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Continuing debate and discussion about FDA vs. the cheesemakers


Fromage aux artisous du Velay. From Wikipedia. Uploaded by Abalg.

Well if you have not yet read Russell Neches post on wooden cheeseboards and the FDA you should.  Cheeseboards on the chopping block : Survival on wood and plastic surfaces.  I am writing here as a follow up to that to just point out some of the varied coverage of the FDA vs. the cheesemakers story that is continuing.

First the responses were pretty strong.  Some examples are below:

But then the FDA “clarified” their stance and the tone of the articles started to change

And now there is a hint that some of the coverage will become more balnced between the two positions.  For example, the LA Times has a piece that is more supportive of the FDA than most articles I have seen: Wood-aged cheese: How science slices the debate over bacteria. This article, by Julia Rosen, is also one of the more science-based articles on the topic. It will be interesting to see which ways things go in the next few weeks to months.  Regardless, I would note – it would be good to get some more publicly available data on the diversity of microbes in and on cheese making facilities/boards/etc and how they relate to what ends up in the cheeses.

UPDATE: June 15

Some more stories to look at:

8 thoughts on “Continuing debate and discussion about FDA vs. the cheesemakers

  1. As a person with a strong sensibility about the matter, I have a few related points to make. My professional opinion is that even data about the transmission of bacteria and fungi among cheeses, transmitted on boards, implements and tools of various kinds, is only a proxy for the variable of concern – health impacts.

    First, Listeria monocytogenes contains organisms of differing virulence (as well as viability, culturability under standard conditions, and other important variables). Culture and molecular tests must be assessed carefully in light of human health data before any judgement can be made about findings of environmental bacteria with regard to human health. Findings such as ‘20% of dairies contain L. monocytogenes’ are meaningless to human health without data demonstrating a causal relationship between the finding and health outcomes.

    Second, presuming that there is a hazard caused by bacteria and testable in some way, the proper control method is usually not on a facility level, but on a batch level, using HACCP (hazard analysis and critical control points). This is the standard food-safety strategy.

    In a HACCP process, there must be a hazard. The hazard in this case is a risk of illness and the proxy is the test for Listeria monocytogenes. Each batch of cheese that is tested can be either positive or negative. If boards risk cross contamination, they may cause multiple batches of cheese to be bad – but this is no health risk unless there is no way of testing the separate batches after aging. These are the ‘control points.’ As long as a ‘critical control point’ exists for batches post-aging, the boards represent a potential financial risk (i.e. multiple batches go bad) but not a health risk. If the only tests are pre-aging, however, on batches of unaged cheese, then the boards can ‘bridge’ the batches. Bridging batches such that a tested batch can be subsequently contaminated in an undetectable fashion is a problem in system design.

    This is ultimately my comment: methods exist to mitigate the health risks associated with all sorts of food preparation methods. Ultimately, we need actual health data to trigger appropriate regulation; and also to inform the science. Methods for food safety exist to mitigate the risks associated with all manner of preparation methods, given appropriate food science and systems engineering.

  2. Thanks, BenK, for pointing out the endpoint of interest — health. Oh yes, did I mention that the end point of interest is health?

    Since I have been using the same wooden cutting board to prepare my meals since 1971, and since I eat a lot of cheese, I decided to read the suggested original post https://microbe.net/2014/06/11/cheeseboards-on-the-chopping-block/

    I was surprised by the numbers cited there: “According to the CDC, one in six Americans (48 million people) are infected by food borne pathogens every year, 128,000 of whom are hospitalized, and 3,000 ultimately die.”

    I tried to find this on the CDC web site and could only come up with this from MMWR (April 18, 2014 / 63(15);328-332): “Foodborne disease continues to be an important problem in the United States. Most illnesses are preventable. To evaluate progress toward prevention, the Foodborne Diseases Active Surveillance Network* (FoodNet) monitors the incidence of laboratory-confirmed infections caused by nine pathogens transmitted commonly through food in 10 U.S. sites, covering approximately 15% of the U.S. population. This report summarizes preliminary 2013 data and describes trends since 2006. In 2013, a total of 19,056 infections, 4,200 hospitalizations, and 80 deaths were reported.” (http://www.cdc.gov/mmwr/preview/mmwrhtml/mm6315a3.htm?s_cid=mm6315a3_w)

    Maybe I am reading it wrong, but the 48 * 10^6 number appears to apply to the percentage of the population covered by the FoodNet survey, not the number of Americans …infected by food borne pathogens every year.” Am I reading that wrong? Is there a reference (url) for the 48*10^6 foodborne illnesses?

    “In 2013, a total of 19,056 infections, 4,200 hospitalizations, and 80 deaths were reported.” (http://www.cdc.gov/mmwr/preview/mmwrhtml/mm6315a3.htm?s_cid=mm6315a3_w) So this is for the 15% of the population covered by the FoodNet survey. (note: In my opinion, the fact that the survey is not based on a a random, stratified sample of the population so it is not known how accurate it may be as an indicator of the national figures. Maybe some of you with more understanding of statistics can help me out here.

