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FDA on the war path against raw-milk cheese, again


StevenC
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i wonder what the driver is behind changing the 60 day rule, which seems to be working quite well........

i almost wonder if insurance companies aren't involved somewhere seeing as they are writing all the product liability policies for the artisinal/farmstead cheese industry........

well written article.......

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i wonder what the driver is behind changing the 60 day rule, which seems to be working quite well........

The website of the Raw Milk Cheesemakers Association cites a number of studies showing the possibility of making cheese with raw milk safely.

If the FDA does go the full extent and bans all raw-milk cheese, including Parmigiano-Reggiano and Roquefort, one hopes that the EU would file suit at the World Trade Organization, the same method that the United States used to force Europeans to swallow our hormone-laced beef.

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I'm not sure the EU is going to be much help. In general, the EU as a governing body is in favor of more stringent pasteurization requirements. Public opinion in Europe may oppose that, and individual EU nations' governments -- especially those of France and Italy -- may oppose it too, but the EU as a body is right there with the US government in being an enemy of unpasteurized cheese.

I'm not sure the article cited really establishes a new FDA push against unpasteurized cheeses, though. What the article seems to indicate -- though quite speculatively -- is that brie-type cheeses may be at risk of tighter regulation under a new set of "risk profiles." These cheeses have always been the borderline cases. I doubt they're going to be able to establish risk for hard cheeses, though.

While it's worth fighting the fight for unpasteurized cheese, the reality may very well be that pasteurization is the inescapable future. So it may make sense for producers and consortium-type groups to follow the example that some of the French companies are setting, by devoting their resources to figuring out ways to make great cheeses with heat-treated milk.

Steven A. Shaw aka "Fat Guy"
Co-founder, Society for Culinary Arts & Letters, sshaw@egstaff.org
Proud signatory to the eG Ethics code
Director, New Media Studies, International Culinary Center (take my food-blogging course)

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ironically you can have lysteria and other pathogenic contamination with pasturized milk.....so it's not goof proof, you still have to be pretty damn careful with your plant design, sanitation, and make process......

having been involved first hand in the farmstead cheese business for about four years i can say that it's TOUGH........

i'm a bag of mixed emotions when it comes to international cheese trade, hippies, slow food, lesbians, gays, country of origin labeling, astrology, numerology, and a host of other issues that interest me but are out of my sphere of influence.........

i know some of the people in the raw milk cheesemakers, i find it hard to belive they'll hold back the winds of change, nor will their european counterparts, who may be romanticized by a few, are unknown by the remainder........

raw milk cheese will become an element from history, and at first it will be missed by many, then a few, then by none.......

these people are not getting fabulously rich in the aritsan cheese industry, even the most successful can't really brag in a room about their wealth...

for instance, sid cook, carr valley cheese, hugely successful at handcrafted cheese, where does he make his money??? commodity cheese.......

i heard it from the man himself..all this other stuff, is just stuff.....

i hope i'm wrong........

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I hate the FDA....

I wish food inspection would at least be extended to some privately owned agencies that don't freak out and put outrageous bans and regulations on everything. I would even think that they would do better than the FDA considering they probably have expert knowledge compared to the bureaucrats in Washington.

Eh I hate getting political, but it's just that I've been doing some research, and it seems like situations like these just prove that government departments like the FDA just get in the way of our freedom to just enjoy life because of their "nanny" mentality. I actually was researching about the "Small farms" movement to allow farmers to provide localized, fresh organic produce instead of garbage they sell at supermarkets, and I ran into an amazing speech by a man named Ron Paul at Farm Food Voices (he's actually running for president I think). Farm Food Voices is a small farms lobby group. Anyways, it seems as if the ideas he expresses tends to reflect on this current, sad situation.

Here's the video if anyone wants to watch

Edited by takadi (log)
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I wish the FDA would spend more time investigating food coming in from China than worrying about local cheeses!

*****

"Did you see what Julia Child did to that chicken?" ... Howard Borden on "Bob Newhart"

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I hate the FDA....

