Letter to Margaret Hamburg, Commissioner of the Food and Drug Administration - The Future of Artisanal Cheese-Making

Letter

Dear Commissioner Hamburg,

The millennia old practice of aging cheese on wood boards is used by many New York artisanal cheese producers in the production of their award winning rind ripened cheeses and is an integral part of the creation of numerous cheeses including Beaufort, Comté, Reblochon, Abondance, Vacherin, Mont d'Or, Salers, Parmigiano Reggiano. Comments by the Food and Drug Administration (FDA) Center for Food Safety and Applied Nutrition (CFSAN) Dairy and Egg Branch call into question the continued use of wood boards to support ripening cheese. While a more recent statement from FDA expresses the agency's willingness to engage with the cheese-making community it does little to address the confusion or concern expressed by producers. If the use of wood aging shelves is prohibited, it would have a substantial negative impact on many small, New York cheese producers as well as make many varieties of imported cheese unavailable to the American consumer.

The Food Safety Modernization Act (FSMA) provides the FDA with expanded authority to improve food safety including mandatory recall, preventive controls, a foreign food safety assurance system, and enhanced surveillance of domestic products. The defining principle of this legislation is that these actions should be based on risk. There is ample research that indicates that the use of wood in cheese manufacturing does not present an inherent risk to the consumer if the boards are properly sanitized.

In light of the research into the time honored practice of curing cheese on wood boards, I ask that FDA issue guidance that would permit the continued, safe use of wood boards in cheese aging. If there is a verifiable, substantive risk posed by the practice of aging cheese on wood boards that can be mitigated through appropriate cleaning and treatment, I ask that FDA include these processes in their guidance. If the FDA concludes that wood boards cannot be cleaned and sanitized for the purposes of aging cheeses, I ask that they provide the scientific and safety data used in their determination.

I commend the work of FDA as it implements the Food Safety and Modernization Act and encourage your continued commitment to risk-based food safety regulations.

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