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Bernie Ziebart

The Engineering Perspective

The blog is a view of life, science, politics and education from an engineering perspective. As engineers, we are taught to view the world objectively. We can hope, believe and calculate a particular outcome, but natural laws are inflexible and pay no heed to who we are or what we believe. We must approach the objective dispassionately, while compensating for our own distorted perceptions. Balance is also a key element; balancing between the ideal and the pragmatic, balancing cost and functionality, balancing analysis with action, etc.

Scheduling routine critical self-analysis is the foundation to objectivity. If we do not fully understand and compensate for our own failures, tendencies, habits and skewed thought processes, we will not see the world as it is. Without a regular critical self-analysis we will see the world as we are and then fall prey to self-delusion.

Failure is a great teacher. When failure is coupled with perseverance, it produces the fruit of patience and humility. An engineer, fresh out of engineering school is typically set up for failure early and often. The failure breaks the new engineer of any ideas of self-importance, arrogance and book smarts. Only then can the new engineer be formed and molded into a productive element in the industry.


The FDA and cheese

In a statement by FDA’s Branch Chief Monica Metz, the chief official responsible for food safety issues involving cheese, the manufacturing process of aging cheese using porous wood is banned.  

“The use of wooden shelves, rough or otherwise, for cheese ripening does not conform to cGMP requirements, which require that “all plant equipment and utensils shall be so designed and of such material and workmanship as to be adequately cleanable, and shall be properly maintained.” 21 CFR 110.40(a). Wooden shelves or boards cannot be adequately cleaned and sanitized.  The porous structure of wood enables it to absorb and retain bacteria, therefore bacteria generally colonize not only the surface but also the inside layers of wood. The shelves or boards used for aging make direct contact with finished products; hence they could be a potential source of pathogenic microorganisms in the finished products.”

What prompted this regulation? Were the cheese manufacturers experiencing a rash of food-borne illnesses?   FDA spokesperson, Lauren Sucher, claimed that the agency is merely attempting to engage the industry in its manufacturing practices, while being proactive. Engage? It’s a bit more like destroy. In a comparable analogy, Boko Haram is merely attempting to engage the people of Nigeria.  

The process of aging cheese on wooden boards is a practice that has been used for hundreds of years. With hundreds of millions of pounds of aged cheese produced every year, the health and safety record has been spotless.

The Wisconsin Center for Dairy Research compiled research on the subject (there's been a lot of it from France), and it suggests that proper cleaning and sanitization methods can sufficiently wipe out bacteria from various kinds of wooden boards. A 1992 study showed those using wooden cutting boards at home were less than half as likely as average to contract salmonellosis, while those using synthetic (plastic or glass) cutting boards were about twice as likely to do so. 

In Wisconsin there are about 33 million pounds of cheese being aged on wooden boards. This aged cheese is a little more costly than your average velveeta. One of my favorites is a mild apple smoked cheddar cheese by Carr Valley Cheese; aged 4 to 6 months.  It costs about $20/lb.

If you like a good sharp cheddar. Renards, from Door County, has a fantastic 14 year cheddar, but it will cost about $45/lb.

The impact on Wisconsin would be enormous. The cost to Wisconsin revenue with the loss of the multi-billion dollar cheese industry is difficult to comprehend.  This regulation would also kill jobs and cause massive bankruptcies.   Many of the cheese manufacturers have built large underground facilities to age the cheese in tightly controlled environments. Cheese manufacturers take great pride in the cleanliness and quality of their products.

In light of a fabulous track record, why did the FDA issue this regulation? Certainly not to improve the manufacturing practices.  Is the FDA trying to protect the consumer? Depriving the consumer of good cheese isn’t protection.  

From CNN, NPR to the Wall Street Journal, the articles about this FDA regulation reflect a head scratching exercise. But when actions and activities don’t make sense, politics is normally a culprit. Politics is the likely driving force behind this regulation as well. Could it be that the cheese industry hasn’t contributed sufficiently to the Obama campaign? Or perhaps the cheese industry hasn’t enrolled enough of its employees in ObamaCare.  Does the Obama administration want to punish Wisconsin for passing Act 10? An even more likely scenario involves the FDA director, Monica Metz, who was the CEO of Monsanto, the parent holding company to Kraft and holds Kraft stocks in a blind trust.  Kraft stock prices would jump if the competition was eliminated.

From the outside this appears to be extortion; Chicago-style politics.  It's akin to the Mafia drumming up money for its protection racket. Unfortunately, no reporter is cynical enough to dig into the politics behind the regulation.

Fortunately, the cheese industry fought back. Wisconsin regulators will not enforce this FDA regulation without a proper investigation.

On June 10th, the FDA issued a statement that they would not enforce the regulation regarding the wooden aging boards. But they left the door open for future enforcement.

“The FDA has not taken any enforcement action based solely on the use of wooden shelves.

In the interest of public health, the FDA’s current regulations state that utensils and other surfaces that contact food must be “adequately cleanable” and properly maintained. Historically, the FDA has expressed concern about whether wood meets this requirement and has noted these concerns in inspectional findings. FDA is always open to evidence that shows that wood can be safely used for specific purposes, such as aging cheese.

The FDA will engage with the artisanal cheese-making community to determine whether certain types of cheeses can safely be made by aging them on wooden shelving.”

I can answer that last concern.  Yes, cheeses can be safely made by aging them on wooden shelving.  There, now you can go on to other matters.

The statement only brings a temporary relief. It is not a repudiation of the regulation that cheese makers were hoping for. The regulation still stands, just lacking enforcement.  But for now, it’s business as usual.

This is a loud and clear proclamation to cheese makers not to expand their businesses; limit the exposure to aged cheese. This is also a lesson for people in other regulated industries.  When government officials make pronouncements that don’t seem grounded in reason or common sense, and threaten your livelihood with an enforcement action, you must organize and fight back.

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