I have been busy reading the various documents put out by the New Zealand Ministry of Primary Industries (MPI) on the matter of raw cheese production. Hardly gripping reading, but nevertheless required. Also noting all the extra checking that will have to be done on a Raw Cheese RMP. Our milking parlour inspections will have to be done twice a year instead of annually, and the cows will have to be examined by a vet twice a year and TB tested annually -we are in a TB free area and the mandatory checks are only done every three years. We were last tested (all clear) in December 2015. Weekly laboratory checks of the raw milk will need to be done (at the moment I only have to do this every two months), and probably the most difficult requirement will be to have the curd of every raw cheese (my ‘batch’ size is normally a single cheese) laboratory tested for coagulase positive staphylococcus. My problem here is actually getting the sample to the laboratory in the same state as it leaves my cheese room, given the difficulties of courier pick-ups (and the expense) from Eketahuna & the distance to the only MPI dairy approved laboratories in Auckland – there are apparently none any nearer. Chris Whalley, cheesemaker of Mt Eliza Cheese who has successfully navigated the MPI raw cheese shoals tells me and I quote
“The point about curd testing is to measure Staphs when they are at their highest level, as the enterotoxins they produce will remain once the Staphs have died off. The limit is 1000, compared with 10,000 in UK and 100,000 in EU.”
I have also contacted Dr Paul Neaves, a food microbiologist with a particular interest in raw cheese. He is based in the UK and is convenor of the UK Specialist Cheesemakers Association Technical Committee and asked if he would be willing to be my technical adviser. This he has kindly agreed to do and has expressed great interest in the project. I look forward to working with him.
I also wrote the following letter to the approvals team at MPI
From: email@example.com [mailto:firstname.lastname@example.org]
Sent: Thursday, 21 April 2016 3:38 p.m.
To: MPI Approvals <MPI.Approvals@mpi.govt.nz>
Cc: Paul Neaves <email@example.com>
Subject: Approval for Cwmglyn Farmhouse Cheese to make raw cheese for sale
Natalie Collins, Manager of Dairy Products, suggested I contact you in reference to my adding a ‘significant amendment’ to my RMP Cwmglyn1 unique ID 242.
As you are probably aware, I am a very small production artisan cheesemaker using the milk from our own 4 Jersey cows to make traditional hard farmhouse cheese. At the moment I am heat treating the milk by thermisation to make it legal to sell, but due to my advancing age (74) I am finding it increasingly difficult to lift heavy pans of milk into larger pans of boiling water and out again into iced water for the heat treatment process, and would like to make raw cheese instead. I am conscious of the new NZ workplace Health & Safety Law, which I am bound to fall foul of, and I certainly can’t afford to pay the fines for breaches of it…
We have always made raw cheese for our own consumption over the last 12 years and during the time I was working with MPI during development of the smallholders Farmhouse Cheese template when every cheese I made during the entire year had to be tested, a number of these were raw cheese and no pathogens were ever detected in any of them and the coagulase positive staphylococcus was always less than 10.
I realise that there might be difficulties posed in this application because of my isolation from the testing laboratories and the small size of my production – a batch is quite often a single cheese, and under your present protocol, there might be difficulties with this. I intend to continue to only make hard aged farmhouse cheese, which is an intrinsically safe product, given it’s acid development and long maturing period and low moisture content. Because of the public interest in this matter, I am writing a blog detailing this process.
Dr Paul Neaves, a UK food microbiologist with a special interest in raw cheese made by artisan cheesemakers, has kindly agreed to provide me with technical assistance. He is the convenor of the UK Specialist Cheesemakers Association Technical Committee and was part of the jointly responsible committee with Cornwall Council in producing the Specialist cheesemakers’ assured code of practice.
I trust you will be able to offer safe passage to this approval process.
With all good wishes,
Cwmglyn Farmhouse Cheese, 36 Morgans Road, RD2 Eketahuna 4994
I received the below email in reply on 26th April 2016:
Thank you for your email regarding a significant amendment to your risk management programme (RMP) to add the production of raw milk cheese. I understand that MPI has already provided information regarding requirements related to raw milk products in our previous email.
All cheesemakers, big and small, have to meet certain rules in order to ensure all associated risks are managed carefully in order to produce safe food. Cwmglyn Farmhouse Cheese is currently operating under the Micro-Cheesemakers Trial Programme (now known as the ‘Farm House Cheese Risk Management Programme Template’). As raw milk is a high-risk food, cheesemakers wanting to produce raw milk cheese have to meet additional measures set out for manufacturing raw milk products. For Cwmglyn Farmhouse Cheese, this means that the scope of your RMP will have to be extended to cover the production of raw milk cheeses to ensure all the right food safety and hygiene requirements are met.
This is a significant amendment to the RMP and prior to submitting the RMP amendment for approval, Cwmglyn will need to have the amendment evaluated.
As a first step, can you confirm that Cwmglyn Farmhouse Cheese will be using the existing MPI Raw Milk Products Code of Practice? As we’ve mentioned earlier, the Code of Practice is one of the key ways in which you can demonstrate that you are meeting the food safety requirements of the Raw Milk Products Notice. If you follow MPI’s Code of Practice, this will help to ensure that your RMP amendment application will move through the evaluation and registration process smoothly.
MPI’s Code of Practice is not the only way you can meet the requirements of the notice, but alternative methods would need to demonstrate that the requirements are being met and this may result in the evaluation and registration process taking longer and it is likely there will be additional costs associated with this. The link to MPI’s Code of Practice is: Dairy – Additional Measures for Raw Milk Products – Code of Practice.
We look forward to hearing from you.
Branch planning, systems & support | Regulation and Assurance
Ministry for Primary Industries | Pastoral House, 25 The Terrace | PO Box 2526 | Wellington | New Zealand
It was a bit disconcerting to not know exactly who I was corresponding with -surely even faceless bureaucrats have a name- but I replied and said I just wanted a significant amendment to my existing RMP and please who was I addressing?
Meantime I am contacting all the various laboratories to find out how much all this testing will cost………..