I wish food inspection would at least be extended to some privately owned agencies that don't freak out and put outrageous bans and regulations on everything.  I would even think that they would do better than the FDA considering they probably have expert knowledge compared to the bureaucrats in Washington.

Eh I hate getting political, but it's just that I've been doing some research, and it seems like situations like these just prove that government departments like the FDA just get in the way of our freedom to just enjoy life because of their "nanny" mentality. I actually was researching about the "Small farms" movement to allow farmers to provide localized, fresh organic produce instead of garbage they sell at supermarkets, and I ran into an amazing speech by a man named Ron Paul at Farm Food Voices (he's actually running for president I think). Farm Food Voices is a small farms lobby group. Anyways, it seems as if the ideas he expresses tends to reflect on this current, sad situation.

Here's the video if anyone wants to watch

You're entitled to hate the FDA as much as you like but consider this.

In general, in the US, you can go into a supermarket and buy food items and feel pretty confident that you're not going to contract tuberculosis or listeria or cholera or experience botulism poisoning if you eat them. Check out this book http://www.amazon.com/Protecting-Americas-...n/dp/037540466X if you want to see what life was like pre-FDA.

Does the system fail at times and people get sick from Hepatitis A from scallions or E coli from spinach? Hell yes. But, consider how much more frequent it would be if not for the "nanny" overbearing FDA.

I am willing to pay the "price" of being denied raw milk cheese in order to have some peace of mind that I am unlikely to contract a bad food-borne illness.

I don't love the FDA but they perform a useful function. And with regard to having private companies perform food safety surveillance instead of bureaucrats...who's going to oversee them to make sure they're not being bought off? Congress has and exercises considerable oversight of FDA.

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I'm not sure it's any more difficult to buy off government bureaucracies than it is to buy off private corporations, however it's beside the point. The reality is that there's no reason we have to trade the right to food choice for the privilege of safe food. Because raw-milk cheeses are not dangerous. All we have to do is look at Europe to know that. Even were raw-milk cheeses potentially dangerous, like pretty much every food (eggs, chicken, fish), the answer would be to ensure that the producers follow rational safety guidelines -- because, again, we know that raw-milk cheese can be produced safely. An outright ban is not the logical response in that situation. And at the most basic level, even if there is a small risk from these products, the choice could simply be made clear, just as it's made clear with cigarettes, alcohol, etc.

Steven A. Shaw aka "Fat Guy"
Co-founder, Society for Culinary Arts & Letters, sshaw@egstaff.org
Proud signatory to the eG Ethics code
Director, New Media Studies, International Culinary Center (take my food-blogging course)

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I'd prefer a labeling option.

'Warning - the surgeon general has determined that there is risk of contracting blahdeblah from consuming raw milk products', and then requiring 'raw milk product' to be somewhere in large bright green letters on the package front.

Those who dont know or care about raw milk cheeses will be put off and not buy, but they dont anyway I suspect. Those who want raw milk cheese already know this and will buy regardless. The visibility this will cause will be all it takes to ensure hypervigilance on the part of US manufacturers.

"You dont know everything in the world! You just know how to read!" -an ah-hah! moment for 6-yr old Miss O.

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I'm not sure it's any more difficult to buy off government bureaucracies than it is to buy off private corporations, however it's beside the point. The reality is that there's no reason we have to trade the right to food choice for the privilege of safe food. Because raw-milk cheeses are not dangerous. All we have to do is look at Europe to know that. Even were raw-milk cheeses potentially dangerous, like pretty much every food (eggs, chicken, fish), the answer would be to ensure that the producers follow rational safety guidelines -- because, again, we know that raw-milk cheese can be produced safely. An outright ban is not the logical response in that situation. And at the most basic level, even if there is a small risk from these products, the choice could simply be made clear, just as it's made clear with cigarettes, alcohol, etc.

A Medline search for "raw milk cheese safety" brings up a couple of interesting references:

Almeida G, Figueiredo A, Rola M, Barros RM, Gibbs P, Hogg T, Teixeira P. Microbiological characterization of randomly selected Portuguese raw milk cheeses with reference to food safety. J Food Prot. 2007 Jul;70(7):1710-6.

