Proposal P263 - Safety assessment of raw milk very hard cooked - curd cheeses
Full Assessment Report
20 November 2002
Full Report [ PDF 313 kb]
EXECUTIVE SUMMARY AND STATEMENT OF REASONS
Background
The processing requirements for cheese and cheese products in Volume 1 and Volume 2 of the Food Standards Code(the Code) specify that milk for cheese manufacture must be heat treated by a pasteurisation or thermisation process. In Volume 1 of the Code, a provision exists whereby the adequate heat treatment of milk can be measured in terms of the destruction of the enzyme alkaline phosphatase. Certain very hard cheeses made from raw milk (not heat treated) have continued to be imported into Australia because, in the past, they were considered to comply with the alkaline phosphatase test. This alkaline phosphatase provision, however, has not been included in Volume 2 of the Code because it was not considered a reliable method for measuring the adequate heat treatment of milk and milk products. When Volume 1 is repealed at the end of 2002, raw milk very hard cheeses will not, therefore, comply with the processing requirements of the Code (Volume 2). Cheeses currently imported into Australia that fall into this category are Parmigiano Reggiano and Grana Padano.
Proposal P263 has been raised in order to assess the safety of very hard cheeses(<36% moisture) made from raw milk and to determine whether an amendment to the Code should be made in order to permit the continued sale of these cheeses. It is being progressed under section 36 of the Food Standards Australia New Zealand Act 1991, omitting the first round of public comment before draft assessment. Two options are considered by this proposal - to amend Volume 2 of the Code in order to permit the sale of very hard cheeses from raw milk (Option 1) or to make no amendment (Option 2).
Scientific Evaluation
The scientific evaluation (Attachment 2) undertaken for this proposal indicated that the very hard cheese manufacturing processes assessed could achieve a 5 log reduction of the bacterial pathogens of concern when using raw milk given good hygienic and manufacturing practices. This benchmark level of bacterial reduction is considered as achieving a product that is equivalent in its microbiological safety to products derived from pasteurised milk. The low moisture content of these very hard cheeses(<36%) and the long maturation/ripening periods involved are integral in determining the survival of any pathogens that may be present and are characteristic of this category of cheese. The cheese types assessed in this evaluation are considered representative of the very hard cheese category and so it is concluded that very hard cheeses in general can be manufactured to achieve a safe product under conditions of good hygienic and manufacturing practice.
Draft Assessment
At draft assessment, an amendment to Volume 2 of the Code (Option 1) was proposed which would allow for the sale of very hard cheeses (36% moisture and matured for greater than 6 months at no less than 10ºC) made from raw milk by exempting them, as a category, from the relevant heat treatment requirements in Standard 1.6.2 of the Code. The amendment proposed was consistent with COAG principles and FSANZ Section 10 objectives in providing minimum effective regulation applicable to both imported and domestic product. It essentially maintained the status quo with respect to allowing the continued importation of raw milk very hard cheeses and, additionally, allowed for the domestic production of such cheeses. The alternative option was not to amend the Code.
Public Consultation
The submissions received at draft assessment supported the continued importation of raw milk very hard cheeses. A number of submissions however had concerns with the domestic production of such cheeses to achieve a safe product, raising that there are no specific requirements in the proposed amendment that would, on their own, ensure safety and the production of supporting material by the relevant State authorities would take time.
The amendment proposed at draft assessment was not intended to be a standard for the production of raw milk very hard cheeses. It provided for an exemption from the heat treatment requirements in the Code for this category of cheeses (36% moisture and matured for greater than 6 months at no less than 10ºC). While the low moisture nature of these cheeses and long maturation times affect bacterial die off, the safe production of these cheeses would be ensured through compliance with the proposed standard, together with the Microbiological and Food Safety Standards in the Code and applicable State and Territory requirements in relation to cheese production, including any specific requirements in relation to the safety of raw milk and raw milk cheese production. An editorial note has been included at final assessment with the proposed amendment to clearly identify these additional requirements.
Final Assessment
Submissions received after the close off date for public consultation further indicated that dairy regulators and industry did not support the general exemption for the domestic production of very hard cheeses from the heat treatment requirements of Standard 1.6.2 unless other measures were in place. It was raised that the use of high curd cooking temperatures seemed to be a significant parameter contributing to the production of a safe product yet this was not reflected in the draft amendment to the standard.
The Final Assessment Report therefore recommends that an amendment to Standard 1.6.2 of the Code is made to exempt very hard cheeses (cheeses which have a moisture content less than 36% and have been matured/stored for at least 6 months) from the heat treatment requirements for milk and milk products for cheese manufacture, provided that they have also undergone a curd heating treatment of at least 48ºC. While the use of higher curd cooking temperatures is implicit in the production of very hard cheeses (compared to other cheese types), this minimum temperature requirement further reflects that a greater level of safety assurance can be achieved through the combination of high curd cooking temperatures and long maturation time for these low moisture cheeses(<36%).
The draft amendment at Final Assessment also includes an editorial note, which states that the draft amendment is to be reviewed within 12 months of gazettal so that a generic standard based on minimum effective legislation can be developed in consultation with jurisdictions. This will enable any outstanding issues with jurisdictions to be resolved without unjustifiably impacting on continued importation of raw milk very hard cheeses in the interim.
Statement of Reasons
An amendment to Standard 1.6.2 of the Australia New Zealand Food Standards Code is recommended for the following reasons:
- The amendment is based on scientific evidence which supports that raw milk very hard cheeses (less than 36% moisture, stored for at least 6 months at no less than 10 ºC and which have undergone a curd heat treatment of no less than 48ºC) can achieve an equivalent level of safety as cheeses using heat treated milk and do not pose any significant public health and safety risk.
- The amendment supports the continued importation of raw milk very hard cheeses such as Grana Padano and Parmigiano Reggiano, which have been imported into Australia for many years.
The impact analysis indicates that the amendment will provide an overall benefit to key stakeholders including importers, consumers, the food service sector and relevant government agencies
Full Report [ PDF 313 kb]