SUBJECTS

Cheese Regulation & Good Practice

Our mission is to inspire and educate individuals from all backgrounds, whether they are cheese enthusiasts or industry professionals, about the world of cheese.

101 guide – Cheese Regulation & Good Practice | Chapter one

What is Regulation and Good Practice?

Regulations around Cheese

Eating cheese is and should be an enjoyable experience. It can only be so, however, if the cheese you are eating or selling is safe for consumption. This is the criteria for all cheese producers and retailers, but one which is made harder when the main reason for foodborne illnesses are something that cannot usually be seen.

Food safety compliance is not an easy undertaking for any food business owner; it is full of rules and regulations, procedures and paperwork. But it needn’t be dreaded and most definitely should not be disregarded. The fate of any cheese business lies both in the quality, safety and reputation of its products.

What are Food Safety Agencies?

Pathogenic microorganisms that are responsible for foodborne illnesses live on the food you prepare as well as on the food handlers themselves. These microorganisms can then travel from one place to another and spread their potential to cause disease.

For these reasons, food safety agencies have been established to regulate the food industry, address these issues and minimise occurrences of outbreaks.

All regulatory bodies across the world have specific laws, code of practices, and guidance documents relating to the control of food stuffs. These cover all parts of the food production and distribution chain including:

Food production and processing,
Packaging and labelling
Importing and distribution
Retailing and catering

The main aim of food regulatory bodies is to protect public health and the interest of consumers. These bodies ensure that food businesses have clear, understandable, and workable regulations in place.

The number of policies and regulations relevant to a business will depend upon the nature and size of the company in question. A large multi-site cheese manufacturer, for example, will have large departments, training budgets and archived documents dedicated solely to the domain of Regulation and Good Practice, whilst a sole trading cheesemonger may only need to spend a couple of hours a week checking their procedures and paperwork are up-to-date and compliant.

In addition to regulatory bodies, there are various specialist cheese industry bodies, which have been set up by industry experts and technical committees to offer codes of best practice, such as the Specialist Cheese Makers Association (SCA) in the UK, the American Cheese Society (ACS), the New Zealand Specialist Cheese Makers Association and the Australian Specialist Cheese makers Association.

Which Laws are Relevant to Cheese?

The framework for UK national legislation is set out in the Food Safety Act 1990, though this has been amended to bring it in line with European law. The general requirements of European food law are described in Regulation (EC) 178/2002 along with three additional regulations which are often referred to as the ‘hygiene package’. These include:

Regulation (EC) 852/2004 which outlines the general hygiene requirements applicable to all food business operators and requires food safety management to be based upon HACCP principles. (link to section below)

Regulation (EC) 853/2004 which sets specific rules for foods of animal origin including the approval of such businesses. Rules for Raw milk, colostrum, dairy products and colostrum-based products are covered in this regulation, including criteria and testing frequencies, rules for transportation and storage of milk temperatures and rules around the raw milk from herds with tuberculosis or brucellosis.

Regulation (EC) 854/2004 which lays down rules on the organisation of official controls on foods of animal origin intended for human consumption.

All businesses are required to meet the minimum legislative requirements of these regulations and will be subject to inspection and subsequent approval to be operational. In the UK, enforcement of these regulations is principally carried out by Environmental Health Officers working for the local authorities. They work closely with the Food Standards Agency (FSA) and Food Standards Scotland.

What are Pathogens and why are they relevant to cheesemaking, cheese maturation and cheese storage?

Listeria monocytogenes: this is a pathogenic bacterium associated with food contamination during the production process, or with soil or faecal contamination at milk production level. Effects of contamination include fever, vomiting and diarrhoea. It can, in the most severe cases, cause an invasive infection that spreads around the body, causing death in 30% of cases. Due to this relatively high death rate and ability to grow, despite refrigeration, Listeriosis is recognised as one of the most significant hazards during the storage of cheese. Certain cheeses, such as fresh lactic cheeses, will not have the right conditions to support the growth of Listeria.

Salmonella: a member of the Enterobacteriaceae group of pathogens, Salmonella lives in the gut, and can contaminate during raw milk production or can be carried by asymptomatic food handlers. Whilst it is still a major pathogen, it is less prevalent than Listeria and will be killed off with pasteurisation.

Coagulase-positive Staphylococci (CPS): these are minor pathogens, associated with either mastitic infections in milking animals, or part of the natural skin microflora of food handlers. Whilst CPS causes vomiting and diarrhoea, it is generally a short-lived illness.