Caro I, Garcia-Armesto MR. Occurrence of Shiga toxin-producing Escherichia coli in a Spanish raw ewe's milk cheese. Int J Food Microbiol. 2007 May 30;116(3):410-3. Epub 2007 Mar 6.

Here's an excerpt from the Almeida abstract: "Twenty-two of the 70 cheeses were classified as satisfactory or acceptable. Thirty-seven of the cheeses were considered unsatisfactory because of the presence of E. coli, S. aureus, or both, while 11 of the cheeses were graded as unacceptable and potentially hazardous because of the presence of excessive numbers of S. aureus, E. coli, or L. monocytogenes and the presence of Salmonella in three of these." So, I'm not sure that the assertion that raw milk cheeses are not dangerous is scientifically justified.

A raw milk cheese is different from an egg, both of which are known to harbor Salmonella. Firstly, the rate of Salmonella in eggs is ~1 in 30,000, not 3 in 70 (11/70 if you count the other pathogents) like the Almeida study found.

Second, most eggs get cooked. The gummint would rightly think that we would eat a raw milk cheese without cooking it.

Edited by mojoman (log)
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But to write off an entire food because of its risk factors? I don't think that merits the FDA to put a total ban on it. Every food has risk factors, but that's our personal responsibility to decide whether to eat it or not based on those risks. A label would be more than sufficient

As for the FDA itself, don't get me started on the pharmaceutical industry and the massive subsidies loaned out to big farming corporation. But that's an entirely different topic =) Let's talk about cheese

Edited by takadi (log)
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Here's an excerpt from the Almeida abstract: "Twenty-two of the 70 cheeses were classified as satisfactory or acceptable. Thirty-seven of the cheeses were considered unsatisfactory because of the presence of E. coli, S. aureus, or both, while 11 of the cheeses were graded as unacceptable and potentially hazardous because of the presence of excessive numbers of S. aureus, E. coli, or L. monocytogenes and the presence of Salmonella in three of these." 

The question is: are people in the real world getting sick from eating these cheeses? If the answer is no then who cares what some study classifies as "satisfactory"? And in the case of the Almeida study, it also says, "All cheeses graded as unacceptable and potentially hazardous were soft or semisoft cheeses made with ewe’s and goat’s milk, with the exception of two hard cheeses made with cow’s milk. E. coli O157 was not detected in any of the cheeses." The soft and semisoft cheeses are already illegal in the US. In addition, we have no basis for comparison to pasteurized cheeses. What percentage of those cheeses have harmful microbes present, and in what quantities? Without that relative measure, the findings are not meaningful.

The concern that studies like this Almeida study present is that policy will be made on the basis of theoretical "risk profiles" rather than real-world impacts. Once you go down that path, you can find a reason to outlaw just about any food -- especially if that food doesn't have a well-funded lobby behind it.

Steven A. Shaw aka "Fat Guy"
Co-founder, Society for Culinary Arts & Letters, sshaw@egstaff.org
Proud signatory to the eG Ethics code
Director, New Media Studies, International Culinary Center (take my food-blogging course)

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The concern that studies like this Almeida study present is that policy will be made on the basis of theoretical "risk profiles" rather than real-world impacts. Once you go down that path, you can find a reason to outlaw just about any food -- especially if that food doesn't have a well-funded lobby behind it.

i agree 100%... so these risk profiles are a concern of whom???

let's try lending institutions and insurance companies...for the win.

you cannot operate a business w/out some borrowed capital and you cannot borrow money without showing proper insurance. if you are operating a cheese making plant, running a dairy, or buying a car, you're gonna have to have insurance. hence the risk profile.

you can win the fight with the fda but still get dropped by your insurance carrier...

do you still want to sell raw milk cheese w/out any product liability insurance....

you can, but your banker wont be very receptive to the idea, as in cut off your line of credit, maybe call in your notes........

those realities are pretty far removed from the romantic notions of a bottle of wine, hand made cheeses, and a picnic lunch with a beautiful french girl.........

