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Cheese Importer Group Urges FDA to Consider Low Risk of Most Cheeses

The Cheese Importers Association of America (CIAA) urged the Food and Drug Administration not to paint with too broad a brush as it devises its list of high-risk foods subject to increased recordkeeping requirements. In comments dated May 21 submitted in response to FDA’s proposed criteria for designating high risk foods, the CIAA said the agency shouldn’t use overly broad product categories that would lump safe products in with foods that actually are high-risk.

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FDA requested comments in February on criteria it should use to designate high-risk foods, as required by the Food Safety Modernization Act (see 14020318). Under FSMA, those foods will be subject to increased recordkeeping requirements. Neither FSMA nor FDA have spelled out what those new requirements might be. According to the CIAA, FDA is proposing to rely on the product categories set forth in the Reportable Food Registry Commodity Definitions. That would lump all dairy, including milk and milk products, into the same category.

Having a product category for all dairy is so broad that it risks including very low-risk foods, said the CIAA. “We are concerned that all dairy products will be designated high-risk foods because of a few products (e.g., dried milk products, soft cheeses) that do pose greater risks,” it said. The majority of cheeses are very low risk foods, particularly hard and processed varieties, said the CIAA. Only soft unripened cheeses were found to present a high risk for listeria contamination in a 2003 FDA survey, it said. The CIAA contrasted the low risk of most cheeses with other products that might be included in the dairy category, including raw milk, “which is responsible for a disproportionate number of illnesses,” and homemade or illegally imported Hispanic-style soft cheeses.

“We see no reason why FDA should not use more precise product categories,” said the CIAA. For cheese, the trade association proposed that FDA use the product categories from its 2003 listeria assessment: hard cheeses (cheddar, parmesan, Swiss), processed cheeses (American, spreads), fresh soft cheeses (queso fresco), soft unripened cheeses (cottage, cream, ricotta), soft ripened cheeses (brie, feta, mozzarella), and semi-soft cheeses (Monterey Jack, gouda, and blue). Comments on FDA’s criteria for designating high-risk foods were due May 22.