preference to be working at the vat—the
artisans we partnered with were committed to the process and paperwork needed to meet FSMA compliance. They’ve
pored over paperwork, established and
implemented new protocols, engaged in
HACCP and Preventive Control trainings, and—in some cases—even hired
additional staff to meet requirements.
Their commitment to providing safe,
high-quality, delicious products to consumers cannot be questioned.
Challenges of Scale and Resources
Yet, challenges to food safety at the
artisan level remain, and those, too,
seem universally shared. Most artisans
have limited technical resources in-house for food safety checks. You won’t
find a lab tech or a quality assurance
manager in a two-person operation. As
a result, some elements of a complete
food safety program, such as environmental monitoring, may be restricted.
Artisans’ buying power is limited, as
their volumes are smaller. It can be difficult for these makers to find suppliers
that will sell a small quantity of sanitizers, like floor powders or granules, or
enter into a pest control contract for a
facility that’s just 5,000 square feet. Additionally, small artisan facilities may
not receive the service of a supplier that
larger dairy plants receive.
We also find that many artisans are
purchasing ingredients for their cheeses
or other dairy products off the shelf
at big-box stores, because they cannot
procure them at desired quantities via
an industry supplier. That creates some
risk, as the consumer retailers of the
world will not provide the same level
of assurance on content that FSMA
requires for a supplier of goods and
services to food plants. These challenges
could be considered business opportunities for industry suppliers. We can
confirm the demand for goods and services is there; a supplier need only find
a way to deliver smaller quantities and
service in a way that’s still profitable.
Moving Forward on Food Safety
An output from our work identified
a need to work specifically with small
and very small operators of raw-milk
cheese production. Through our visits,
we identified a number of best practices
and formulated the Food Safety Systems
Guide to Raw Milk Cheese Production that
provides suggestions for the cheese-
maker to identify and mitigate potential
food safety risks posed by pathogens.1
This guide offers three tools: a flowchart
showing key food safety steps in the
manufacture of raw-milk cheese, the
top 10 action steps intended to provide
a quick and handy overview of food
safety management to manufacture
raw-milk cheese with suggested risk-mit-
igation steps (note: cheesemakers must
implement a range of strict controls to
mitigate food safety risk), and a top 10
action-steps narrative that provides spe-
cific details for those steps. The top 10
steps are included here:
1. Develop a supplier control program
for raw milk and ingredients.
2. Identify hurdles that use a kill step
via process control and/or a recipe
to control pathogenic contamination.
3. Set a target to monitor wet acid development during the make.
4. Create active pest and insect control
5. Implement hygienic zoning and
Good Manufacturing Practices to
6. Verify documented cleaning procedures with a reputable sanitarian.
7. Conduct environmental monitoring
and product testing to verify effectiveness of sanitation and barrier
8. Ensure a 60-day curing time at a
minimum 35 °F prior to distribution.
9. Maintain a brine maintenance program (brined cheeses).
10. Identify opportunities for continuing education in food safety management.
In addition, as a second output,
we are currently working to outline a
cheese brine management plan for small
and very small operators. This plan is
intended to provide cost- effective intervention steps to mitigate potential food
safety risks that pathogens pose to the
We also believe there’s an opportunity here for the industry to continue to
strengthen itself by pooling food safety
knowledge. The entire dairy industry
collaborates on food safety through the
Innovation Center for U.S. Dairy and
the Dairy Food Safety Alliance, which
was recently launched by WCMA,
CDR, and the Dairy Farmers of Wisconsin, to share regulatory updates and
insights from the brightest minds in
government, research, and business.
Joining is free (contact Events Manager
Kirsten Strohmenger at kstrohmenger@
wischeesemakers.org) and open to dairy
processors of all sizes.
The truth is, FSMA compliance work
is only just beginning. Our collective
understanding of food safety continues
to evolve and, as a result, regulations
will evolve, too. Improving food safety
in dairy processing facilities should be a
continuous goal, and one we work hard
to reach every day. n
Jim Mueller and Larry Bell are members of the
Artisan Dairy Producer Food Safety Initiative.
Challenges Encountered by Artisan Dairy Producers
• Limited technical resources to support and manage a food safety plan
• Developing and deploying an environmental monitoring program
• Facilities with adequate barrier control between raw, in-process, and fin-
• Difficulties with small-quantity purchases in procuring required supplier ap-
proval documentation, including Certificates of Analysis
• Conducting mock recalls to test the recall plan
• Documented sanitation procedures and training