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Here's an excerpt from the Almeida abstract: "Twenty-two of the 70 cheeses were classified as satisfactory or acceptable. Thirty-seven of the cheeses were considered unsatisfactory because of the presence of E. coli, S. aureus, or both, while 11 of the cheeses were graded as unacceptable and potentially hazardous because of the presence of excessive numbers of S. aureus, E. coli, or L. monocytogenes and the presence of Salmonella in three of these." 

The question is: are people in the real world getting sick from eating these cheeses?

1. I did not see any epi studies that would inform to this pertinent question. Do you have any references for any well conducted studies that show no excess morbidity? I think that would be a hard study to conduct because of the omnivorous nature of humans. With the myriad of things people eat, such a study would likely be excessively confounded. 2. Absence of evidence does not constitute proof that an association does not exist. That is a basic scientific principle. If two people take rofecoxib (Vioxx) and don't get heart attacks, does that mean that rofecoxib does not cause heart attacks? Maybe it does or maybe that "study" was flawed and does not adequately inform.

If the answer is no then who cares what some study classifies as "satisfactory"?

A concurrent control is always the best way to conduct hypothesis testing. However, I suspect that the definiton of "satisfactory" was based upon innoculum size. For most pathogens, the number of viable organisms necessary to cause clinical disease is known. For instance, IIRC, one Shigella organism will give you Shiggelosis. Those data were probably the basis for dichotomizing into satisfactory or not.

The concern that studies like this Almeida study present is that policy will be made on the basis of theoretical "risk profiles" rather than real-world impacts. Once you go down that path, you can find a reason to outlaw just about any food -- especially if that food doesn't have a well-funded lobby behind it.

Because of the difficulties of conducting a epidemiologic study that could inform to the effects of raw versus pasturized milk cheese eating in a scientifically valid manner, shouldn't we base our public health decisions on what scientifically valid data we do have, even if we have to extrapolate?

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all of this unpleasantness has convinced me to go downstairs to the grocery store and pick up some of this week's special: Fourmette Croix de Chazelles: raw cow milk blue cheese from Auvergne...and enjoy the danger while I still can.  :wink:

stick around it's gonna get better.......

we haven't even broached the "save the small farmer" topic yet........

it's one of my all time favorite debates.........

mostly because you can't win it, and you can't lose it either.....

if you do go to the store, pm me a wheel of that blue......

thanks in advance

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Mojoman, the CDC often concludes that a given outbreak, or a sporadic case, was due to a specific food product. Otherwise how would we know that spinach caused a given outbreak? However, there doesn't seem to be any sort of frightful body of evidence to indicate that raw-milk cheeses are a problem. Indeed, the two major instances I've read about were attributed not to unpasteurized milk but to post-production contamination of pasteurized milk. In addition, in the literature there is discussion of the "Jamison effect," which is the proposition that the beneficial microbes in unpasteurized cheese can help protect against post-production contamination, whereas those beneficial microbes are killed by pasteurization.

The question of acceptable level of bacteria is one that's not so easily summed up as "the number of viable organisms necessary to cause clinical disease is known." Especially when "All cheeses graded as unacceptable and potentially hazardous were soft or semisoft cheeses made with ewe’s and goat’s milk, with the exception of two hard cheeses made with cow’s milk. E. coli O157 was not detected in any of the cheeses." And clinical disease in what population? Newborns and the elderly? That's not relevant because those people can be told to stay away from certain foods, just as they're currently told to stay away from raw oysters. In addition, the findings in the study don't even cross the threshold of common sense. If 11 of 70 raw-milk cheeses (almost 16%) have enough organisms to cause clinical disease, then why aren't Portugal's emergency rooms flooded with food-poisoning cases?

We do need to extrapolate from scientific data when making policy, however we have to be certain that the data are as complete as we can possibly make them, and we need to extrapolate in a meaningful, sensible way. We still need to know the risks from pasteurized cheeses. We still need to know if there are any actual outbreaks associated with raw-milk cheeses, and how they compare in number to outbreaks associated with pasteurized cheeses. Then we need to ask whether, assuming the truth of the extrapolated scenario, a ban is the answer, or whether there are less intrusive mechanisms available: production safeguards, testing, inspection, warning labels, etc.