    Having said that, if I use 80 deaths in the 15% of the population covered by the FoodNet Survey and extend that to the entire population, I get 533.3 deaths per year. [I am not sure what “0.3 deaths” means, but it’s just the math :-)]

    1. Here’s the CDC page with the oft-cited 48 million figure:

      And here are two papers that lay out the statistics:

      It frustrates me that such numbers are often cited as fact, rather than extrapolations with error bars or other acknowledgment of uncertainty. I’ll credit David Gumpert with getting me to take a closer look: http://thecompletepatient.com/article/2012/december/11/why-we-media-need-end-our-addiction-cdc-food-safety-%E2%80%9Cepidemic%E2%80%9D-data

      Those aren’t the only dubious numbers. In the FSMA proposed produce rule (the focus of my attention), the FDA’s cost-benefit analysis is based on the assumption that the rules will prevent 3 orders of magnitude more illnesses each year than the annual average of documented illnesses within a ~15 year time span.

      In spite of the usual quoting of the CDC numbers, I greatly appreciate the original cheeseboard post; nice to hear a scientific voice speaking up on this issue in an informative way. Thank you.

      1. The estimates you’re citing for the number of illnesses caused by domestically acquired foodborne are somewhere between 6.6 and 12.7 million, and between 19.8 to 61.3 million for foodborne illnesses where the identity of the agent was not determined. I’m not prepared to judge whether the statistical methodology is appropriate or correctly applied, but I don’t see anything obviously dubious about them.

        Nevertheless, I have been more clear about where the numbers came from, and that they are estimates with a confidence interval of about +/- 30%. I’ll update the post to that effect.

  3. Hmm. I’ve been using the same two wooden boards in my kitchen for years. Both are used for cheese, raw meat, veg, fruit…washed between uses of course, but no one has ever been ill from eating food prepared on these boards in my home. I cook and serve fresh foods daily. Probably many hundreds of meals by now. I realize that I’m not aging cheese on them, but it leads me to think that proper handling, and in the case of commercial food production add safety testing, can mitigate most food contamination concerns.

  4. Paula,

    Me too! I have been using the same Teak wood cutting board for 44 years! I eat a lot of cheese. No illness so far.

    But the original article was not about home food preparation but, rather, about the use of wooden shelves and boards for aging cheese in the cheese-making industry. There is a big difference between letting cheese sit for long periods in contact with the wood (or plastic) in aging cheese during commercial preparation/processing and simply cutting or chopping some cheese as part of meal preparation.

    So it is not clear what relevance your or my experiences with wood cutting boards might have to Russell’s initial post or Jonathan’s exhaustive list of further reading.

    Regarding my wooden cutting board, as far as I know, neither I nor anybody else has gotten ill from foodborne disease here. I rarely go out to eat, so these 44 years have covered a very large number of meals prepared at home in 7 different homes, the last 28+years in the same home. I use the cutting board during preparation of nearly all my meals. Of possible relevance, my water comes from a well and is not treated.

    I have been a vegetarian for 43 years, so no meat has been involved, but I eat a lot of cheese on most evenings, and its preparation almost always involves some cutting on the cutting board.

    Does the type of wood matter? What about cutting, slicing, chopping, etc.? What about the sharpness of the knives or other tools? What about clean-up procedures and materials?

    There are huge differences in the various woods available for cutting boards, and the sharpness of the knives and their uses and the procedures followed create “niches” where microbes can linger and, perhaps, multiply or evolve. There are a lot of visible cut marks in my board. Even the hardest wood will not resist some grooving as a result of cutting with sharp knives pressed hard.

    Cleaning probably matters, but I simply wipe off visible residual food particles and let the board air dry.

    1. I hope we have a few more people involved in MicrobeNet who have particular professional training; I’m thinking specifically of infectious disease, infection control, and food safety. I wouldn’t say that the training from ServSafe is necessarily extensive, but it provides entry level awareness training – the awareness that commercial, industrial and public service food safety and preparation is not private/residential.

      Without going on at length, as the numbers of consumers and preparation staff increase, as the maximum distance/time from preparation to service increase, and as the scale of preparation increases, there are non-linear effects. This is why many consumer tools – many so-called chefs’ knives, for example – would not be accepted in a commercial kitchen. NSF standards demand that the materials typically be non-porous and have solid welds or joints, not seams or gaps where filth could accumulate over time. Porous materials can absorb and later release cleaning agents (chemical contamination), for example.

      To be clear – my argument is not that rough wooden boards should be used at point of service, say, on a buffet line, where cross contamination and time-temperature abuse are extremely serious concerns.

      As every trained cook knows, cross contamination from ingredient to ‘ready-to-serve’ is one of the most serious failures. As long as there is a HACCP critical control point downstream of the preparation, there is an opportunity to mitigate the upstream risk; but at that control point we also need good, evidence-based testing that reveals the true hazard, not a poor proxy.

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