The FDA’s Food Safety Plan Builder – Cheesemaker’s Perspective

Perhaps you’ve heard of the free software being provided by the FDA to help food producers develop an in depth food safety plan, called Food Safety Plan Builder, or FSPB for short. I had been eagerly awaiting its release, which happened in August 2017. This article will share my experience of working with the software – and the FDA when problems arose. To reassure anyone who is concerned, this is entirely downloaded software, none of it is “in the cloud” or stored on some lurking governmental server computer. The FDA has no access to this, unless you send them a copy or they show up to inspect.

Our Existing Food Safety Plan and My Background

I had a fairly complete food safety plan in place for our company, Gia’s Cheesorizo and our previous business, Pholia Farm Creamery. Our plan had some gaps that I was aware of and probably more than a few that I hadn’t yet discovered, not to mention it consisted of stacks of binders and no simple way to navigate the entire body of info. As members of the Oregon Cheese Guild, we have some exceptional resources for plan review thanks to Dr. Lisbeth Goddik at Oregon State University. We are on the list for a “mock 3rd party audit” during which our plan and our process would be scrutinized. We are also working with UL Everclean (a large company that does 3rd party audits), but were in the initial stages.

FoodSafetyBInders

I have taught a decent number of classes on developing basic food safety plans for small cheese producers. My emphasis in these classes is helping people understand the concepts so that developing and implementing the programs makes sense. Working with the FSPB will come most easily for those who have had at least one thorough class on food safety plans. Later in the article I include a link to a pdf of one of my classes on the subject.

The Download Lowdown

The initial download of the software went fairly well after I realized that I didn’t have unzipping software on my old Windows 7 computer. The instructions on the FDA page for downloading were and helpful, but on my newer Windows 10 computer, I found that the “unzip” option is now called “extract files”. I downloaded the program to more than one computer so that I could work on the plan while traveling and in the office. (Download the plan at www.accessdata.fda.gov/scripts/foodSafetyPlanBuilder/ )

When I was a week or so into the program, however, it hit a glitch and wasn’t performing as advertised. Namely (in case you accidentally end up with the first version 1. 0 0 0 instead of 1.0_0_1) that once the Hazard Analysis tab is completed and you’ve moved to the subsequent tabs and then go back and make changes to the hazard analysis, then importing those changes to the subsequent process controls tabs failed. I used the link provided on the instruction page of the FDA’s link to contact them for help. They were quite quick to respond, but it was a bit of an insight when they got me on the phone and we spent about 25 minutes trying to trouble shoot the problem. There were two people helping, one an admin person and the other IT. The Admin guy seemed to really want to wrap it up and get home for the weekend and the IT guy, with a lovely Russian accent, wanted to figure it out. In fact, even though the admin fellow finally gave up and said they would get back to me the next week and had the IT guy hang up, the IT fellow kept at it on his own and then emailed me about an hour later with the fix. Hurray for IT! Bottom line, be sure you have version 1.0.0.1 – or even newer if they make further updates (which I hope they will as you will read in a bit).

Video Tutorial and ACS Helpful Docs

You’ll definitely want to watch the video tutorial. It’s a good overview of the program and kind of prepares you for the lack of intuitiveness and the redundancy of some of it. I wasn’t surprised by these characteristics as anything produced by a regulatory body is likely to be such, in my experience. (My husband was a career Marine Corps officer, so we’ve had our fair share of experience with the realities of beauracracy.)

I used the American Cheese Society’s page Safe Cheesemaking Hub to access some sample documents to help me along. In particular two documents were super helpful: The first was created by the Center for Dairy Research (thank you Marianne Smukowski and team!) and is called “Food Safety Plan for Pepper Jack Cheese”, the second is “Food Safety Workbook for Farmhouse Cheesemakers”. Visit the Hub and its templates page at:  http://guides.cheesesociety.org/safecheesemakinghub/templates

The first of these is helpful as it uses a product, pepper jack cheese, as a cheesemaker’s-real-world example. It helped me understand better what the FSPB was trying to do. The second document, a publication out of Ireland, is the best I’ve ever seen on the topic of farmstead cheesemaking as it includes the milk production side of the equation. If you are already a farmstead cheesemaker, then you KNOW that without scrupulous process controls of things such as animal health and milking hygiene, then your cheese might not be safe. Here in the states, the FDA doesn’t want to include these areas, as they are not under their jurisdiction as inspectors. But YOU can take that into your own hands and include documentation of the farm-side practices in your plan. I used this booklet and its handy checklists to track our practices and then entered them into the FSPB software. I’ll go over some of the differences and what you’ll have to work around in the “Working with the Tabs” section.

FSPB Overview

The program is arranged by helpful tabs that correlate with sections that you complete in order of their presentation. It starts out pretty simply and fortunately you can make changes to each section as many times as you need (quite a few times for me).

There are some terminology and methodology differences in this program that I think are quite sensible and forward thinking. Namely the lack of the term “Critical Control Points”. It was always confusing to me to create a plan and then try to segregate out which steps were the most important and then write a separate document just for them. Instead this approach identifies every step along the way and the “process controls” that you use to reduce any risks associated with that step.

