I was pleasantly surprised to see the sign shown here at a Vermont food co-op where I like to shop—truthful labeling that contrasts with the questionable labeling of almonds in many food stores, often suggesting they are “raw” when they have been pasteurized.
There’s a big controversy that is ongoing about the labeling of genetically-modified food, with Congress well along in passing legislation that would prohibit states from requiring the labeling of GMO food.
I mention truth in labeling because a few days ago, the U.S. Food and Drug Administration posted a notice on its web site that it was seeking input to help it “minimize the impact of harmful bacteria in cheeses made from unpasteurized milk.” The agency said it was particularly “interested in learning more about the standards and practices in use by….the growing artisanal cheese manufacturing community.”
All innocent stuff, the FDA suggested, “part of an ongoing discussion with industry and other stakeholders about potential health risks associated with consumption of cheese made from unpasteurized milk…” Except it’s not really a “discussion,” but rather a monologue that has been going on for the last 11 years, in what can be more accurately described as an FDA campaign against raw milk cheese. The exact opposite of truth-in-labeling.
The FDA said it was seeking comments and data because it had just released “a joint FDA/Health Canada Quantitative Risk Assessment. This is apparently the latest version of a paper first issued in early 2013, which I analyzed for Food Safety News, in which I questioned the agency’s conclusion that soft raw milk cheese is 50-160 times riskier than pasteurized-milk cheese, even though the agency couldn’t identify a single outbreak of illness over a 23-year period, aside from a few from queso fresco cheese.
So what about the new version of the risk assessment the FDA is now trumpeting? Well, as co-workers used to say at a place I once worked, “Same sh**, different day.” Among the most obvious problems:
- The actual full written risk assessment is nearly impossible to find. There’s no link to it on the FDA web site notice, even though it is supposedly the main reason for the request for comments and data. I had to get some expert help in locating this chart, and way down on the list is the mysterious FDA risk assessment.
- Once you find the assessment/report, it’s nearly impossible to read, because its 177 pages aren’t written in anything approaching understandable English.
- Predictably, though, the material that is understandable does what the previous version of the risk assessment I wrote about two years ago did: It concludes that soft raw milk cheese is much more dangerous than pasteurized milk cheese, even though nearly all the outbreaks and illnesses it lists on page 19 come from pasteurized milk cheese. Of 18 outbreaks of illness from listeria in soft cheese that sickened 473 people worldwide since 2006, only one outbreak, involving 15 illnesses from listeria in blue cheese (in the U.S.), came from raw milk cheese. Everything else? Nearly all pasteurized milk cheese, or else the pasteurization status wasn’t clear.
The FDA’s risk assessment doesn’t bother to dwell on such central information, which contradict its campaign against raw milk cheese. Indeed, I couldn’t find any discussion about the actual illnesses. Instead, it goes through hypothetical risk models—what-ifs, what might have been, what could happen. It points out that there have been dozens of recalls of soft raw milk cheese in the U.S. because listeria was found in the cheese or the production environment; what it doesn’t say is that these recalls rarely involve illnesses. That’s because the FDA is nearly alone among developed countries in adhering to a zero-tolerance policy on listeria, even though it’s been well established that small amounts of listeria pose little danger of illness.
And the FDA concludes that raw milk cheese, even under the best of circumstances, which entail it being treated with “a hypothetical substance (an antimicrobial voluntarily added during the manufacture of the raw-milk cheese) that would reduce the L. monocytogenes concentration present at the surface of the cheese by 2 log10 cfu would provide a lower mean risk of invasive listeriosis per serving than estimated in the raw- milk cheese baseline, but this risk would still be 50 and 86 times higher than the mean risk per serving of pasteurized-milk cheese, as estimated in the pasteurized-milk cheese baseline, in Canada and the U.S., respectively.”
Yes, even if the raw-milk soft cheese were treated with some imaginary purification agent, it would still be 50 to 86 times riskier than pasteurized milk cheese. Can’t win for losing.
And therein lies the FDA’s “problem” since the start of its long campaign against raw milk cheese—the campaign has been unable to demonstrate via real-life data that raw milk cheese, even soft raw milk cheese which it assumes is the most dangerous and thus would make the best target for its campaign against raw milk cheese, poses any danger.
Why doesn’t the American Cheese Society, which represents hundreds of artisanal raw milk cheese producers, speak up about this crazy charade, how this campaign against raw milk cheese could lead to its ban? Because one smart move FDA made in its campaign against raw milk cheese was to co-opt the potential opposition. The ACS made an ill-advised decision to cooperate with the devil, and so it has become a “partner” in this insidious campaign against truth in labeling, and is now left speechless.