Shiga toxin-producing E. coli (STEC): STEC is an emerging pathogen associated with faecal contamination of raw milk used to make dairy products, though it is inactivated by effective pasteurisation. Illness may be caused by a low infectious dose and may result in serious complications including Haemolytic Uremic Syndrome (HUS), which may result in Kidney failure or death.

What is Cross-Contamination and what are the Hygiene Issues Surrounding Cheese Safety?

If a cheesemaker and retailer follow strict food safety procedures and have robust HACCP programmes in place, then their cheeses should reach the consumer free from pathogens. At this stage, the biggest risk then to human health is that which arises through cross contamination.

Cross contamination is the movement of harmful microorganisms and other pathogens that are spread unintentionally from the service area or equipment to the food being prepared. It is a way of spreading foodborne illnesses and can, potentially, cause an outbreak. Cross contamination can occur at any point in the food supply chain with several different routes, including:

Dirty hands
Contaminated equipment, surfaces & packaging
Contaminants in the environment, such as chemicals, airborne spores and allergens
Transporting and storing cheese with contaminated foods

Cross contamination can be avoided by following some simple practices:

Store cheese below 8c and away (always above) from raw meat and fish.
Use clean surfaces and cutting tools.
Never re-use wrapping material.
Ensure hands are clean when touching cheese.

What is HACCP?

If you work in the cheese industry, chances are that you will have heard of HACCP. Originally, the Hazard Analysis Critical Control Points (HACCP) program was developed in the USA as a way of ensuring the safety of foods intended for the space programme. Microbiological testing of end products was known to be ineffective at detecting low levels of contamination so, instead, food safety was managed by identifying the hazards relevant at each process step during food manufacture.

More commonly known as HACCP, it is a systematic and scientific approach to food safety, built to address potential food safety hazards by analysing risks, establishing critical control measures and monitoring procedures to prevent their proliferation which may cause harm to public health.

The program was later adopted as the basis for food safety management by the World Health Organisation and forms the basis of many food policy decisions taken by governments around the world.

What are the 12 Steps of HACCP?

Whilst there are 12 HACCP steps, the first five are known as “Preliminary Steps” and include (1) Assembling a Team; (2) Scoping the Process; (3) Identifying the Target and finally (4) Constructing and (5) Verifying a Process Flow to identify the production process from supply through to manufacture and delivery.

Steps 6 – 12 are known as the Principles of HACCP and are as follows:

6: Carry out a hazard analysis: this refers to identifying and looking at the level of risk posed by any chemical, microbiological and physical hazards relevant to each process of food manufacture. Further categorisation of microbiological hazards may be needed to assess the risk of presence, introduction, growth or survival.

7. Determine the Critical Control Points: these are identified as being particularly important to food safety; the pasteurisation of milk would be an example, in the instance of it being contaminated with pathogenic bacteria, such as listeria.

8. Establish Critical Limits: these are threshold limits which must be met to ensure CCPs will control the hazard. Refrigerator holding temperatures and pasteurisation times would be examples of this.

9. Establish a system to monitor control of the CCP: this takes a step back and requires that management introduce procedures that check the critical limits are being adhered to and could include something as simple as a daily record of temperature checks on fridges up to ensuring a defined acidity point during cheesemaking is reached within the agreed time limit.

10. Establish the corrective action to be taken when monitoring indicates that a particular CCP is not under control: this may include further processing of a batch of cheese to remove the hazard specified, or potentially rejecting the batch in full.

11. Establish procedures for verification to confirm that the HACCP system is working effectively: the point of this, what is essentially a spot-check, is to have an added level of security to ensure all HACCP systems in place are working together to ensure the hazards are effectively reduced or eliminated.

12. Establish documentation concerning all procedures and records appropriate to these principles and their application: this formalises all of the above, bringing all steps and verifications into one, easy-to-access document.

What are Food Labelling Laws?

All prepacked cheese requires a food label that displays certain mandatory information. Some of these are general requirements applicable to all foods, whilst others are specific to milk products.

There are general requirements, which must be accurate and not misleading, including:

Name of the Cheese
Net quantity
List of Ingredients (although these may be omitted if the only added ingredients are lactic products, food enzymes, starter cultures and salt)
Allergen information
Use-by date
Storage conditions
Name and address of cheese producer or who the cheese is marketed by
Country of origin
Nutritional declaration (this may be omitted if the manufacturer only supplies small quantities to the final consumer or to a local retailer that may supply the final consumer)

What Happens When a Cheese is Withdrawn or Recalled?