When you click on each tab, you are presented first with a dialog box which is meant as an introduction. I recommend reading these the first time. Sometimes they are helpful, others they are redundant. You can select “do not show this again” if you get annoyed, but in my version, they reset and appear every time I reopen the program. Grrr.

Once a tab is fully opened, the presentation gets a little clunky. On the left is a helpful outline of what is inside the folder. Usually this outline is created as you add information, but in some cases, it is partially or totally preexisting. In the center is the meat (or should I say, the “paste”) of the software, where you see what you are working on and add information. On the right is the section that is the most awkward. In fact, I stopped paying attention to it as it seemed redundant, then low and behold, it did contain useful information. In general it is quotes from pertinent sections of the Code of Federal Regulations and therefore, by nature, hard to understand. Often it is not pertinent to the small producer, at least in wording. I suggest always looking at the information, but don’t let it confuse you if it doesn’t make sense at this time!

Working with the Tabsfspb

Depending on the size of your company, some of the tabs might not apply to you. As usual, I’m going to focus on information that is most likely to help small producers (not only because that’s what we are, but because the big guys are going to have a qualified individual or team working on this, it won’t be the farmer/owner. Here are the tabs you’ll be completing – in the order you will complete them (think of this as your table of contents) and some information about working with them:

Facility Information

Where you are located, your FDA premises ID number, and who is on your safety team. Everyone must have a FDA premises ID. The safety team might just be you, or you and your partner.

Preliminary Steps

Information about what you make and how you make it. This part is fairly straightforward with the exception that they call the process steps a “flow diagram” and that it instructs you to “enter all of the steps from each flow diagram”. I guess they are assuming you have done an actual diagram on your own. I expected it to generate one for me after entering the steps, but it does not. Flow diagrams are very helpful, though, and if you want to create one on your own, both of the downloadable documents from ACS include examples.

GMP and Other Prerequisite Programs

The first part of this tab is an acknowledgment of your review and acceptance of the Good Manufacturing Practices as defined by our government. If you haven’t ever actually read the GMP’s, it’s a good idea to do so.

The second part, “Other Prerequisite Programs” is for documents you have created elsewhere such as SSOP’s and SOP’s – instructions for cleaning, sanitizing, and performing tasks. The FSPB does NOT help you create these documents! My “No Hassle HACCP Power Point ( pdf version, might help you. This part of a food safety plan is very important and also very time consuming. But just get it started and keep adding as you have time. A plan in progress is better than no plan!

Hazard Analysis and Preventative Controls Determination

This is probably one of the most helpful sections, but since it comes early, it is also a bit confusing, at least to me. To help me understand this step, I relied heavily on the corresponding portions of the Pepper Jack cheese food safety plan (that I mentioned earlier). Even then, I had to go back and make changes and corrections as I went through the subsequent tabs. You have to do this section before you proceed, though. Once complete, the software will generate a nice table that should make any regulator beam (only on the inside, of course). The table (as viewed in the Food Safety Plan tab) would really benefit from some pertinent headings for the 6th-9th columns.

Process Preventative Controls

When the previous section is complete you can work on the next four tabs, the preventative controls, in any order you like. In each you will import the Hazard Analysis once and then again if any changes to it have been made. If you have done a decent job identifying the risks at the proper step, then these sections are fairly straightforward. BUT, the questions/directives are a bit cumbersome and the tables generated are a tad silly in that they include the directives in the table. I really hope this is addressed by the creators rather than later as it results in a document that is much harder to understand than is necessary. Compare it to the pepper Jack cheese process preventative controls and you’ll see what I mean.

Food Allergan Preventative Controls

For most cheesemakers, this step won’t be too complex as we are usually working with only one allergen, milk. This is addressed by ensuring that the product includes a label that lists milk. You don’t have to worry about cross contaminating a non-milk product produced in the same plant. If you use any ingredients that are allergens, though, cross contamination must be addressed.

Sanitation Preventative Controls

When I got to this section, I initially thought it was woefully short on usefulness, as sanitation preventative controls are really the core of safe cheese production. I muddled around with it and was griping to my husband about its shortcomings when I noticed that the Supplementary Information side (on the right) had a useful directive at the very bottom:

“Instead of describing the sanitation preventative controls in the “Comments” box you could reference an attachment(s) and place that document(s) in the “Supporting Documents” tab.”

 Okay! That would have been nice to see first. So here is where your hard worked SSOP’s can be cited. The “Supporting Documents” tab, you can add documents to it at any time, allows you to attach all of your SSOP’s and SOP’s (or whatever you call the detailed descriptions and step by step instructions of how you do each task such as cleaning, washing, and operating equipment). Unfortunately these docs won’t appear when you click on the “Food Safety Plan” tab, but they will be accessible to any regulator or insurance person reviewing your plan. I suggest printing them all out and putting them in the pertinent sections of the plan generated by the FSPB.

