Apparently, cheese unites politicians from both sides of the aisle.
Welch's letter described longstanding cheesemaking traditions and assurances that the cheesemaking industry already has “rigorous [safety] protocols in place.”
It also took potshots at the FDA: Noting that the agency lacked “evidence to support its enforcement,” Welch called this “crackdown” and “bureaucratic overreach” nothing more than a “solution in search of a problem.”
The letter urged the FDA, instead, to “take a deep breath and work collaboratively with food scientists and cheese makers.”
Going further, Welch plans to attach an amendment to an upcoming agricultural appropriations bill. In a move to slaughter the cash cow, the proposal proscribes the agency from spending any money to enforce the ban on wooden cheese-aging planks.
In response, the FDA backpedaled, claiming that the agency does not “have a new policy banning the use of wooden shelves in cheese-making, nor is there any... requirement in effect that addresses this issue. Moreover, the FDA has not taken any enforcement action based solely on the use of wooden shelves.”
It's worth visiting the page on Welch's official website where the congressman reacts to FDA “clarification” on use of wood shelves to age cheese. He joins in solidarity with the social-media movement “Save Our Cheese” (#SaveOurCheese), and posts an infographic displaying the confusion emanating from the FDA.
The two contradictory quotes - one banning wooden shelves, and one saying there is no ban - from the FDA appear in front of a graphic of two hands. Above the hands appears Welch's statement: “The FDA's right hand doesn't know what its left hand is doing. Which FDA should cheese makers listen to? We will not back down.”
* * *
Amid all the cheese-related doomsday predictions and chest-thumping - no matter how appropriate - does the FDA present a good point?
According to its website, the Center for Food Safety and Applied Nutrition is responsible for ensuring “the food supply is safe, sanitary, wholesome, and honestly labeled.”
One can argue that the CFSAN doesn't always hit its target, but would we accept its looking the other way just because of tradition? Listeriosis can be deadly.
Conventional wisdom tells us Listeria monocytogenes and other pathogenic bacteria thrive on wooden planks. With all those uneven surfaces, the wood cannot be properly sanitized. Plastic shelving is better, because bacteria can be completely removed from its surface. Right?
Not entirely.
Despite what your local health inspector says, wood turns out to be safer than plastic for food preparation. Numerous studies conducted in France, and one notable domestic one, back up this claim.
In a study conducted by University of Wisconsin's Food Research Institute, microbiologists Dean O. Cliver and Nese O. Ak, while trying to discover ways to thoroughly remove bacteria from wooden cutting boards to make them as “safe” as plastic ones, “stumbled upon” surprising results, wrote New York Times health columnist Jane Brody.
“[T]hey found that when boards were purposely contaminated with organisms like Salmonella, Listeria and Escherichia coli that are common causes of food poisoning, 99.9 percent of the bacteria died off within three minutes on the wooden boards, while none died on the plastic ones,” she wrote.
“When contaminated boards were left unwashed overnight at room temperature, bacterial counts increased on the plastic, but none of the organisms could be recovered from the wooden boards the next morning,” Brody continued.
Furthermore, the ACS states, “No foodborne illness outbreak has been found to be caused by the use of wood as an aging surface.”
And, according to Deerfield, Mass.–based New England Cheesemaking Supply's website, “Another recently understood aspect […] is that some of the coryneforms [bacteria] that are harbored in the wood will naturally fend off (out-compete) the Listeria that tends to grow in washed rind cheeses.”
* * *
Of course, this doesn't preclude anyone from thoroughly washing any food preparation surfaces of any material, but it also shoots big, Emmentaler-like holes in the FDA's earlier stance.
It's worth noting that some bacteria are beneficial to cheesemaking, and wooden planks provide a comfortable home for them. Wood also acts as the perfect humidor for cheese, assuring that the moisture level in the cheese is not too wet and not too dry. Some woods add to the flavor of the cheese; without their aromatic resins, many of our favorite cheeses would have a diminished organoleptic profile.
Countless cheese-industry books and websites instruct cheesemakers on the proper sanitization of wooden aging planks, both prior to initial use, and in between batches of cheese.
One of the French studies “concluded traditional methods of cleaning wooden cheese ripening boards by soaking them in cold water and brushing them minimized the risk of contamination by pathogenic microorganisms, thus allowing useful microflora to be preserved.”
Other cleaning methods include washing, soaking, brushing, and rinsing in hot water, and kiln-drying.
Jim Wallace, New England Cheesemaking Supply's technical expert, describes methods on the company's website.
“What I see throughout Europe are stacks of boards drying in the sun,” he writes. “This is not just to remove the moisture but it is also pointed out that 'Ol Sol' has the ability to sanitize naturally with an abundance of UV. The UV will cut back the numbers of microbes on the board surface.”
* * *
Accepting the reality that bacteria do sometimes get out of control and cannot be mitigated, cheesemaking rules demand planks with large-scale pathogenic contamination be destroyed.
Unlike plastic - which, according to the studies, can harbor pathogenic bacteria in the grooves and scratches that inevitably occur with use - wooden planks burn, providing heating fuel or just a nice campfire.
Cheesemaking is an art and a science. Every aspect of the process - from the microbiology of the milk, to the environment of the aging rooms, to the temperature during transport and sales display - has a very small range of acceptable conditions, with little margin of error.
Were wooden planks harmful, the practice of aging cheese on them would have disappeared as soon as a more suitable material were found or developed.
* * *
Despite the FDA's most recent assurance, not all cheesemakers are breathing easily.
The ACS's recent member update states the organization has been contacted by Kari Barrett, advisor for strategic communications and public engagement for the FDA Office of Foods and Veterinary Medicine.
“FDA is not taking a hard stance from which they cannot back away,” the ACS advised.
The update mentioned that the initial FDA statement “was perhaps more definitive than intended, and that FDA would never take action without going through the normal regulatory steps including a public comment period.”
This still leaves the possibility open that the FDA will, in fact, “go through the normal regulatory steps” to ban, and then enforce the ban, on wooden aging planks.
If you have an opinion on this matter, contact your federal legislative representative.
And if your opinion includes preserving the tradition of aging cheese on wooden planks, consider signing the online petition to the Obama administration, “Lift the FDA restrictions on ripening cheese on wooden boards, which will devastate the American craft cheese industry,” at petitions.whitehouse.gov.