By: Heather Williams

Brie, feta, Gorgonzola, blue…  I love them all.  While most people don’t think too much about how cheese is made, some examples are more obvious than others.  Cheeses made with raw milk, mold, and fungus are quite tasty and their artisan production techniques date back centuries.  But what does that mean for the modern health code where bacteria, mold, and fungus are not just frowned upon, but would get a restaurant or manufacturing facility shut down instantly?  The FDA doesn’t quite know what to do with this.  So many times these wonderfully aged, albeit perfectly moldy, rounds of deliciousness are banned from American shelves.  This is leaving cheese-makers frustrated with the FDA’s stance.  It’s “a war against artisan cheese,” says Mateo Kehler, and award-winning cheese-maker from Jasper Hill Farm in Vermont. But the FDA’s job is to keep us healthy and safe. It is quite a conundrum.

How is Cheese Made?

Cheese begins with milk.  Whether pasteurized or raw will depend on the cheese-maker.  Pasteurized is what is typically used, as the United States has huge restrictions on raw dairy.  The milk is the beginning of the flavor profile.  Discerning cheese-makers are very particular about the milk that is used.  Everything from the microbes in the air, the breed of the cow it comes from, the quality of the grass it ate, and even the location of the farm can produce subtle differences in the product.

Then, starter cultures are added to ferment the milk’s natural sugar.  This develops the flavor of the cheese as well as the texture.  Each cheese uses a specific culture.  Depending on the type of cheese being made, additional ingredients may be added, for example rennet is added to Cheddar.

As the cheese begins to form a gel-like texture, the cheese maker will cut it, making smaller curds to allow the whey and moisture to come out.  The more often the cheese is cut, the drier it becomes.  Cheese curds cut less will maintain more moisture.  The product is salted and pressed into a form.  At this point it starts looking more recognizable.  The cheese is shaped depending on what type it is by pressing the curd into a mold.  The curd is salted and pressed into a form (for cheddar and Colby) or hoop (Swiss or mozzarella).  Once the cheese is shaped, it may be aged or treated depending on the type of cheese and flavor profile the cheese-maker is trying to create.

What’s Mold Got to Do with It?

While the general association of mold is unfavorable, producing a visual image of green stuff growing on water damaged walls and fuzzy growth on spoiled food.  Sometimes, mold can be a good thing.  Particularly when it comes to cheese.  Different types of mold, fungus, and bacteria are responsible for the characteristic flavors for each cheese.  Ever wonder what those blue streaks are in blue cheese are, or what causes the smell of gruyere?  Molds and bacteria are responsible for these delights for the senses.

In some cases, such as the Montgomery Somerset (a pale cheddar streaked with blue veins) the environment contributes to the particular cheese.  English fromanger, James Montgomery employs a technique of lightly dropping each wheel during production.  This produces fractures inside the cheese wheel, exposing the inside to the flora in the cave where it ages in Somerset, England.  The mold in the cave, and consequently the cheese cannot grow anywhere else in the world in the exact same way, making this cheese very distinct an impossible to replicate.

Where Cheesemongers and the FDA are Butting Heads

Recently, the Food and Drug Administration (FDA) created the largest overhaul for food safety regulations that this country has seen in 70 years. The Food Safety Modernization Act (FMSA) has implemented the Hazard Analysis and Risk-Based Preventative Controls (HARPC), a control system designed to identify risk at each step of the production process with controls at each step to prevent or minimize risk to increase the safety of food products.  Under these guidelines, non-toxigenic E. coli has been identified as a risk, limiting the amount that is allowed in cheese by 10-fold, essentially prohibiting the presence of E. coli in cheese.

In a statement to TIME magazine, the FDA explains, “Non-toxigenic E. coli in dairy products has long been used by FDA and other public health regulatory agencies in the U.S. and other countries as an indicator organism for the presence of fecal contamination, which could indicate unsanitary conditions in a processing plant.”

The FDA has been strict on milk for quite a long time, dating back to a 1949 typhoid outbreak resulting from poorly kept milk.  This deadly outcome prompted legislation for dairy products that required milk products to be pasteurized.  Pasteurization is a heat treatment for milk that kills harmful bacteria such as Listeria monocytogenes and Salmonella that causes illness.  Current regulations dictate that if cheese is made from unpasteurized milk, it must be aged for at least 60 days with the understanding that existing pathogens die out during the aging process.

The idea behind using non-toxigenic E. coli as a contamination factor is that if the pasteurization process involves heat that destroys microbes, and this bacterium is found in the finished product, then the product must have been contaminated.  However, for raw milk cheese, this is problematic.  Non-toxigenic E. coli is naturally found in raw milk, so it is not necessarily an indicator of the presence other disease-causing bacteria in the cheese.

The naturally occurring non-harmful bacteria and mold found in artisan cheeses is what gives each cheese its distinct flavors.  For some cheese varieties, pasteurization is not an option.

While inconvenient for cheese-makers and unfortunate for consumers, the FDA has reasons for being so picky about bacteria in cheese.  Between 1998 and 2001, one study found 92 different outbreaks associated with cheese, causing 1,882 illnesses, 230 hospitalizations, and 6 deaths.  A nearly split 42% of those outbreaks traced back to unpasteurized cheese, while 49% traced back to pasteurized cheese.  The other 9% was unknown.  The study also determined that many of these cases were from illegally imported cheeses or cheeses that were contaminated post-production.

Non-Toxigenic E. coli is the Heart of the Debate

The heart of the debate lies mostly on non-toxigenic E. coli.  Significant scientific literature has proven over and over that non-toxigenic E. coli is not harmful and critics believe that testing should focus instead on detection of disease-causing pathogens.

Continued pressure from the American Cheese Society against the FDA to re-examine the ineffective use of non-toxigenic E. coli bacteria as a safety standard finally paid off.  The FDA issued a statement in February of 2016 that they would “[take] another look at non-toxigenic E. coli’s role as an indicator organism.”  This was confirmed later that year by Jenny Scott, Senior Advisor to the FDA’s Center for Food Safety and Applied Nutrition.

Cheese producers are happy with the temporary truce and hopeful for a compromise that doesn’t compromise their product.  “It’s a win for sure,” says Kehler, who’s own Winnimere and Bayley Hazen Blue came under threat from the FDA’s testing program.  “For producers like us, making raw milk cheese is at the core of our identity,” says Andy Hatch, the award-winning co-owner of Uplands Cheese in Wisconsin who has also engaged in FDA talks.  Hatch is hopeful for positive change to lean closer to policies in other countries where cheese is more reasonably regulated.  “I have been frustrated by the way they’ve gone about [regulatory implementation],” says Hatch. “But my hope is that they’ll be more transparent, more communicable, and more in line with international standards.”

To Cheese, or Not to Cheese…

Happily moldy?  Contently pasteurized?  Adventurously raw?  To cheese, or not to cheese.  Is that a question?  We are each responsible for our own health and choices and making informed decisions for ourselves.