Steven A. Shaw aka "Fat Guy"
Co-founder, Society for Culinary Arts & Letters, sshaw@egstaff.org
Proud signatory to the eG Ethics code
Director, New Media Studies, International Culinary Center (take my food-blogging course)

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Mojoman, the CDC often concludes that a given outbreak, or a sporadic case, was due to a specific food product. Otherwise how would we know that spinach caused a given outbreak? However, there doesn't seem to be any sort of frightful body of evidence to indicate that raw-milk cheeses are a problem. Indeed, the two major instances I've read about were attributed not to unpasteurized milk but to post-production contamination of pasteurized milk. In addition, in the literature there is discussion of the "Jamison effect," which is the proposition that the beneficial microbes in unpasteurized cheese can help protect against post-production contamination, whereas those beneficial microbes are killed by pasteurization.

The question of acceptable level of bacteria is one that's not so easily summed up as "the number of viable organisms necessary to cause clinical disease is known." Especially when "All cheeses graded as unacceptable and potentially hazardous were soft or semisoft cheeses made with ewe’s and goat’s milk, with the exception of two hard cheeses made with cow’s milk. E. coli O157 was not detected in any of the cheeses." How does this address my statement that the clinically significant innoculum size is known?  Check in any medical microbiology book.  These are accepted as fact.

In addition, the findings in the study don't even cross the threshold of common sense. If 11 of 70 raw-milk cheeses (almost 16%) have enough organisms to cause clinical disease, then why aren't Portugal's emergency rooms flooded with food-poisoning cases?  Totally valid point.

We do need to extrapolate from scientific data when making policy, however we have to be certain that the data are as complete as we can possibly make them, How do we know when we have enough data?  I don't know and neither do you but I hope that a regulatory agency with 100 years of experience would be able to make a better guess than you or me.

With the miniscule consumption of raw milk cheese in the US, I'm finding it hard to see how the absence of a CDC-verified outbreak, linked to raw milk cheese consumption, constitutes evidence that there is no problem. However, take a look at this reference (from the UK).

Kuusi M, Lahti E, Virolainen A, Hatakka M, Vuento R, Rantala L, Vuopio-Varkila J, Seuna E, Karppelin M, Hakkinen M, Takkinen J, Gindonis V, Siponen K, Huotari K. An outbreak of Streptococcus equi subspecies zooepidemicus associated with consumption of fresh goat cheese. BMC Infect Dis. 2006 Feb 27;6:36.

Six people had septicemia and one had purulent arthritis. Here are the author's conclusions: "CONCLUSION: The outbreak was caused by goat cheese produced from unpasteurized milk."

Here's a reference for an outbreak in Canada.

Honish L, Predy G, Hislop N, Chui L, Kowalewska-Grochowska K, Trottier L, Kreplin C, Zazulak I. An outbreak of E. coli O157:H7 hemorrhagic colitis associated with unpasteurized gouda cheese. Can J Public Health. 2005 May-Jun;96(3):182-4.

So, there are documented cases of outbreaks attributed to unpasteurized cheeses. I do not know how the incidence compares to that for pasteurized cheeses and one would have to normalize for quantities consumed to make a valid comparison.

I'm going to let this go here. I don't disagree with those who want raw milk cheese available...IF they understand the risks and want to take them. However, do you all really understand the risks?

You stated that "...raw-milk cheeses are not dangerous." (post #9). The references I've posted here show that raw milk cheese has been responsible for serious medical outcomes (purulent arthritis, hemolytic-uremic syndrome, hemorrhagic colitis). I'm pretty sure if you asked any of those patients, they would disagree that raw milk cheese is not dangerous.

Edited by mojoman (log)
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I wouldn't say the cheeses themselves are dangerous. That's like saying canned vichyssoise is dangerous because people died from botulism. Aside from that, I don't see how raw milk cheeses are any more dangerous than any other food if they are carefully and safely made

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If cheese from unpasteurized milk is no more dangerous than cheese from pasteurized milk, then I think that meets the definition of "not dangerous." Unless, that is, we want to use a definition that says all cheese is dangerous, and that all food is dangerous unless it can be established to be in a zero-risk category. I have no doubt that there have been illnesses caused by unpasteurized cheeses, but there have also been illnesses caused by pasteurized cheeses. In years of reading and writing about this subject I've seen nothing to indicate that, as a practical matter, unpasteurized cheeses are proportionately more dangerous than pasteurized. And there is at least some information out there indicating that unpasteurized cheeses are more resistant to post-production contamination. There's also the argument that pasteurization generates complacency and therefore encourages carelessness in other aspects of production.