The term product withdrawal means the removal of foods from the market, where it has not yet reached the final consumer. This might be necessary where a cheese is found to be unsafe but is still in distribution (eg being stored by a wholesaler). While the wholesaler will be notified about the issue with the product, this information is not made public and the risk of reputational damage is minimised.

The term product recall means the removal of foods from the market at all levels, including from the consumer. This is necessary where cheese placed on the market is found to be unsafe and would usually be accompanied by a notice to consumers to return the product. This could cause reputational damage to the cheesemakers business but is necessary to protect consumer health.

Regulatory bodies can provide information on how to deal with food incidents which may require a product withdrawal or a recall.

What is Food Crime?

Whilst not a large topic within Regulation and Good Practice, food crime, or “food fraud” is becoming an increasing challenge for the food industry. There are opportunities to make money by unscrupulous suppliers of food which have false claims, origins, and certifications. Examples of food crime include:

Adulteration/Substitution – where a foreign substance or inferior ingredient is used to reduce costs; Waste Diversion, where inferior cheese is diverted into processing; Document fraud and misrepresentation – where labels and documents are produced to wrongly market its origin or quality and Theft – whereby expensive cheeses are stolen from a storage facility and sold on the black market.

There are systems, like those used in HACCP, that can be put in place to help prevent food crime, using the flow of production to identify hazards, assess the risk, and put controls in place.

Consumer and business guidance is given by food regulatory bodies and in the case of unsafe food having reached the consumer, this body must be informed, so that a product recall notice can be sent out.

How Does the Design of a Dairy Impact Food Safety?

When looking at the design of a dairy, the placement of a cheese cave, or perhaps the site of a cheesemongers, it is necessary to consider how the space will contribute to an effective, safe food environment. There are several design factors that will have an impact on food safety, predominantly from cross contamination. It is important to consider these when deciding whether to move into an existing building or create a purpose-built space. Factors to consider include:

Can the space accommodate a “Forward Flow” process: it’s easier to control cross contamination when the movement of materials goes from a raw material to a finished product in a forward process through a production facility. Products only move in one direction, towards storage and despatch. Older buildings aren’t necessarily big enough to allow for this forward flow and additional cleaning procedures may need to be implemented.
Building material, ventilation, sanitisation and condensation are all issues that can impede an older building and the ability to prevent cross contamination.
External location of a building should be considered to prevent cross contamination. For example, non-proximity of animals, effective water drainage and sanitary access areas are all necessary in preventing cross contamination.
The internal environment is just as critical, with surfaces being made from impervious and washable materials; floors should be free-draining and all areas should be accessible for cleaning.
Dairy design extends to equipment and is imperative in preventing cross contamination, with the ideal material for large pieces being stainless steel, due to its non-toxic, non-migrative and hygienic properties.

It is key to understand that the HACCP process is a technique of assessment, and a comprehensive pre- requisite plan is the base line to providing a safe cheese making environment, together with design of the dairy, its location, and the equipment choices.

101 guide – Cheese Regulation & Good Practice | Chapter two

What does Regulation and Good Practice mean to the Cheese Industry?

Cheese Industry Responsibilities

Every year, millions of consumers become sick due to foodborne related cases. It is the responsibility of cheese industry professionals to fulfill all the necessary steps to protect public health. Not just from an ethical standpoint, but also financially: the burden of extra costs, not only due to foodborne illnesses, but also with food waste can add up to millions of pounds.

Whilst food safety is not a small matter, it is necessary if you want to keep running your business.

Cheese making support is available globally. There are many regulatory bodies across the world, in addition to specific cheese focused industry bodies who provide expert and scientific based advice to support all sizes of cheese making dairies to make safe cheese.

Cheese Food Businesses

When deciding to set up a food business, advice should be sought from the local regulatory body, as listed below:

UK: Food Standards Agency (FSA) (England, Wales & NI)

Scotland: Food Standards Scotland (FSS) (Scotland)

USA: Food and Drug Administration (FDA) (US)

EU: The European Food Safety Authority (EFSA)

Australia & New Zealand: Food Standards Australia New Zealand (FSANZ)

Canada: Health Canada/Canadian Food Inspection Agency (CFIA)

Japan: The Food Safety Commission of Japan (FSCJ)

As well as setting down laws on food hygiene requirements and managing food safety, they also offer advice on HACCP plans, premises design and internal requirements, packaging and labelling and registration advice.