Supply-Chain Preventative Controls

I also found this tab confusing. But it boils down to one question. “Do you use any ingredients that include a potential hazard and your process does NOT include a kill step?” For example, if you herbs to your cheese and don’t boil, Pasteurize, irradiate, or otherwise treat them first, then you will need to fully address this section.

Recall Plan

Our existing recall plan was already one of the strongest parts of the plan. I know too many people who have gone through a recall and of those, the only ones that survived it had a solid plan in place. If you don’t have a solid recall plan in place, step up its priority! In fact, I’d almost recommend doing it FIRST, it helps light a bit of a fear-fire under you which is great motivation for completing the rest of the plan!

When you complete the “external notification” section aka “recall press releases”, don’t just copy and paste the suggested talking points from www.fda.gov/Safety/Recalls/IndustryGuidance/  instead, copy, paste them and fill in as much as possible ahead of time. If you ever have a serious recall, you will likely find that you aren’t thinking clearly and will be very glad that these important documents are almost ready to go.

I chose to import our current plan into the Supporting Documents tab and then reference it in the comment section of the Recall Plan tab. When I print out the entire food safety plan, I’ll print out and insert our recall plan and place it in the binder.

Reanalysis of Food Safety Plan

Having just done the initial work in this software, this step isn’t pertinent to me yet. In addition it states that such work “must be done by a preventative controls qualified individual (PCQI)” Our company is too small to require such training at this time. But read the info in this section anyway, it will help you understand the expectations of others.

Food Safety Plan

The Food Safety Plan tab creates a printable document of all of the information you have filled in and organizes it into sections that should make an audit or FDA inspection much easier, at least from the navigation standpoint. It will also make updating and refining your plan very easy. I’ll cover more about the awkwardness of some of the information generated in this tab in the next section.

Signature

This is totally self-explanatory and easy to complete.

 Record Keeping Procedures

This is a checklist of topics that you will complete when your plan is done. The first section is self-explanatory, but the part 2, with just one question, confused me. It states “The facility maintains records of the basis for NOT establishing a preventative control, if applicable”. After reading the section of the code that applies, CFR 117.136, I can’t foresee an instance when any small to mid-scale cheesemaker would click “Yes” in response to this statement. An example of a time when “yes” would be appropriate, would be when a cheesemaker sells tainted product to a secondary processor who will reprocess it and makes it safe. But most of us won’t be doing that. Step 4 is a follow up to this query.

 Important Contacts

This tab is easy to navigate. I appreciated that it included the FDA contact links that can be a pain to track down. I already had some of them in the recall plan, but these were nice to find here. We use a wonderful inventory management software called Fishbowl Inventory which integrates with Quickbooks – creating every tracking document we could ever need as well as allowing me to update company contact information in one report. So I didn’t include company contact information here, instead I referenced this software as well as will print out a report of contacts for the FSP binder.

Supporting Documents

This is where you will create links to documents on your computer or online that round out your plan. All SSOP’s, existing recall plans, floor plans of hygienic zones, and research articles that support a practice (for example wood shelving maintenance and safety). There should be a lot of documents in this section. I suggest naming them in a way that makes them easy to navigate in case of inspection or audit, such as beginning all research articles that pertain to a process control with that word or acronym. Such as a preventative control related document: PC_Dry_Ingredient_Kill_Step. Something along those lines!

The problem with the way this tab functions is multi-faceted. First, you can only add one file at a time – not highlight and move an entire set of files. Second, once imported, the folder that is automatically created was hard to find on my hard drive. (The instructions as to where to find this folder are vague, at least to a non-tech-savvy person such as myself). Third, you cannot drag and drop files into the folder created directly from Windows File Manger – you can copy them to the folder, but then they don’t appear in the FSPB program. And finally, if you want to make changes to these documents, you’ll have to work directly in this new folder, not where you originally created or kept these documents, so be sure to either rename them or otherwise tag the old versions so that you don’t mix them up.

 Conclusions

I love that the FDA has created this software! I think it can definitely be improved, but you have to start somewhere. The most unhelpful tab currently, in my opinion, is the Sanitation Preventative Controls. I would appreciate seeing templates for SSOP’s, hygienic zoning, environmental monitoring, and the like integrated into this section. I think this is the area that most cheesemakers would really love help understanding and creating.

It would also be great to see the table for process preventative controls (created in the Food Safety Plan tab) more closely resemble the example in the Pepper Jack Cheese document created by the Center for Dairy Research.

Bottom line, this program should help most of us fill in some gaps in our existing plans, create a sound new plan, understand what the regulators are focused on, and come up to the expectations of the FSMA. Give the FSPB a try.

