ACS engagement on food safety and regulatory issues:
The American Cheese Society engages with regulators and other key stakeholders on a regular basis to advance issues of importance to our members. This work keeps American cheesemakers, and particularly traditional cheesemaking practices, top-of-mind for industry decision-makers.
An overview of advocacy and engagement efforts can be found below. Please note that this list may not be all-inclusive, and updates are made periodically.
American Cheese Society members can also follow the latest updates on this work by reading the “Traditional Cheese Advocate” newsletter, which is disseminated via email on a quarterly basis.
For questions about this work, or for media inquiries, please contact the ACS office.
- Ongoing: The ACS Regulatory & Academic Committee is incorporating FDA’s technical comments into the ACS Best Practices Guide for Cheesemakers. In addition, the chapter of the Guide focused on Preventive Controls will be revamped to better reflect the Food Safety Modernization Act. The updated edition of the Guide was published in February 2017.
- 10-31-16: ACS submitted Comments on the Voluntary Sodium Reduction Targets to the Federal Register.
- 9-21-16: The Artisan Cheese Food Safety Advisory Group met to focus on how identified gaps in education, information, and outreach might be filled for artisan producers. ACS will take the helm on one initial project, the creation of a website that will serve as a free, robust portal accessing important food safety resources for cheesemakers. The site, to be launched in 2017, will consolidate the most current and up-to-date links to resources, extension and on-line learning, research, and local/regional support.
- 9-16-16: A report of outcomes from ACS’s July 27 Preventive Controls Working Group meeting was shared by ACS representatives at a September 16 meeting with FDA. All who attended the meeting agreed that these points offer a valid direction. While FDA made it clear that they do not feel raw milk as an ingredient can ever achieve the validated safety of pasteurized milk, they were open to the idea that a set of steps, or hurdles, taken in aggregate might form a food safety plan for raw milk cheese.
- 7-29-16: Dr. Nega Beru, Director, FDA CFSAN Office of Food Safety, shared an update with ACS Conference attendees in Des Moines this summer. The full presentation is available at ACS Education on Demand. The session addressed key stakeholder concerns including: Results of the Raw Milk Cheese Testing Pilot Program; the status of FDA’s pause in testing for non-toxigenic E. coli as an indicator organism; potential direction for the 60-day aging rule; conclusions drawn from the Risk for Listeriosis from the Consumption of Soft-ripened Cheese Risk Assessment; Preventative Controls for raw milk cheesemaking.
- 7-27-16: Leading academics, retailers, producers, and distributors met in Des Moines at the invitation of ACS to participate in a Preventive Controls Working Group. Under the Food Safety Modernization Act (FSMA), FDA considers not only Critical Control Points, but broader risk-based Preventive Control (PC) steps as part of a food safety plan. To this end, these industry stakeholders met to discuss what such PCs might look like for cheeses made with unpasteurized milk.
- 2-22-16: ACS sent a letter to FDA Deputy Director Michael Taylor and CFSAN Director Susan Mayne in follow up to the 2-11-16 meeting held with ACS members in Washington, DC. ACS also submitted a Request for Data to FDA for information from FDA’s Listeria Environmental Sampling Program and FDA’s Raw Milk Cheese Sampling Program.
- 2-11-16: ACS members met with FDA Deputy Director Michael Taylor for a Listening Session on raw milk cheese in Washington, DC. Read a press release with more details and outcomes from this meeting here.
- 12-10-15: A meeting was held between ACS and FDA representatives in Washington, DC on topics including non-toxigenic E. coli levels in raw milk cheese, FDA’s risk assessment of Listeria mono. in soft-ripened cheeses, and FDA’s raw milk cheese testing assignment, along with the ACS Best Practices Guide for Cheesemakers. See the meeting agenda.
- 12-2-15: ACS received detailed technical comments from FDA on Chapters 1-5 of our Best Practices Guide for Cheesemakers, which will be reviewed by ACS’s Regulatory & Academic Committee.
- 10-29-15: ACS submitted its Response to U.S. FDA Request for Information Regarding Safe Production of Cheese from Unpasteurized Milk.
