Member Update: 
ACS Spring Meeting with FDA 
Recap from May 18 Meeting

On Friday, May 18, ACS leaders met with FDA  to touch base regarding a number of issues of relevance to members. 
The first issue discussed was the current targeted sampling and testing of blue cheese. FDA clarified its process for determining targets for sampling during routine compliance inspections, and how the current testing was spurred largely by recent recalls and data from the literature showing that Listeria prevalence can be as high as 55% in some internationally-produced blue cheeses. It is not an official field assignment, but rather comes out of FDA's annual fiscal year planning, at which time resources are allocated to target sampling of certain food products on a priority basis. Less than 200 cheeses are expected to be sampled, and the sampling will be included as part of regular inspections.  Please see our March 2018 issue of The Traditional Cheese Advocate for more related information and resources. 
Labeling issues were discussed in regards to terms such as "natural" and "healthy," as well as clarification being sought on the current voluntary guidelines for sodium reduction. All of these issues will be part of a public hearing this summer, where stakeholders may provide input. ACS will inform members once these meeting details become available. FDA did state that they understand sodium plays a different role in cheesemaking than it does in many other products, including its impact on food safety. They also reiterated that their focus is on large producers whose products reach the greatest number of consumers. Nestle, for example, is working to lower salt, fat, and sugar across its product lines in response to the voluntary guidelines.
The use of wood boards in cheesemaking was briefly touched upon, and FDA mentioned that wood boards are evaluated by inspectors just as any other food contact surfaces and/or equipment. Sanitation Standard Operating Procedures (SSOPs) must be in place, and demonstrably efficacious. They will only become the focus of additional attention if the boards appear to be in poor status, poor repair, or test positive for pathogens.
Non-toxigenic E. coli as an indicator of pathogen contamination continues to be under review by FDA. They are conducting a literature search of current research, and plan to write a paper for publication in the future on indicator organisms specifically in cheesemaking. This document will reflect scientifically defensible policy.  Their goal is to move forward with a policy that makes sense, and around which stakeholders can rally. FDA intends to continue the current pause on non-toxigenic  E. coli testing as an indicator of insanitation until a new policy is in place. A new Compliance Policy Guideline will always first be released in draft format for public comment. Currently, testing is focused on Shiga Toxin-producing  E. coli (STEC). State inspectors in some areas continue to use the <10 mpn/g limit for non-toxigenic  E. coli as an indicator organism. You may always ask your inspector to show documentation as to why they are conducting such testing, as well as under whose authority they are conducting the inspection. If on behalf of FDA, and not based on state regulations, you may inform them of the current pause.
FDA is working to modernize in tandem with the innovation occurring in the food supply system by updating and expanding Standards of Identity (SOI).
In the past, many SOIs were very prescriptive, and they hope to allow for more flexibility to meet current markets without compromising the integrity of the products. Any changes to the SOIs for milk and milk products fall under congressional review and therefore require a more formal rule-making process, and must be approved and passed by Congress. This makes any potential changes to d airy product SOIs 
more complicated and time-consuming. Instead of the simpler "notice and comment" process, objections to potential changes to dairy product SOIs could be made at any point in the process, and such objections could stop the process from moving forward. 
ACS ended the meeting by sharing its efforts to proactively enhance cheese safety. FDA recognized the many strides the organization and its members have made and asked specifically about certain ACS resources. In particular, they were impressed to learn about  ACS's partnership with Cherney Microbiological Services to provide discounted testing to ACS members, and its all-inclusive packages for Listeria environmental testing programs. Steve Musser, Deputy Center Director, Scientific Operations, mentioned that ACS may be the first industry group to have successfully established this type of consolidated testing discount for its members. It is something FDA has long hoped industry groups could take on.

In addition, ACS shared the following resources with FDA per their request: 
FDA is sending a representative to Pittsburgh this summer to present at ACS's Annual Conference,  Forged in Cheese . The as-yet-to-be-determined speaker will share information on how products are selected for targeted sampling, as well as touch base on the key issues of concern to ACS members.
We will continue to keep members apprised of further updates from FDA as they become available. In the meantime, if you have questions or input related to the issues covered during this recent meeting, please contact us at