 

Advertisements

Goat Midwifery – an Excerpt from “Holistic Goat Care”

To Pre-order Holistic Goat Care (out early June 2017) visit the book’s listing at Chelsea Green Publishing or Amazon

The Assisted Delivery

 Over the years I have become quite good at sorting out kids tangled up inside the womb and successfully delivering them. There’s no way to develop competence at assisting during difficult deliveries, though, without having to go through some very stressful and challenging times. I learned early, when I still needed a vet’s help during particularly difficult deliveries (dystocia is the proper term), that the essential attitude to cultivate for success is a combination of patience and persistence. If you are lucky enough to have a goat mentor who will let you be present during deliveries then you will gain a lot of useful knowledge. That same mentor might be willing to walk you through the steps over the phone. When I teach our “Goat Academy” here at Pholia Farm, I try to time it for a week when several does are due to kid just for that opportunity. And hopefully this book can help you learn the skills needed to assist during deliveries.

I always err on the side of helping a doe earlier in the process, rather than regretting later. My perspective is that the animal is only in this predicament due to my choices, so she deserves my help. Another part of my viewpoint is the potential to decide to stop breeding a doe for good if difficult deliveries are her norm.

Seven Things to Remember During a Tough Delivery

  1. Keep calm!
  2. Take your time. Move methodically and slowly inside the doe.
  3. Give the doe and yourself a break every 5 to 10 minutes.
  4. If the delivery requires intervention that increases the doe’s pain to the point of causing her extreme distress, administer pain medication (Banamine, which requires a vet’s prescription, is a good choice.)
  5. Medicate yourself! Have a helper bring you a quick shot of tea or even whiskey.
  6. Give the doe a dose of high-potency oral nutritional supplement during the delivery, between kids or pushes, and when delivery is over.
  7. Keep calm!

When a doe is in labor and you’ve decided that further manual exploration is necessary, first take a few moments to gather your

Presentation 1 (see details below)

supplies—which hopefully will all be near at hand already. Fill a pail with a warm water and Betadine wash solution (follow the dilution instruction on the bottle). Be sure your fingernails are trimmed, remove any rings or bracelets, and put on gloves. You can use long OB gloves if you like. A trick I learned (from that patient vet I mentioned earlier) that leaves your fingers more agile than using an OB glove alone is to cut the fingers out of a long OB glove, put a nitrile glove on your hand first, and then put on the fingerless long glove over it. It’s preferable to use your dominant hand for exploring the doe. This may mean you have to roll her over. If it’s not possible to do this, you can use your non-dominant hand, but it will feel more awkward. If the doe is standing, ask an assistant to try to hold her head to keep her still.

Wash the doe’s backside with a bit of the warm Betadine solution, then dip your gloved hand and forearm in the solution and shake it off. Dispense a generous amount of lubricant, either gel or powder, on your gloved fingers. You don’t need to squeeze it all over your hand; it will spread as you enter the doe. Repeat this process whenever you reenter the doe.

Presentation 2 (see details below)

With your other hand, lift her tail. Bunch your gloved fingers together, holding them straight, with your thumb tight to your palm, and then insert the fingers into the vagina. The doe is likely to begin pushing as the pressure of your hand in her pelvic canal stimulates that response. You will have to push against it. Slowly but steadily continue to move your fingers forward, then your hand. As you move forward, note the tightness of her pelvis and the dilation of the cervix. When the cervix is fully dilated you might find that as your hand goes into the vagina, the cervix will feel like a funnel, with the small end toward the uterus. You will feel the rings of the cervix and maybe even feel parts of a kid through the cervical tissue. Do not mistake the tissue of the cervix for an amniotic sac and try to push through it! Instead, continue straight forward until you find the final cervical ring. Then your hand will enter the uterus. Sometimes the body of the uterus will feel large and spacious; other times it will be small and tight, with the kids positioned in the horns.

In this collection of illustrations you will see many of the possible presentations of kids—but not all of them! The possible combinations of presentation that can occur is huge. Because

Presentation 3 (see details to left)

the scenarios can be quite complicated and because you will likely be anxious in the moment when a delivery is taking place, I recommend you take the time to study all the illustrations below well before kidding season arrives. Imagine each one, and mime the movements you would make with your hands to assist in the delivery. It can make a big difference should an emergency occur.

Other possible presentations not shown here include a normal front presentation, but with one front leg crossed over the neck; two twins presenting normally, but both trying to exit the uterus at the same time, and so blocking each other’s way; a kid presenting stifle joint first (this is so hard to imagine, even though I’ve seen it occur, I couldn’t figure out how to draw it!); and back pressed against the cervix. And there are many more; too many for me to describe here.

Guide to Common Kid Presentation Illustrations

(Note, illustrations show the pelvis as transparent so that you can view the uterus and kids. In reality the kid passes through the pelvic outlet between both sides of the pelvis)

Presentation 1: Normal presentation of twins, one in each horn of the uterus, before labor begins.

Presentation 4

Presentation 2: Normal presentation of twins, delivery of twin in right horn, front feet and head first. No assistance should be needed.

Presentation 3: One front leg and head first, one front leg back. Usually no assistance is necessary. If help is needed, apply gentle pulling pressure to the presented front leg and around the kid’s skull. If this presentation is determined before the kid’s head clears the pelvis, the front leg that is back can be repositioned.

