Cultivation of a Cheesemonger

A Blog of Cheese Culture and Cultures

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On Tasting

The following  post is written by guest author and friend.  He is an international bartender, fantastic painter, and a lover, not a fighter.

He writes about tasting coffee, but his views are equally applicable to cheese.  Please welcome our guest author, Jonathan Gaige.

On Tasting 

by Jonathan Gaige

I’m a New Yorker currently in Australia and have noticed that Australians are into coffee in a big way. I’ve been a self-proclaimed coffee connoisseur for 12 years and this came as a surprise to me. They have their own signature cultural drinks such as the Flat White. The Flat White is similar to a latte but with thinner foam on top and a ratio of milk to espresso that makes it much stronger in coffee flavor. Every cappuccino I’ve seen here is topped with cocoa powder, which, in my opinion as a gastronomic purest, is not natural but an enjoyable foible in this foreign land. I would like to make clear, in case I come off as preachy (which I’m sure I will) that this is simply my opinion and my perception of why and how we taste.

Twelve years ago, I took my first job as a barista and I have been exploring the world of coffee ever since. I continue to refine my taste through revisiting drinks I’ve had before and expanding my palate trying new beverages. I’ve sampled and tasted coffee varieties from all over the world – Vietnamese Iced, Turkish/Greek, Espresso beverages, good ol’ American Drip, Japanese pour over and have dreamed of starting a cafe that could brew any kind of coffee that you want because all of these styles of drinking the bean tea are unique and admirable.

Photo of Japanese Pourover by Kenji Aoki for New York Times Magazine

Photo by Kenji Aoki for New York Times Magazine

So, it took me by surprise that just about all of the Australian natives I’ve met in my journey throughout the country say that there is no good coffee in America (speaking about NYC predominantly). I would like to get out of the way that there are some world class establishments in New York to seek out if you’re hard core about your coffee. As a country that takes their coffee seriously, this mindset is truly befuddling to me. First off, the espresso drinks here taste pretty much the same as back home to me, and second, and I’m not trying to go tit for tat with the Aussies, but I’ve gotten some pretty random interpretations of a Flat White, some indistinguishable from a latte.

I‘m not making a point that there is no good coffee in Australia, but it has made me start thinking about the interpretation of taste and how taste is perceived. Since I cannot put my finger on exactly why Australians feel there is no good coffee in America, I turned my thoughts inward and began to analyze my own methods of taste.

I realized quickly that over the years, I have developed my own personal standards to evaluate what I am tasting. Whether it’s for coffee, wine, chocolate, or cheese, when I try something new and am evaluating the craft by which something was made, the first thing I look for is “some quality”.

Quality and Blandness

Some quality” to me is anything I can identify as a quality. I may not like the particular quality but as a taster I’m trying to identify if it’s got something distinct for someone to appreciate. I don’t take my own taste buds as gospel. Any wine merchant will tell you at a tasting that there are no wrong answers. The first thing I think about while evaluating any digestible is basically “Is this bland?”

Factors within Quality – Is this I something I enjoy eating?

This search obviously and inevitably leads to a variety of other questions about exactly what those qualities are: what notes on a flavor wheel could be identified, if there is balance struck with those flavors, mouthfeel, aroma, texture, etc. One could, after that, bring other factors under evaluation – like cost – which if you happened to be in a place that only has civet digested coffee, could effectively bring a person to the conclusion that, practically, it is not accessible and therefore there isn’t any good coffee in the place. At the end of the day I’ll draw the conclusion as to whether or not this thing is a thing I like and would enjoy eating.

Ask yourself... is this bland?  Courtesy of Arrested Development

Ask yourself… is this bland?
Courtesy of Arrested Development

Cultural Relativity and Location

I thoroughly believe too, that cultural relativity would comes into play. If I hear about balut, for example, can’t just go find a fertilized egg and say I’ve had it. In other words, when in Rome, do as the Romans. The first time I had balut was in Cambodia at a market stall on the street with all the accouterments. Without that perspective, I don’t think I could say that I’ve really had it. Nor would I know its better with vinegar. If I know that I’m the type of person who doesn’t like cilantro, as in for many people cilantro tastes like soap, I would hope I’m not the type of person to say there’s no good food in Mexico. I think this often happens when people come into contact with American Drip style coffee. If I gabbed a coffee at a bodega I’m not going to value it in the same way I would a single origin, small batch roasted coffee at an independent cafe. At a bodega I would add a bit of cream and maybe a dash of sugar. It’s a totally different beast because of the utilitarian aspect than the fine wine of a single origin drip. That drip would have totally different qualities if you grind it finer and use it in a latte.

