Sixty Days Isn’t a Panacea for Contaminated Food: Proper Hazard Analysis Is

Over 15 years ago, as a starry-eyed kid just moved to New York City, I stumbled into love with cheese. I was much less sophisticated than millennials are today but I fell hard for this new food that stirred something deep within me. So much so that I scrapped my Ivy League trimmings and went to work for peanuts on a little cheese counter in the West Village.

I made cheese my career because cheese made me care. I met farmers crafting food by hand who made me care. I saw animals raised outside, eating grass, contributing to healthy ecosystems that powered entire rural communities; that made me care. I saw and learned food traditions that were thousands of years old, the preservation of which made me care. To this day when I tell people I work in cheese they are universally enthusiastic. For whatever reason, cheese is a food that people love, and it’s a food we want to love.

Perhaps it’s this goofy and unabashed love that also makes us want to dangerously over-simplify what is an extremely complex microbiological evolution from liquid milk to solid cheese. Last week the news broke of multiple illnesses and deaths linked to a cheese made in New York State. I’ve been shocked by the broad generalizations and inaccuracies in the reporting of this story. As a cheese expert, the number one question I am asked has to do with the safety and legality of raw milk cheese. If you are an eater of cheese who read about the recall of cheeses from Vulto Creamery and felt confused, or scared, or unsure what cheeses are safe to keep buying, my hope is to offers some context and clarity.

Last week it was reported that between September 2016 and January 2017 there were two deaths and at least six illnesses caused by an outbreak of listeria linked to a raw milk cheese.

Listeriosis is a serious infection that causes an estimated 1600 illnesses and 260 deaths each year. It is most likely to sicken pregnant women, newborns, adults over 65 and people with compromised immune systems. It is most usually caused by food contaminated with the bacterium Listeria monocytogenes. Major outbreaks in 2016 were linked to packaged salads and frozen vegetables, among other foods. Listeria is often closely associated with cheese.

Listeria can be caused by cheese made of pasteurized or raw milk. One month ago, one of the largest cheese makers in the country, Sargento Foods, Inc. recalled 7 lines of cheese due to possible listeria contamination. These were not rarified or exotic “artisanal” cheeses, but the most common, the most consumed cheeses—Colby, shredded Taco cheese, and the like. Every one was made of pasteurized milk. Their recall in turn prompted other companies to recall thousands of pounds of premade salads, cooking and snacking products that contain Sargento cheeses.

The importation and production of raw milk cheeses in the U.S. is strictly tied to what’s commonly called “The 60 Day Rule.” That is, cheese made from raw (unpasteurized) milk must be aged a minimum of 60 days before sale. The 60 day rule was not established “to block E. coli from developing” as stated in The New York Times’s article of 10 March by Kimiko de Freytas-Tamura. Two months’ of age (60 days) has been established by the U.S. Food and Drug Administration (FDA)

as a benchmark by which enough moisture loss will occur as to render an unpasteurized cheese inhospitable to harmful pathogenic growth.  By this logic, when a cheese turns 60 days the bad stuff can’t live in it anymore. As the tragic deaths and illnesses linked to cheese from Vulto Creamery show, this is not the case.

That is in no way to conclude, however, the raw milk cheese is inherently unsafe, nor is it to suggest that longer mandatory aging restrictions will fix the problem of contaminated food. What makes raw milk cheese safe—what makes any product of our food system safe—is a thorough analysis and understanding of the food production chain, and its ongoing testing.

de Freytas-Tamura cites an expert who describes listeria as “… hard to pinpoint.”  Listeria is not, in fact, hard to pinpoint as any expert in microbiology or hazard analysis would testify. It’s quite straightforward to pinpoint, but doing so requires a cheese maker’s rigorous and ongoing analysis: testing fluid milk, testing every batch of finished cheese, testing a cheese’s production and aging environments. This relentless monitoring must be accompanied by road-tested protocols for managing a worst-case scenario like the one at Vulto Creamery: a proper HAACP (Hazard Analysis and Critical Control Points) plan empowers a cheese maker to understand how their products interact at the site of production (and so what the cross contamination risks are, and how they can be mitigated); how to quickly and thoroughly remove compromised (or even potentially compromised) product from the marketplace; and perhaps above all else a willingness to speak publicly at the first sign of risk so as to ensure that no greater crisis occurs farther down the road.

If one needs a compelling illustration of the merits of the industrial cheese making industry it is not that pasteurized cheese is safe (while artisanal raw milk cheese is dangerous.) It is, as the Sargento recall shows, that industrial-scale pasteurized cheeses can be unsafe but are also likely to be inscrutably tracked and immediately recalled at the first indication of potential contamination. 

In 2014, the FDA undertook a massive collection and testing of raw milk cheeses aged 60 days, made both domestically and abroad. The intention was to adopt a proactive approach to understand what trends, if any, existed and to use this knowledge to prevent contaminated food from reaching consumers. Their test pool disproportionately favored soft, higher moisture (and accordingly higher risk) raw milk cheeses. When results were published in 2016, of the 1,606 samples collected, 10 tested positive for listera (.62%) Of the 10, five were domestically produced and of the five, three came from a single producer.  The issue at hand is not with raw milk cheese per se, but with the proper management of cheese making on a producer by producer basis.


There is risk in any food making and risk in any cheese making, whether from raw or pasteurized milk. As a consumer, and a parent of two small children who eat raw and pasteurized cheeses on a daily basis, I trust that makers will hold themselves to the highest production standards and the most conservative hazard analyses. I also hope that regulators can serve as collaborators and teachers, as well as third party auditors. Cheese makers are licensed and inspected by their states as well as by the FDA and deserve knowledgeable state agencies with whom to collaborate, improve and manage their production systems. We all deserve that, for the outcome is a safer supply chain that preserves our choices about the kinds of food we want to support with our dollars. 

My heart breaks for those people who bought some cheese sometime in the past few months to nourish themselves or treat themselves and wound up sick, or worse. But it would be wrong to assume that all raw milk cheese, or all artisanal cheese, or all cheese period poses the same threat as this isolated incident.