Presentation 4: Normal presentation, back legs first.

Presentation 5: When a small kid presents butt first and the back legs are forward, no assistance is usually needed. But in this instance, two more kids are present. The one in the left horn is a larger kid, with front legs and head first. In this case, the larger kid may block the exit of the smaller, backward kid. You can gently push the smaller kid farther back into the uterus and deliver the larger, normal-presentation kid first if needed. The last kid is upside down in the right horn. As it is pushed by the contractions up toward the cervix, it may rotate on its own so that it isn’t upside down. If not, you may need to gently rotate its head and front legs before the kid can clear the pelvis and be delivered.

Presentation 5

Presentation 6: Butt-first presentation with hocks bent, causing the kid to lodge behind the pelvis. To assist, reach in and gently push the kid toward the mom’s head. Then follow each back leg down to the hock, continuing to push the kid back in as each contraction pushes it toward you, and hook the lower legs up and toward the cervix. Once they are freed of being caught behind the pelvis, they will quickly extend backward into the vagina and the kid can be easily delivered.

Presentation 7: This kid is almost in a normal presentation of head and front feet, but its elbows are back just enough to cause the shoulder blades to broaden and become wedged in the pelvis. This is sometimes called elbow lock. It can happen with the kid a bit farther out, too. When it does, push one leg backward a bit and pull gently on the other leg and the head.

Presentation 8: In this drawing twins are presenting with the left twin in a normal, back-legs-first presentation, but the larger twin in the right horn is head first with the front legs back and

Presentation 6

is blocking the cervix. In this case, the doe may not even dilate fully or perhaps not try to push. When you reach in, you will feel the larger kid’s head and perhaps the back feet of the other kid. If you aren’t sure if they are back feet and even which kid those feet belong to, follow the neck of the larger kid to its shoulder then down to the front legs. Then you have two options: You can push the bigger kid back in a bit and hook up and bring forward its front legs, one at a time, and deliver it first; or you can push it down into the horn and deliver the other kid first.

Presentation 9: In this common presentation the front feet are first, but the kid’s head is down. Help is usually required. Reach in and gently push the dome of the head back in toward the mom’s head until you can reach under its chin and lift the muzzle up between its front legs. While you do this, you may “lose” a front leg and have to hook it back up and make sure it stays in place as the kid moves into the birth canal. Less common but with a similar presentation is front feet with the head turned to the side. In that case, when you reach in you will feel the neck at the throat. Push on the neck to move the kid back in a bit, then follow the neck to the head and swing it around. When it has been bent down or sideways, it will want to move back to that position, so keep your hand on the dome of the head until it moves into the vagina.

Presentation 7

Presentation 10: The first kid presenting has its head down and its front feet back. A triplet in the left horn is presenting normally with front feet and head, and a triplet in the right horn, below the first kid, is presenting normally, but backward. Because the first kid is blocking the cervix with its forehead, the doe may not have fully dilated or may not be pushing. When you reach in, you will feel the forehead of the first kid, but you will also likely feel the front feet of the kid on the left and maybe even the back feet of the other kid on the right. You’re likely to want to first raise the head of the kid, but be sure you determine which kid’s feet belong to that head! Once the kid that has been blocking the exit has been delivered, the other two shouldn’t need assistance if the doe is still strong and pushing.

Presentation 11: When the cervix hasn’t fully dilated it might feel like a funnel when you palpate it. You will feel the other rings as your hand moves toward the uterus. The last ring will be the smallest. Because of the funnel-like form, you might feel the kid through the cervical tissue. Don’t mistake that tissue for an amniotic sac and try to break through it to reach the kid!

Presentation 8

Presentation 9

Presentation 10

Presentation 11

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(All of the above illustrations will be found in full resolution in the book along with a complete guide to Breeding, Pregnancy, and Delivery in Chapter 8)

Illustrations copyright © Gianaclis Caldwell 2017 

DIY: Traditional Rennet

Warning: This post has a few photos that might bother some – internal organs just after being harvested. 

Although I’m a vegetarian in all other respects, I do eat classic cheeses such as Parmigiano Regianno and Roquefort, all of which are made with traditional rennet. I also butcher animals on our farm to feed my family. Included in that menu is the occasional goat.

Cheesemaking is a huge part of my life. I’m inquisitive nature and always wanting to learn more about all aspects of cheesemaking. One of those aspects that I had no experience with is the harvesting of a kid and production of natural rennet.

An opportunity presented itself while I was teaching a week long goat care class here at our farm and the attendees expressed an interest in learning how to butcher a goat. Athough slaughter and butchering are a very somber, intense, and private experience for me, I believe strongly in helping others learn not only how to do it properly, but that it can be a beautiful and educational experience as well.  The saying “every animal deserves a good life, a good death, a good butcher, and a good chef” is one of my favorites. So we selected a candidate, a two week old buckling. Not only would the students learn to butcher, but I would harvest the abomasum (the fourth stomach from which traditional rennet is made), our intern Amanda would tan the hide, and the entire

Baby ruminants are truly the first cheesemakers! These cheese curds were in the abomassum of a two week old kid.