Try it, You Might Like It – Practice, Practice, Practice

The last thing which I might consider, if I don’t understand or like the thing I’m starting to taste, is the acquired taste aspect. Sometimes you have to smoke several pipes to understand the subtleties of tobacco. I wasn’t a huge fan of Armagnac when I first tried it but after my fifth time trying it it grew on me. There’s a lot of scientific evidence to suggest that we can and will learn to like things of we only try, weather it’s with cigars, brandy, or spiciness of chili peppers. So, there’s a lot of relativity to trying new things. The only way to truly understand if there is “good” food or drink in a culture is to humble yourself, keep an open mind, and try different samples for comparison. The Buddhist have a practice of meditation when they eat. Leave the rest of your mind and meditate on your next meal with each bite and sip.

Practice, practice, practice!  Photo courtesy of The Larder, 09/17/2010

Practice, practice, practice!
Photo courtesy of The Larder, 09/17/2010

Like many things we appreciate in life, I feel that tasting comes with patience, awareness, and knowledge. The ability to leave our comfort zone to partake in and appreciate others’ cultural traditions and subtleties and to keep an open mind that what we are about to experience may be our next favorite thing or, if not at that grand of a scale, definitely makes our scale of evaluation standards a little more robust for our next tasting.


I’d like to invite all of you to apply this method of thinking to when you eat cheese.  So many people eat cheese and simply think “This is good.  It tastes like cheese.”  I challenge you to recall to the last cheese you ate and compare what you’re eating to that previous one – and remember the cheese you’re eating now to apply to comparison to future cheeses you will eat.  Like different styles or methods of preparing coffee, cheese is the same.  Approach with an open mind and you world can and will open up.


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Vermont Cheesemakers Festival

Hello, Everyone —

This past Sunday I was up at Shelburne, VT at Shelburne Farms for the Vermont Cheesemakers’ Festival.  We packed up the Tobasi, Maggie’s Round and Maggie’s Round Reserve, and Town Meeting and took the 3 hour drive north on route 7 to eat and talk cheese.



We set up our table and cut samples for 1500 tasters!

When I got the chance, I left the farm table and took a walk around the festival…


Will O’ Wisp from Fairy Tale Farm in Bridport, VT, had a very similar taste to our Maggie’s Round – both were unpasteurized cows milk natural rind cheeses and both have a pretty tart flavor. But while Maggie’s Round tartness lingers on the tongue, Will O’ Wisp mellows out in the finish. When I commented on the flavor, I was told, very proudly, that what causes that mellow, delicious finish is because the cheese is made from milk Ayrshire Cows (Cricket Creek is mostly Brown Swiss).


Next, I stopped at the table of one of my favorite dairy farms, Twig Farm. I knew I loved their Goat Tomme and Square Cheese, but I had to ask about their washed rind. I was curious as to how the paste of their cheese stayed so firm while that of our washed rind cheese, Tobasi, was like pudding. I was told that “It’s all about monitoring the pH to control the bacterial breakdown of the paste.” Effects of pH on paste breakdown is something that I’ve been learning intimately while apprenticing. The curd is hand cut for a half hour and the pH is watched over several hours until the target of a pH of 5.1 is reached. A labor of love with splendid results!


Next, I went looking to try to try the newest cheese from Parish Hill Creamery but was told I’d have to wait until November. However, I got another treat with their West West Blue. A two-curd cheese that is made by making curd, letting it acidify over night, and then mixing it with the next day’s warmer, less acidic curd. I have never heard of such a process but it sure produced some tasty results!


I also had the pleasure of talking with the folks at Cherry Grove FarmDiscussed the FDA’s recent flip-flop with wooden aging boards with Woodcock Farm (and exactly how they flip their Timberdoodle!) I caught up with my prior bosses and said hello to CheeseNotes and owner of Flora Artisanal Cheese in Charlottesville, VA and two-time second place winner of The Cheesemonger Invitational.