I wouldn't call raw-milk cheese consumption in the U.S. "minuscule" -- not if we're including cheeses like Parmigiano-Reggiano in the count. And in the U.S., where we have the 60-day rule, there's no risk from young goat cheeses anyway.

I also have my doubts about the abstracts cited, and the value of making a policy leap from such incidents even if they've been evaluated correctly. Associating an outbreak with unpasteurized cheese is different than saying the outbreak wouldn't have happened if the milk for that cheese had been pasteurized. Post-production contamination remains a possible explanation, especially on a farm where the milking and cheesemaking are the responsibility of the same people. If, for example, a farm is filthy, the milkers don't use proper hygienic procedures, the entire staff is sick but nobody does anything about it, and the animals are sick too, then reducing that to a claim that unpasteurized cheese is dangerous is irrational. The problems lie elsewhere. Otherwise it's like saying that pasteurized cheeses are dangerous because sick workers handled them and spread disease that way.

I'll let this go now too.

Steven A. Shaw aka "Fat Guy"
Co-founder, Society for Culinary Arts & Letters, sshaw@egstaff.org
Proud signatory to the eG Ethics code
Director, New Media Studies, International Culinary Center (take my food-blogging course)

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if you can detatch yourself from the topic in terms of science, foodieism, and 1960's counterculture combined with old world nuance and pseudo sophistication........

imagine you are a risk ascesment analyst for a major insurance provider.....

your employers have told you to make a call on this topic.........

your company will then notify all policy holders and their lenders regarding carriers position based on YOUR recomendations......

what do you do?...

tell'em go for it these raw milk cheeses are the bomb, the 60 day rule is great....

tell'em hell we don't even need the 60 day rule, people in europe aren't dying, plus the stuff tastes great, AND as a bonus, we not only foster harmony with our fellow man, but we can single handedly revitalize the family farm........

or...tell'em this is a hot potato, and it's in our best interest to cancel policies to producers of raw milk product regardless of the fda decision. it's too easy to insure business' of lower risk, we should pursue new business and eliminate these policies from our portfolio.....

are the insurance muckity mucks thinking about the gorganzola they had in Italy while on 2nd honeymoons w/ wives???

or are they gonna think about their condo at the beach, the kids in college, and paying for their gf's boob job and tummy tuck .....

think about it, they don't care about thier own palate, let alone fat guy's...

they most likely wouldn't know the diff between a pice of emmental and kraft sliced swiss at the g- store........

follow the dollar...the decision will be made over cocktails and cigars. ....

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All the "controversy" around raw milk cheese drives me friggin' nuts!

Label it, then let me - THE CONSUMER - make up my own mind!

The USDA "lets" me buy raw fish, raw beef, veggies contaminated with human feces... and yet rules out my purchasing raw milk products?

If I'm immune-suppressed (I am) thats my business, and something I have to deal with - on my own terms, and with my own outcomes.

Jamie <--- cancer patient, and chemo warrior

Jamie Lee

Beauty fades, Dumb lasts forever. - Judge Judy

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  • 2 weeks later...

While it's worth fighting the fight for unpasteurized cheese, the reality may very well be that pasteurization is the inescapable future. So it may make sense for producers and consortium-type groups to follow the example that some of the French companies are setting, by devoting their resources to figuring out ways to make great cheeses with heat-treated milk.

It might be possible to make great cheeses with heat-treated milk, but that depends upon what you call "great". A great cheese to me would contain all the tastes and proportions of raw-milk, all the benefits, too, and, if you like, risks. So, I guess I would say it is NOT possible to make a great cheese with pasteurized milk.

Thinking out loud and circular here....

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