Baby ruminants are truly the first cheesemakers! These cheese curds were in the abomassum of a two week old kid.

class would feast on roasted, suckling kid for our final meal.

 

I had read several accounts of how to harvest and make kid, calf, and lamb rennet. All of them varied and all of them stated that the curing time for the organ was anywhere from 6 months to a year. Hmm, why would that be, I wondered? The kid makes cheese curds immediately in its stomach, so it wouldn’t be for the sake of effectiveness. I believe now, but haven’t confirmed, that it might have to do with safety. The long pickling time might be to anticipate parasites or pathogens present in the organ. One of the students in the class told me that she had a Greek cheesemaking friend and would find out what he knew. Fortunately his recipe for kid rennet took only a few days of processing. The resulting rennet works beautifully!

I have made two varieties of our cheeses using the same batch to make one wheel using the homemade rennet and the rest of the batch with what I usually use. This way they will age side by side and any flavor differences will not be due to different milk or cultures. I’m still waiting for the cheeses I’ve made with it to age, but will report back to you on the flavor comparison. One of the cheese types I made usually uses purchased traditional rennet and the other microbial. So it should be quite interesting to compare. I can’t wait!

The abomasum is on the left in this image.  The esophagus can be seen at the bottom and the intestines at the top right

The abomasum is on the left in this image. The esophagus can be seen at the bottom and the intestines at the top right

The inside of the abomasum is covered with gentle folds of skin

The inside of the abomasum is covered with gentle folds of skin

 

 

 

 

 

 

 

 

 

 

Instructions for making kid, lamb, or calf rennet

  1. Harvest the abomasum of a kid, calf, or lamb under two weeks of age is ideal
  2. Rinse with non-chlorinated water, but don’t scrub
  3. Weigh the abomasum and place in jar.
  4. Add 12-15% salt and enough water to cover
  5. Let set at 65-70F for 24-36 hours
  6. Remove from the salt brine and shake off.
  7. Hang to dry in a cool room (no warmer than 70F) and dry until hard – depending on size 1-2 weeks.
  8. Weigh then cut into thin strips and place in food processor or run through a meat grinder.
  9. Slowly add 8 parts non-chlorinated water and process or use mortar to grind into a slurry or paste.
  10. Pour through a fine cloth, pressing with a spoon to extract as much liquid as possible.
  11. Add 4-5% salt by weight
  12. Keep in fridge.
  13. Use about ½ tsp (2.5 ml) per gallon (4L) of milk (you may have to adjust amount,  milk at 95F should coagulate within 10 min.)
  14. Lasts about six months in fridge.
The abomasum after drying

The abomasum after drying

Straining the rennet paste and brine after processing in food processor

Straining the rennet paste and brine after processing in food processor

During storage in the fridge, the whitish portion separates quickly from the salt water. I’m gently agitating mine periodically and for sure right before using. When used at the recommended ½ tsp (2.5 ml) per gallon (4L) of milk, our milk flocculates in under 10 minutes. So likely a bit less of the mixture is needed. So far, the strength hasn’t changed, but it’s only been six weeks since it was harvested and the processing begun. The strength could be checked before use using the steps in my book, Mastering Artisan Cheesemaking, for testing rennet (page 47) to better calculate the dosage before using.

The kid I harvested was exactly two weeks old and hadn’t yet started to chew his cud. This is ideal, however younger would mean an even higher proportion of chymosin to pepsin (the best natural rennets have at least 95% chymosin). Older animals will have increasing amounts of pepsin that will still coagulate milk, but can lead to bitterness in aged cheeses. Our kid was half Nigerian Dwarf and half Lamancha, so not a very large animal. The abomasum yielded about ½ to ¾ of rennet liquid after processing (I forgot t.o measure it before I used some!)

The Greek cheesemaker, who makes barrel aged feta in Greece and who now uses industrially produced kid rennet, says his cheese hasn’t been as good since he switched. It’s a shame when concerns over food safety also remove aesthetic diversity and opportunities for cheesemakers to craft unique products.  I’m actually not sure what would be involved to legally be able to use “small batch” rennet. Certainly the animal would have to be slaughtered at a USDA facility, but I imagine the process steps would also have to take place in an inspected facility with a meat processing license. Oh well, that doesn’t have to stop any of you from trying this at home!

I recommend Adam Danforth’s book Butchering for an even more in depth, artisan approach to harvesting meat.

 

Early Release Signed Books

PrintHot off the press, I have 100 copies of my new book available now! (Before the official release date March 2016). If you would like to purchase a signed copy I can mail it to you or as a gift to someone else. The cover price is 29.95. I will ship it priority mail for 35.00.  Let me know who to sign the book for and if you want a gift note included.