A wonderful time, I got to taste a lot of delicious cheeses, talk to some really great people and of course, encourage others to taste cheese from Cricket Creek Farm and answer questions and education others about cheese!

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Cheesemonger Invitational/ NYC Fancy Food Show

Hello everyone,

I admit that sometimes I wonder if I made the right decision leaving my cushy office job for a job in cheese.  The last weekend in June reinvigorated my passion for the systematically spoiled and aged milk product through the Cheesemonger Invitational and all of the people who came into New York City for the Fancy Food Show.

Kris and I at CMI

Kris and I sharing celebratory hugs and beers at the Cheesemonger Invitational, 2013

Although I had to work the day of the Invitational, I made it out for the last hour to grab a couple beers and see my good friend and coworker stand on stage as one of the “top ten cheesemongers in the country.”  Congratulations to the top three – All from south of the Mason Dixon line! And a big congrats to the top ‘monger – Justin Trosclair from the St. James Cheese Company in New Orleans, LA.

(Justin tells Culture Magazine why domestic cheeses can be so expensive in this article.)

52 cheesemongers competed in three battles (1)a blind taste test – to identify the milk type, age, pasteurization status, country of origin, style/type, and if possible name; (2) an exam; and (3) a “plate your slate” where cheesemonger selected a cheese from a list provided and asked to create the most delicious and appealing pairing of the cheesemonger’s choice with use of honeys, jams, pickles, crackers… one contestant even used pop rocks!

The top ten proceeded on to another 4 rounds of selling (my friend was judged by LeMunier on his salesmanship of gruyere to LeMunier!) , wrapping, cutting a perfect quarter, third, and half pound a wedge off of a wheel of cheese (within 2/10ths of a pound), creating a pairing on the fly, and a 60 second oration of why you became a monger combined with your favorite cheese and why.

Here’s a promo video from the 2012 battle – I was told by my friend that Adam’s pep talk to the contestants before the battle begun was one of the most inspiring and that he’s never felt so enthusiastic about a job.  He came to the contest as a ‘monger, and when the evening was over, he walked away a raw milk rockstar!

And it wasn’t just the Larkin cold storage facility that was packed with people.

People were coming in and out of the cheese shop all weekend.  Because the Cheesemonger Invitational and the NYC Fancy Food Show were happening at the same time, Rudolphe Le Munier stopped in to say hello and the shop held a panel of affineurs of cheeses carried through Formaggio Essex – Philippe Goux, affineur of Marcel Petit comte, Betty Koster, owner of L’Amuse goudas; Manuel Maia, premier exporter of Portuguese cheese, and Jose Luis Martin, affineur of Manchego.

Goux in the shop.  I seized this opportunity to tell him that his 16 mo. aged Marcel Petit Comte' was the cheese that inspired me to become a cheesemonger.

Philippe Goux in the shop. I seized this opportunity to tell him that his 16 mo. aged Marcel Petit Comte’ was the cheese that inspired me to become a cheesemonger.

Sue Conley and Peggy Smith of Cowgirl Creamery stopped in to see the shop as well as the folks from Cabot and others associated with other cheese shops from around the country.

It was a thrilling event to speak with all of these successful people in the cheese business, I admit, and the air was simply electric!  Although I didn’t get a pep talk directly from Adam Moskowitz, I just felt pretty damn proud to be a cheesemonger.

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Cheesy Colorado

Hello, gang.

I have been working on a post about veggie rennet – that extracted from the species Cynara cardunculus, mainly – and its specific milk curdling enzymes, cardosins A and B… however, it proved to be very difficult to find information about where the enzymes break the kappa-casein – if that is even how the situation works.   I have a lot of cultural information, but am lacking in scientific information.

So, I will postpone that particular blog and in the mean time, put together a cultural blog of my own of my trip to Colorado this past April.  Enjoy!

My sister, brother-in-law, and niece were all very kind to oblige to go on a tour of the cheesemaking facilities of Haystack Mountain Goat Dairy in Longmont, Colorado.

We carry a couple of their cheeses in the shop – Sunlight and Queso di Mano.  I had to go and visit to meet the creators of these delicious cheeses and find out what more they had to offer.  John, our tour guide was wonderfully knowledgeable and extremely friendly – and a native New Yorker!