- 7-31-15: FDA representatives presented at the ACS Annual Conference in Providence, RI and FDA announced its request for comments from the public that would assist the agency in identifying and evaluating measures that might minimize the impact of harmful bacteria in cheeses made from unpasteurized milk.
- 7-30-15: ACS submits draft chapters 1-5 of the ACS Best Practices Guide for Cheesemakers to FDA for comment.
- 5-27-15: ACS sent an email to Mike Taylor on the 60-day aging rule for raw milk cheese as a follow up to 5-13 discussions; Taylor acknowledged and thanked us for the information provided in the email.
- 5-13-15: A meeting was held between ACS and FDA representatives in Washington, DC to discuss items including the timeline of a recent industry recall, and updates on FDA’s raw milk sampling program, FDA’s risk assessment for soft-ripened cheeses, the 60 day aging rule for raw milk cheese, and issues/delays with imported cheeses to the US. See the agenda.
- 2-10-15: FDA provides ACS with Artisanal Cheese Producer Inspections, Sample Collections, Analyses, Post Sampling Communications in response to our request for a guide that covers the steps producers can expect during an inspection, as well as when product is collected for sampling. It was shared with members via a member alert, “What To Expect When You’re Inspected.“
- 12-11-14: A meeting was held between ACS and FDA representatives in Washington, DC on topics including non-toxigenic E. coli in raw milk cheese, risk assessment of Listeria mono. in soft-ripened cheeses, raw milk cheese testing assignment, and other timely concerns (see the agenda).
- 9-10-14: ACS sent a letter to William Correll, Director, Office of Compliance for CFSAN/FDA, requesting clarification on why the non-toxigenic E. coli limit for raw milk cheese was changed.
- 8-15-14: ACS sent a letter to Michael Taylor to follow-up on a number of issues including the ACS Best Practices Guide for Cheesemakers, limits for non-toxigenic E. coli in raw milk cheese, wood surfaces for aging cheese, and other timely industry concerns. In this letter, ACS confirmed a plan to meet with FDA 2-4 times annually to connect proactively on industry issues, rather than merely in response to urgent issues.
- 7-29-14: A team from FDA, including Michael Taylor, met with ACS representatives at the ACS Annual Conference in Sacramento, CA. Mr. Taylor presented to ACS members at the Conference.
- 6-13-14: ACS sent a letter to Michael Taylor on the issue of aging cheese on wood boards.
- 6-10-14: ACS issued a Statement on the Safety of Aging Cheese on Wood.
- 4-7-14: ACS sent a letter to Michael Taylor, Deputy Commissioner for Foods at FDA, requesting an in-person meeting to discuss critical issues for the industry.
- 12-20-13: ACS disseminates a member alert, “FDA Launching Pilot Program to Sample and Test Domestic and Imported Raw Milk Cheese.”
- 5-22-13: ACS presented comments at a joint FSIS/FDA Public Meeting on the Interagency Retail Listeria monocytogenes Risk Assessment.
- 4-19-13: ACS submitted comments to the Federal Register in response to the Joint FDA/Health Canada Quantitative Assessment of the Risk of Listeriosis from Soft-Ripened Cheese Consumption in the US and Canada – Draft Report.
- 12-17-12: ACS sent a letter to FDA’s John Sheehan with updates on our work, a request for information about FDA’s raw milk cheese risk assessment, and an invitation to present at the ACS Conference. ACS leadership also sent letters to elected officials around the country in support of raw milk cheese.
- 4-12-12: ACS issued a Statement on the Safety of Raw Milk Cheese.
- 1-31-12: Kate Arding, ACS Board Member, attended an FDA public meeting in Washington, DC and shared the views of ACS on foodborne illness source attribution and product traceability.
- 4-20-11: David Gremmels, ACS President, attended an FDA public meeting in Washington, DC and shared the views of ACS on preventive control regulation and guidance.
- 3-8-11: ACS leaders met with FDA staff at their CFSAN offices.
- 11-17-10: ACS issued a Statement on Safe Cheesemaking and a Statement on the Importance of Artisan, Farmstead, and Specialty Cheese.