Book details: Full color, 151 pages, a Mother Earth News Wiser Living recommended book, published by New Society Publishers

In the book I take the approach of teaching cheesemaking as organically progressing lessons – each cheese recipe adds a layer of information, technique, and ingredients. By the time you are through, you should truly understand how to make almost any cheese, and be ready to move on to the deeper science contained in my previous book, Mastering Artisan Cheesemaking (Chelsea Green Publishing).

You can pay via Paypal or check.
Buy Now Button

 

Disbudding – Using Sedation

In the archives you’ll find my article on the Dehorning Dilemma . Because I seem to like inspiring a bit of controversy, here is a video and instruction on how producers can sedate their kids (or calves) and disbud while the animal is semi-conscious. This drug also provides pain control (analgesia).  While some of you may wonder what could be controversial about pain control when performing painful procedures on animals, I have already come under a bit of criticism mostly from professionals who seem concerned that farmers can’t learn how to do this safely and animals will die. I, on the other hand, believe that most of us have the capacity to learn and deserve these options.

Burrata – Forming the Dumplings

As an augmentation to the article I wrote for the summer culture the word on cheese magazine http://culturecheesemag.com/diy/beautiful-homemade-burrata , here are step by step photos of how to make burrata sachets, dumplings, packets or whatever you want to call them!

When the mozzarella texture is just right, you are ready to form the outside

When the mozzarella texture is just right, you are ready to form the outside

Place the ball on a plate and gently flatten it with your fingers, making it as even as possible

Place the ball on a plate and gently flatten it with your fingers, making it as even as possible

Place a well packed dollop of the ricotta and butter mixture in the center

Place a well packed dollop of the ricotta and butter mixture in the center

Gather two sides together in the middle, overlapping and press them together. Gather the other two sides, squeezing closed any openings, and overlap in the center.

Gather two sides together in the middle, overlapping and press them together. Gather the other two sides, squeezing closed any openings, and overlap in the center.

Place the closed packet on the ladle, with the overlapped edges down and immerse the bottom into the hot whey for a few moments, this seals the packet

Place the closed packet on the ladle, with the overlapped edges down and immerse the bottom into the hot whey for a few moments, this seals the packet

Serve immediately or cool in bowl of cold water then wrap and chill. Best right away, though!

Serve immediately or cool in bowl of cold water then wrap and chill. Best right away, though!

Aging Cheese on Wood Shelves and Food Safety – a Non-Issue

Wood Shelves

Don’t be afraid!

As a person who tends to want to follow rules, it is sad to be reminded that a good portion of food production regulations have little to do with actual food safety, rather they are the result of a ponderous, rigid system that steam rolls forward, sometimes based more on the ease of generalizing rather than the complexity of reality. The FDA has never liked wood shelves, especially when you sit food, in this case naturally rinded cheese, directly on its porous surface. Wood does not fit their Good Manufacturing Practice (GMP) model for a cleanable surface. While wood aging shelves have technically never been okay with the FDA, they have until now been mostly ignored and the decision to allow them been left to individual states .In many” big cheese” states, the regulators defer to the scientific knowledge of the leading expert within each state. For example, in both Oregon and Wisconsin (where at least 30 million pounds of cheese is aged on wood each year) the departments of agriculture have an official stance of “no wood shelves”. But in both states if a cheesemaker gets a thumbs up from the academic expert regarding their maintenance protocol for the shelves, then they have been allowed.

Isn’t that sensible? Did you hear me mention the words “scientific knowledge”? Let’s review what is well researched and known about wood shelves. (I’ll give you some references at the end of this post). Guess how many outbreaks of food borne illness they have been implicated in since the dawn of cheesemaking? Zero. This doesn’t mean that pathogens can’t exist on a wood shelf. If a cheese is contaminated and the wood poorly cared for, it will pass it to the shelf, no matter what material it is made from. Contamination of any aging shelf can happen when poor practices occur at any stage of cheese production, but it is not any more likely when wood is used. Bottom line.

Pros and Cons

So why do cheesemakers and affinuers (the folks that age cheese) love wood shelving? Tradition? Romance? Practicality? In the days before the invention of plastic, that ubiquitous, malleable material that we now take so for granted, wood was the logical and singular option. But fortunately it was also perfect. Like naturally aging cheese, wood “breathes”, it holds moisture without being wet, pulling it both out of the cheese, but also helping keep the aging space at a steady level of humidity. Not unlike the natural stone walls and bricks of the pre-modern aging space. Wood shelves used in aging room also take on the same family of fantastically helpful microflora – yeasts, molds, and especially bacteria – that help create distinctive, out-of-this-world cheeses. The usefulness of these microbes has not only to do with flavor, but also with the final safety of the cheese.

Given what I have just told you about how awesome wood shelving is, why isn’t everyone using it? (At least 60% of American Cheese Society cheesemaker members do) Or at least trying to use it? First it is, not surprisingly, highly discouraged thanks to the stance of our federal friends.  Second, the knowledge of how to properly care for wood is tucked away in the minds of a few and only a smattering of books and papers. Third many make only fresh cheeses where aging is not used. And finally, it is more work. More work is not what most cheesemakers need or can even contemplate. Let me tell you about our experience with wood shelves in our own aging room.