Cheesemaking facilities at Haystack Dairy

Here is a worker draining the cheesemaking vat.   Milk is trucked in from a nearby goat farm and is curdled and cut in the large, rectangular stainless-steel vats.   After the curds are placed into the hoops, molds, or forms (the plastic containers that give the cheese its shape), a faucet at the bottom of the vat is opened and the whey is taken to a large plastic container outside.

Sunlight (larger forms in back) and Red Cloud (smaller forms in front)

Sunlight is a 6-pound washed rind cheese, a 2008 American Cheese Society and World Cheese Award winner, it’s recipe is taken from it’s smaller predecessor,  Red Cloud which won awards at the American Cheese Society in 2007, 2008, 2009, 2010, 2012, and the World Cheese Awards in 2008.

My sister and niece enjoying the cheese tasting at the end of the tour.

My sister and niece enjoying the cheese tasting at the end of the tour.

The cheesemakers  graciously allowed us to have our cheese tasting in their lunch room/ kitchen.

I supported Haystack Mountain by purchasing a lot of cheeses that we don’t carry at the shop and bringing them back to share with my fellow cheesemongers.  Everyone had a different favorite!
The most fun was that John allowed me to purchase their alpine-style cheese, Wall-Street Gold although the milk type was unknown.  He did, however, track down Jackie, the cheesemaker, to find out what the type was – but to give the cheesemongers a little taste challenge, he wrote it down on a card in a sealed envelope.  John, everyone guessed right!

Haystack Mountain spread at work – Top to Bottom:  Mountain Peak, Snowdrop, Camembert, Lucky U IPA washed rind cheese, and mystery milk Wall Street Gold.

In the same town is a delightful little shop called Cheese Importers. The shop follows a dream to bring local, handcrafted cheese to their customers.  As is written on their website: “After 2 decades working in the natural food industry of the 60’s Lyman and Linda White began to see that people were becoming increasingly aware and conscious about food. The cheese industry like so many, was a traditional one that had fallen victim to over processing and mechanization. … Like many boot straps, Cheese Importers was started with little money and a lot of heart. The basic plan was to hand select and deliver natural and imported cheese to shops, café’s and co-ops along the Colorado front-range. We were also going to find and promote small local cheese makers.”

          I picked up a couple cheeses that I hadn’t tried before and a few issues of Cheese Connoisseur for some light reading on the flight home.

My report wouldn’t be complete without mentioned Cured – a great little shop in downtown Boulder, CO.

Part of the cheese case at Cured

Part of the cheese case at Cured

Cured is a beautiful space that sells domestic and foreign cheeses, high quality salami, pickles, and chocolates, as well as wine with a coffee shop inside of the space and tables and booths shared by both.

My niece and I shared a Chiriboga blue but I had purchased a Green Hill – a double cream camembert style cheese – from Sweet Grass Dairy – a wonderful dairy in southern Georgia really making a name for itself with its delightful cheeses!

After days of collecting cheeses, there was only one thing to do, but eat them!  A couple bottles of wine, fruits, chocolates, and homemade baby food doubling as some jam later… and once the baby was put to sleep, we had ourselves a casual pairing party.


Pairing Party

From Southern Georgia to Colorado, artisinal cheese is happening everywhere.

I am so glad I got a chance to do two of my favorite things in one week – spending time with my family and eating cheese!







Buon Appetito!

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The Ripening of a Camembert


Le Camembert,

The ripening process of cheese is very complex and involves microbiological and biochemical changes to the curd resulting in the flavor and texture characteristic of the particular variety.

Dairy fermentations involve microbial interactions at several levels.  These interactions lead to different microbiota playing their role in a succession important to the progress of the fermentation and the quality of the final product.  They take place in the form of complex interactions between the starter culture, yeast and microflora in mold-ripened cheeses

The Flora of Camembert Cheese

Although a considerable variety of molds and fungi has been observed on Camembert cheeses, a list of possibly twenty species would include those which were often found.  Among these are perhaps six species of Penicillium, two or three of Aspergillus, Geotrichum candidum (previously known as Oidium lactis)Cladosporium herbarum, one or two of Mucor, one or more of Fusarium, Monilia candida, and two species perhaps related to it, with the incidental occurrence of Acrostalagmus cinnabarinus, a Cephalosporium, various species of Alternaria, and Stysanus.  Besides these, yeasts such as Kluyveromyces lactis were found in large numbers and considerable variety in many cases.