HACCP plans

Making an HACCP plan means reading a lot of related materials, understanding your whole production, supply and/or retail process, and countless hours of analysing your food safety management system.

Owners and managers will be responsible for all ensuring all steps of an HACCP plan are set up and implemented. They will be required to identify the hazards, such as drawing up the list of potential pathogens; recognise, with the use of reliable and factual resources, the CCPs; and initiate monitoring, verification and documentation procedures.

Food Safety

Food safety is not a short-term process that can be introduced at the opening of a new business or at the start of a batch of cheese. It is a process that must be maintained, constantly reviewed and improved upon, according to current food safety regulations. As such, depending upon the size of the business, it may be necessary to employ one or more persons specifically tasked with the overall running of the HACCP program.

Nor should the responsibility be restricted to managerial staff; HACCP processes must be passed top-down and enforced, so that a company-wide approach is adopted. There is a responsibility of the employer to provide supervision and adequate training to all personnel in food hygiene matters.

Personal Hygiene Requirements

Employees such as cheese counter staff, sous chefs and dairy hands have a responsibility for their own personal hygiene requirements; contamination of milk by food handlers is relatively uncommon if there are effective personal hygiene arrangements, e.g., hand washing, clean uniforms and covering hair.

As well as their own personal hygiene, staff may also have to carry out the actual documentation of HACCP procedures, such as temperature checks, cleaning schedules and use-by dates.

Failure to comply with Food Safety laws and regulations can result in one of five improvement notices, prohibition orders, remedial action notices or detention notices, that can severely impede on a business, whether that’s a dairy, a cheesemaker, a restaurateur or a cheese retailer.

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What does Regulation and Good Practice mean to consumers?

Caring for and Serving Cheese

Having a basic understanding of food safety, when it comes to keeping, caring for and serving cheese, will, ultimately keep you, as a cheese lover, and your family/guests safe from any potentially harmful pathogens that may have developed because of poor production processes or care prior to and after purchase.

Correct Temperatures for Cheese

Factors such as storing cheese at the correct temperature and adhering to use-by dates will help reduce incidences of food-poisoning in the unlikely event of inadequate food safety programmes being in place prior to purchase.

Cheese Cross Contamination

An understanding of cross contamination will further reduce these risks. Often cheese is eaten “uncooked” on its own, rather than cooked within a recipe. If pathogens from raw meat and fish, or chemicals from domestic supplies are transferred onto the cheese, they could have a detrimental effect on the safety of the cheese.

101 guide – Cheese Regulation & Good Practice | Chapter four

What is the relationship between the Academy of Cheese and Regulation and Good Practice

Practical Guidance for Cheese

Regulation and Good Practice is the area of cheese industry and study that outlines the relevant issues, identifies the laws and associated bodies and offers practical guidance with the aim of reducing incidences and minimising the risks associated with food born illnesses.

Cheesemaking, Supply and Mongering

Acknowledgement of this critical aspect of cheesemaking, supply and mongering cannot be overstated, which is why the Academy of Cheese is committed to educating both industry professionals and cheese-loving consumers, of this topic of Regulation and Good Practice with its own module, within each of their three levels of certification.

101 guide – Cheese Regulation & Good Practice | Chapter five

How is Regulation and Good Practice Taught at Levels One, Two and Three?

Each certification builds upon the previous level, with the knowledge required progressing from the perspective of a junior level monger and consumer at Level One to the legal responsibilities and in-depth establishment of process more relevant to ownership and managerial staff at Level Three.

Level one – basic hygiene measures

At Level One, we look at basic hygiene measures, cross contamination causes and food safety labelling that are relevant to both consumers and cheese industry staff.

Level two – regulations and legal requirements

Level Two takes an in-depth look at cheese-related pathogens; the regulations and legal requirements in place to protect the consumer from foodborne illnesses and a detailed breakdown of the Seven Principles of HACCP.

Level three – regulatory bodies and accreditation schemes

At Level Three, delegates will be expected to know the aims and responsibilities of the different regulatory bodies, including specific industry bodies and accreditation schemes as well as the role of due diligence in food safety cases. From a management perspective, they will identify the list of pre-requisites to any food safety plan, including induction and training, waste management, equipment management and traceability procedures. They will take a more detailed look at each of the 12 HACCP steps, relevant to each stage of the supply chain, and be able to compare them to HARPC controls in the US. Finally, the design of a dairy and the equipment within are considered, not only in relation to cross contamination, but also from a cost and regulatory perspective.

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