This is the letter I sent the Approvals Team at NZ MPI this morning, while I was between doing things to my curd during this morning’s cheese make. Their prompt reply follows after. Regular readers of this blog will note that in a previous communication to the Approvals Team, I asked with whom I was communicating. As yet no reply…..
For those who might be interested to know how much cheese I produce in a year from my 4 lovely Jersey cows, I see from Colin’s calculations (maths not my strong point!) that I sold 889 kilograms of Cwmglyn Cheese in the financial year 2015-2016, not, unfortunately, as good as the previous year, when it was just over a ton, but then as every dairy farmer will tell you, we have our ups and downs……
Hello Approvals –whoever-you-are!
I have carefully read the various papers with the links you gave in your email below, and although I note that you mention it might be rather more expensive for me not to use your existing MPI COP for raw milk products, I reckon there would be considerable expense attendant upon Cwmglyn Farmhouse Cheese actually using it.
I propose to write my significant amendment with relevant details taken from the MPI COP, The UK Specialist Cheesemakers Assured Code of Practice, edition 1, 2015 and any other worthy scientific papers that would be applicable to our very small production artisan cheesemakers here at Cwmglyn Farm.
I note that on page 40 of the NZFSA additional measures for raw milk products, you require a sample to be tested of raw milk used in that particular make; as I have explained previously, my batch sizes are frequent and very small. Courier charges and laboratory testing expenses for the milk and curd testing for 3 or 4 days a week that I make my cheese will be logistically difficult for us as it seems the only recognised dairy laboratories are located in Auckland, hundreds of kilometres away from Eketahuna. How about doing some regional development and getting some recognised labs in Palmerston North –far cheaper for the scientists to live there, than Auckland!
On page 41, given your definitions of ‘process run’ and ‘Lot’, I note that there is absolutely no difference between standard frequency and high frequency on the microbiological monitoring of raw milk products, or, in fact, any difference between soft or hard cheese. I would have thought that if you can demonstrate over 10 –20 make sessions that your curd coagulase positive staphylococcal are well below levels to produce enterotoxins, then having to test every single cheese make curd would be a bit excessive, especially given that we only make traditional hard farmhouse cheese (cheddar type) at Cwmglyn and have NO intention to make any other sort of cheese.
I have asked my AsureQuality auditor, Jude Dooley if she will be able to continue to do my audits if I finally get permission to make raw cheese to sell, but have had no response from her as yet.
I am happy to follow the extra farm steps (and most of them we do already or, in fact, exceed) given in your raw cheese COP and they are detailed in my existing RMP. The only issue here will be on page 22 “transport” of milk to process facility. Our milk only has to travel around 5 metres from the cow’s udder to the receiving churn in the cheeseroom. There is NO WAY I can adhere to the sentence “From the point of collection through to delivery to the manufacturing premises, the temperature of the milk must not exceed 8°C” …. if it arrived at that temperature, the cow concerned would be long dead and rather difficult to remove from the milking parlour!
With all good wishes,
Biddy Fraser-Davies, Sole cheesemaker Cwmglyn Farmhouse Cheese
Thank you for your email, it has been received by the Approvals Operations Team and will be processed accordingly. We will endeavour to reply to your query within 5 working days. It may be that we need to get some technical advice, and if this is the case, replying to you may take longer than expected.
ANIMAL PRODUCTS ACT, FOOD ACT & WINE ACT
Please note that as of last year, exporter and dairy exporter registrations combined into an Animal Products Exporter registration. The link below can be used for all new and renewal applications: http://foodsafety.govt.nz/industry/exporting/documents/forms.htm
General information on Exporting can be found here: http://foodsafety.govt.nz/industry/exporting/overview.htm
General information on Risk Management Programmes can be found here: http://foodsafety.govt.nz/industry/general/rmp/
General information on Maintenance Compounds (dairy and non-dairy) can be found here: http://foodsafety.govt.nz/industry/general/maintenance-compounds/
General information on Food Control Plans can be found here: https://www.mpi.govt.nz/food-safety/food-act-2014
General information on Wine can be found here: http://www.foodsafety.govt.nz/industry/sectors/wine/overview.htm
General information and application forms regarding Class Determinations can be found here: http://foodsafety.govt.nz/industry/acvm/overview/class-determination.htm
If you require further help, a list of consultants can be found here: http://www.foodsafety.govt.nz/registers-lists/consultants/index.htm
The Approvals Operations Team | Ministry for Primary Industries
Pastoral House, 25 The Terrace | PO Box 2526 | Wellington | New Zealand
Telephone: 64-4-894 2550 | Facsimile: 64-4-894 2566 | Web: www.mpi.govt.nz
The Approvals Operation Team
This email message and any attachment(s) is intended solely for the addressee(s)
named above. The information it contains may be classified and may be legally
privileged. Unauthorised use of the message, or the information it contains,
may be unlawful. If you have received this message by mistake please call the
sender immediately on 64 4 8940100 or notify us by return email and erase the
original message and attachments. Thank you.
The Ministry for Primary Industries accepts no responsibility for changes
made to this email or to any attachments after transmission from the office.
The below email is the first one I had from the Approvals Team
From: MPI Approvals
Sent: Tuesday, April 26, 2016 3:05 PM
Subject: RE: Approval for Cwmglyn Farmhouse Cheese to make raw cheese for sale
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