We are just going to focus mainly on  P. camemberti and G. candidum whose mycelium development is responsible for the bloomy aspect of Camembert-type cheese.

Geotrichum candidum

It has been noted that G. candidum is abundant upon every brand of Camembert.  The wide genotypic and phenotypic diversity of Geotrichum candidum strains…[and] G. candidum possesses many different metabolic pathways that are of particular interest to the dairy industry. G. candidum is of importance in the maturation of cheese, and much is known about its direct contribution to cheese ripening and flavour formation.  Its diverse metabolic potential means that G. candidum can play an important role in the ripening of many soft and semi-hard cheeses and make a positive contribution to the development of taste and aroma. It may also influence the growth of other microorganisms, both valuable and detrimental. The significance of the presence of G. candidum in cheese depends on the particular type of production and on the presence of biotypes featuring specific types of metabolism.  However, in situ metabolic pathways involved in cheese ripening and their regulations are mainly unknown (Boutrou, Guéguen)

Penicillium camemberti

The comparison of the results  by a 1906 study done by  Charles Thom, mycologist in Cheese Investigations in the Dairy Division of the Bureau of Animal Industry, showed that a single species of Penicillium was present upon every Camembert cheese that was examined and in partially ripened cheeses this mold often covered the majority of the cheese surface.  This mold is known as “Penicillium Camemberti” or the “Camembert mold.”  This species develops a large and characteristic growth of aerial mycelium in addition to a densely felted mass of white threads which penetrate the surface of the cheese for 1 or 2 mm. and largely constitute the rind.

During aging, Geotrichum candidum and yeasts grow initially, but they are soon followed by a dense growth of Penicillium camemberti:

Microbial count on acidified potato dextrose agar medium (pH 3.5) of the K. lactis LMA-437 (●), G. candidum LMA-436 (□), and P. camemberti (▲) ripening culture.

Salts migrating to the rind

Salts are ionic compounds that result from the neutralization reaction of an acid and a base.  Both lactate, from lactic acid, and Calcium (Ca) and Phosphate (PO4)  are defined in chemistry as salts.  P. camemberti and G. candidum oxidatively metabolise lactate to CO2 and water, deacidifying the cheese surface and resulting in a higher pH at the rind of the cheese.   This deacidification causes a pH gradient to develop from the center of the cheese to its surface and this established pH gradient of decreasing values towards the center of the cheese causes lactate to migrate towards the surface where it is used as a carbon source by P. camemberti.   As the cheese continues to age and the microbes continue to metabolize, pH increases to about 7.0 in the outer part of the cheese and about 5.5 in the centre.  The change of pH is most pronounced on the surface of the cheese, which is covered by the white mycelium of the P. camemberti after a week of maturation.  When lactate becomes depleted, casein, a milk protein, is then metabolised.

Calcium phosphate, found in high quantities in or on the casein micelles, is also soluble in acid environments, and as the pH of the surface of the cheese decreases, calcium phosphate migrates towards the surface of the cheese, where it then precipitates as a layer of Ca3 (PO4)2.  This migration results in a calcium phosphate gradient from centre to surface and  the depletion of calcium phosphate in the center of the cheese assists in the development of the desired soft texture of the cheese.  Reduction in the concentration of calcium phosphate, together with increased pH and proteolysis (the breakdown of proteins – casein proteins in this case) results in softening of the interior, which is characteristic of mature Camembert-type cheese.

Further metabolisation of casein results in the formation of ammonia from amino acids.  In very mature cheese, ammonia is produced at the surface from proteins and diffuses into the curd.  A cheese that smells very strongly of ammonia is extremely old and probably should not be eaten.

Enzymes migrating into the paste

The proteinases (enzyme that conducts proteolysis) from P. camemberti  migrate very slowly into the cheese, and only reach a depth of about 6mm from the surface.  This means that their direct participation in the enzymatic reactions deep in the interior of the cheese is limited.  The important enzymatic activities in the interior of the cheese are caused by the enzymes from the rennet, the plasmin from the milk and enzymes from the lactic acid starter cultures.