Wood Shelves at Pholia Farm

A few years ago we got permission from our inspectors to use wood shelves as long as we consulted with Dr. Lisbeth Goddik,Oregon State University’s Dairy Extension Specialist – a darned amazing woman. She suggested routine cleaning of the shelves with mild soap and warm water, then after rinsing with plain water either wiping the boards down with vinegar or a lactic acid bacteria wash. We did both. We marked which side of each shelf was treated with vinegar and which with bacteria. After aging the cheeses for many months, and before selling them, we swabbed the shelves and sent samples of the cheese to Agrimark lab. All results, for cheese and shelves, whether vinegar or lactic acid bacteria washed, were free from pathogens. So why did we stop? Ironically enough it was another aging room reality that is on the FDA’s hit list (not recent hits list…) cheese mites. I won’t go into too much detail about these little buggers (see one of my most popular posts for all of the itchy details), but what is pertinent is that the dark underside of the cheese sitting on the board was very desirable real estate for the mites. This required more frequent cheese rind labor, something that we were not prepared to do at that time. But I am now.

 So Why the Ruling?

Consider for a moment that the FDA is tasked with an enormous responsibility. As that responsibility grows and food systems expand it becomes more expeditious to simplify. This means generalized rules that apply to everyone – versus thoughtful, logical exceptions. Think about it, before a couple of decades ago, you would be hard pressed (like one of those fabulous wood aged European Comtes) to find any US made cheese that was aged in a cellar type situation with a natural rind. Consequently the paradigm for aging became a squeaky clean walk in cooler. The regulations that developed reflected that reality. With the looming burden of the Food Safety Modernization Act, it’s not surprising that they are now seeking to streamline and enforce existing regulations, rather than allow states to take the responsibility of allowing exceptions.

As we move forward as cheesemakers, I think we need to nurture a new paradigm, one in which the aging room is not treated as a processing room, but as a separate type of space in which a different set of GMP’s apply. When I was at a cheese science conference in England, it was repeatedly said that “The dairy/cheese plant is NOT A HOSPITAL”, nothing could be more true in a room in which you are counting on microbes to flourish.

What Can We Do?

I am a member of the American Cheese Society’s Regulatory and Academic committee. This morning (June 10th) we finalized the press release and position of the largest body of cheese professionals in the United States. (See the document at: http://www.cheesesociety.org/wp-content/uploads/2014/06/ACS-Statement-on-Safety-of-Aging-Cheese-on-Wood.pdf )

So support ACS (join if you are not a member), contact your state representatives, let the FDA know how you feel, and most importantly keep buying and making great cheese! Now, I am going to go put those beautiful Pacific maple shelves back in the aging room. Watch out cheese mites, I’m watching you!

References
The best overall summary of the topic: Donnelly, Catherine, Cheese and Microbes (2014), American Society for Microbiologists, 171-174
Ak, N. O., Cliver, D. O., & Kasparl, C. W. (1994). Decontamination of Plastic and Wooden Cutting Boards for Kitchen Use. Journal of Food Production, 57, 23–30.

Guillier, L., Stahl, V., Hezard, B., Notz, E., & Briandet, R. (2008). Modelling the competitive growth between Listeria monocytogenes and biofilm microflora of smear cheese wooden shelves. International Journal of Food Microbiology, 128, 51–57.

Mariani, C., Briandet, R., Chamba, J.-F., Notz, E., Carnet-Pantiez, A., Eyoug, R. N., & Oulahal, N. (2007). Biofilm ecology of wooden shelves used in ripening the French raw milk smear cheese Reblochon de Savoie. Journal of Dairy Science, 90, 1653–1661. 

Mariani, C., Oulahal, N., Chamba, J.-F., Dubois-Brissonnet, F., Notz, E., & Briandet, R. (2011). Inhibition of Listeria monocytogenes by resident biofilms present on wooden shelves used for cheese ripening. Food Control. 

Nese, AK, Cliver, Dean, Kaspar, C. (1994). Cutting Boards of Plastic and Wood Contaminated Experimentally with Bacteria. Journal of Food Protection, 57(1), 16–22.

Oulahal, N., Adt, I., Mariani, C., Carnet-Pantiez, A., Notz, E., & Degraeve, P. (2009). Examination of wooden shelves used in the ripening of a raw milk smear cheese by FTIR spectroscopy. Food Control. 

Schvartzman, M. S., Maffre, A., Tenenhaus-Aziza, F., Sanaa, M., Butler, F., & Jordan, K. (2011). Modelling the fate of Listeria monocytogenes during manufacture and ripening of smeared cheese made with pasteurised or raw milk. International Journal of Food Microbiology, 145 Suppl 1, S31–S38. 

Zangerl, P., Matlschweiger, C., Dillinger, K., & Eliskases-Lechner, F. (2010). Survival of Listeria monocytogenes after cleaning and sanitation of wooden shelves used for cheese ripening. European Journal of Wood and Wood Products, 68(4), 415–419.