Final Thoughts

The French have been producing Camembert cheese for hundreds of years.  The creamy consistency and delicious, earthy flavors (flavor chemistry is a post I hope to tackle soon) all result from ambient fungi.  While it is true that some cheesemakers spray the necessary fungi on their cheeses in the aging caves, there are still many that allow the fungi to settle naturally  to ripen the cheese.  It is interesting to me – and I hope I have enlightened you as well – about what you’re eating and the relationship between you and the fungi on the cheeses you love.   The research on cheese microflora continues today – there are many studies and unanswered questions.



Marie-Hélène Lessard,  Gaétan Bélanger, Daniel St-Gelais, and Steve Labrie. The Composition of Camembert Cheese-Ripening Cultures Modulates both Mycelial Growth and Appearance. Appl Environ Microbiol. 2012 March; 78(6): 1813–1819.  doi: 10.1128/AEM.06645-11   last accessed: 11/16/2012

Paul L. H. McSweeney, Biochemistry of Cheese Ripening, Vol 57, No 2/3 May/August 2004 International Journal of Dairy Technology.   Dept. of Food and Nutritional Sciences, University College, Cork, Ireland.  last accessed: 11/16/2012

Charles Thom. Fungi in Cheese Ripening: Camembert and Roquefort. U.S. Department of Agriculture, Bureau of Animal Industry, Bulletin No. 82. 1906. last accessed: 11/16/2012

Herbert William Conn. The Camembert Type of Soft Cheese in the United States. U.S. Department of Agriculture, Bureau of Animal Industry, Bulletin No. 75. 1905

Karl Esser, ed. The Mycota: A Comprehensive Treatise on Fungi as Experimental Systems for Basic and Applied Research: Industrial Applications X, 2nd ed. Dec 1, 2010

Boutrou R, Guéguen M. Interests in Geotrichum candidum for Cheese Technology Int J Food Microbiol.  2005 Jun 25;102(1):1-20.

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Creation of the ‘Pasteurization or 60 Day’ Regulation

Okay, let’s get to what we came here for

History of Milk Pasteurization in the U.S.

The pasteurization or aging of cheese was not regulated in the U.S. until 1949.  Before then, there were only few preexisting standards by the FDA – standards of identity for only three American varieties of cheese – cheddar, colby, and washed curd and soaked curd cheese – were essentially quality control measures dictating milkfat content and production methods that contained no reference to pasteurization or aging.

Prior to WWII, production in the American cheese industry was very similar to the practices found in Europe.  Cheese manufacture was confined to smaller farms which drew on local milk supplies.  It was not until cheese manufacturing was made at such a large-scale industrial process that milk from many dairy farms from multiple states was needed to enter the cheese production facilities.  It was this interstate shipment and combining milk sources that put milk-safety in danger.  The FDA had to acknowledge the dangers of the new cheese production procedures and in response, instituted pasteurization and aging requirements.

On February 21, 1947, the FDA first revealed its concern for pasteurization and aging in a Notice of Hearing for the adoption of several dozen new standards of identity. Without discussing its reasons, the agency proposed to modify the three existing standards and to have all of the new standards require either aging or the use of pasteurized milk in manufacturing.  The final rulemaking release from April 22, 1949, offered the FDA’s rationale for the standards of identity which survive to this day:

“Consumers expect, and have a right to expect, that manufacturers of cheese shall take reasonable precautions to render the finished cheese safe for human consumption. Under present conditions reasonable caution on the part of manufacturers of cheese intended for human consumption without further processing requires that the milk used be pasteurized, or in the alternative that such cheese, after manufacturing, be held for a period whereby it can reasonably be expected that it will be safe for human consumption. It will promote honesty and fair dealing in the interest of consumers to include in the definition and standards of identity of the different varieties and classes of cheese requirements that the milk used be pasteurized or the cheese held for a period whereby it may be reasonably expected that the cheese will be rendered safe. Based on the best evidence available now it is reasonable to require that when the milk used in manufacturing cheese is not pasteurized the cheese be held after it is manufactured for not less than 60 days at temperatures of not less than 35◦F.”

The FDA’s strong concern for consumer expectations of safety led it to set the aging requirement at 60 days with very little scientific evidence to support such a specific duration regardless of cheese variety.  In its rule-making release, the agency admitted as much:

“Viable pathogenic microorganisms in cheese, even when present to such an extent as to be capable of causing disease in humans, tend to die when the cheese is held for some time at temperatures above 35◦F. It is not known with certainty how long cheeses must be held before they become safe. . . .No outbreak has been reported from cheese held 60 days or more.”

The Health Research Group of Public of Public Citizen petitioned the Secretary of the Department of Health and Human Services (HHS) to promulgate a regulation banning all sales, interstate and intrastate, of raw milk and milk products in the United States on April 10, 1984.  After a few months, the citizens’ group then filed suit in federal district court to compel HHS to promulgate such a rule.  The court ordered HHS to respond to the petition, finding that there had been unreasonable delay.  The Commissioner of Food and Drugs then denied the petition, forcing the Health Research Group to seek judicial review. This time, its request for relief also challenged the agency’s failure to terminate the stay of the 1973 regulation which had required pasteurization of fluid milk products through standards of identity.  In Public Citizen v. Heckler , the court ruled that the denial of the petition had been arbitrary and capricious, and ordered the FDA to institute rule-making procedures for a regulation banning the interstate sale of all raw milk and milk products.

And so, nearly three years later, on June 11, 1987, the FDA proposed a rule requiring mandatory pasteurization for all milk and milk products in final package form intended for direct human consumption.  The relevant portion of the rule was promulgated as originally proposed and is contained today in 12 C.F.R. §1240.61:

“No person shall cause to be delivered into interstate commerce or shall sell, otherwise distribute, or hold for sale or other distribution after shipment in interstate commerce any milk or milk product in final package form for direct human consumption that has not been pasteurized except where alternative procedures are provided by regulation, such as Part 133 of this chapter for curing of certain cheese varieties.”

The regulation applies to cheese as it applies to any other milk product and incorporates the standards of identity in 12 C.F.R. §133 for purposes of allowing certain cheeses to be aged at least 60 days instead of made from pasteurized milk.

However, it wasn’t until, academic researchers in South Dakota took on the experiment of bacteria survival on raw milk in 1995 and demonstrated that Esherichia coli O157:H7 (E. coli) bacteria could survive the 60-day aging period.  These results suggested that existing regulations were insufficient to protect consumers from pathogens and that all cheese, whether fresh or aged over 60 days, should be made from pasteurized milk.  Three years later, a trade group consisting of large-scale manufacturers of both specialty cheeses and process cheeses created a compilation of such relevant studies and contacted the FDA.

That same year, the FDA announced that it would research whether pathogenic bacteria contained in raw milk cheese could survive the 60-day aging period.  Such a discovery would justify a complete ban on interstate sales of raw milk cheese, making the current regulations even more restrictive.  The FDA’s studies were funded by former President Clinton’s Food Safety Initiative and conducted by government researchers at the National Center of Food Safety and Technology in Chicago.

In summary, the studies found that in the event that 60-day aging is found to be inadequate to provide the appropriate level of public health protection, an evaluation of alternative control measures would assist the agency in the development of policy in this area. Validation of the effectiveness of current or alternative process control measures used in the manufacture of aged hard cheese would result in a greater assurance of a safe food supply and enhanced public confidence in these products.

However, the controversy was not finished yet.  Catherine W. Donnelly, a professor in food microbiology at the University of Vermont, conducted an independent review of the FDA study as well as the 1995 South Dakota study.  Donnelly found two critical flaws in the design of the 1995 South Dakota study of E. coli: (1) the researchers had injected strains of E. coli into cheddar samples made from pasteurized milk, and (2) the samples were injected with several thousand times more bacteria than could realistically enter cheese during the manufacturing process.

The first design flaw meant that E. coli bacteria were never exposed to lactic acid during fermentation, as would normally happen in manufacture of cheese from raw milk. The high acidity that occurs naturally in the cheese making process helps kill pathogens. The second design flaw meant that the South Dakota study might have produced overly pessimistic and alarmist results.

Publication of Donnelly’s independent research and activism by the Cheese of Choice Coalition produced sufficiently negative publicity that the FDA’s review lost its priority status in 2002.

As of when the referenced document was published, the FDA’s results, scheduled for release in September of 2002, have not been released.

Next Posts: Pushback from Artisinal Cheesemakers

and What’s the Appeal of Raw Milk Cheese?


(1) Knoll, Laura P., Origins of the Regulation of Raw Milk Cheeses In the United States, April 26, 2005

This paper is submitted in satisfaction of the Food and Drug Law course paper and the Written Work Requirement at Harvard Law School.