There has been a lot of discussion on FaceBook about two recent recalls of artisan cheese, one by Bravo Farms in California’s Central Valley and the other, perhaps more serious, by Sally Jackson Cheeses of Oroville, Washington. Bravo Farms, which produces my favorite California Cheddar, “Silver Mountain”, is not tiny, but is small by any modern standard of a food production plant. Bravo suffered a recall when the California Department of Food and Agriculture found both Listeria monocytogenes and E.Coli O157:H7 at their plant. Cheeses were recalled even though, to date, no one has been confirmed to have gotten ill from eating their cheese. The later FDA report of Bravo shows twelve separate dates when a team of three inspectors visited Bravo over a 26 day period and found numerous – though I must say rather minor – violations. Sally Jackson Cheeses has a far more serious problem, because their cheeses have sickened at least 8 people with the very serious E.Coli O157:H7. As is evidences by both the photos on Jackson’s web site and the descriptions of the facilities in the FDA report, this is a tiny, ill-equipped “Mom & Pop” operation. The FDA report is rather shocking in the number and nature of violations for which Jackson was cited.
Both of these cheese makers focus on the production of raw milk cheese, which is perfectly legal as long as proper protocols are followed and the cheese is aged at least 60 days. I have tended, as a chef, to be the guy who sides unfailingly with the small, artisanal producer, believing in food as art and in traditional food handling techniques that predate and therefore trump most modern food safety regulations. Furthermore, I tend to see some food regulations as being reactionary once-the-horse-has-left-the-barn sorts of reactions to one-off food tragedies: some idiot does not know how to wash his hands properly and gets a bunch of people sick, so the rest of us are left fumbling around in rubber gloves all the time (and if you think those protect you, you should see that same idiot rubbing his nose with his gloved fingers right before making your BigMac).
So while I have always been as slavish adherent to the laws of kitchen cleanliness and sanitation (ask anyone who has ever worked for me about my love of bleach solution for sanitizing everything) and to drilling staff on hand washing, I have not always slavishly followed food regulations that would have prohibited me from making great, traditionally preserved foods. It has been my feeling that there are ways of handling food, particularly when preservation through fermentation, curing, drying and aging come into play, that the normal by-the-book rules of food handling would not allow, and that is not acceptable to a chef. Fermented sausages like classic salami, for example, have to be left for an extended period of time at what seem like an alarmingly dangerous temperature for a day or more or they will not ferment properly. It is that fermentation is what lowers the pH and helps make the sausage safe from botulism. Until about the last 60 or 70 years we didn’t understand how salami became salami: it was like magic, but it worked and people did not usually die from eating it.
Now don’t get me wrong. We have learned a lot in the past 70 years, and with food as well as with wine, that knowledge of microbiological activity has made it a lot easier to use the good bugs in our favor and prevent the bad bugs from making us sick or killing us. That said, we tend to over react, such as the ubiquitous use of hand sanitizer and antimicrobial soaps, which kill – according to their own labels – 99.9% of germs… leaving behind only the toughest ones, which now have no competition and can grow and breed out of control. Super bad idea if you ask me.
I have been of the belief, reinforced by what I have read over the last decade, that a lot for the food safety issues – surrounding meat in particular – are limited to CAFO meat and mega farm produce that comes in contact with CAFO run off or ground water contamination. So I have assumed, and I think a lot of chefs are in this boat, that if I bought the best possible meat from good, small, local farms, then a lot of the food born illness issues were a lot less likely to occur. An example of this is my comfort with serving medium rare grass-fed beef hamburgers to my daughters.
However, this latest recall has made me question some of my beliefs. What is interesting and chilling about the two cheese recalls is how quick my fellow foodies were to assume that Sally Jackson’s rumored decision to close up shop was as a result of heavy-handed regulation from the government. I do think that Bravo’s FDA report indicates that the inspectors spent a lot of time trying to find violations, and in the end what they found are really some pretty minor violations, such as failure to create a cleaning schedule for their cart and some gaps around doors that needed to be filled.
I might normally have tended to fall on the side of blaming regulation, but I do not know that I can in this case. That might be partly because I am annoyed by the current trend of blaming everything on the government, but it is mostly because of two other issues: One is that the Sally Jackson FDA report shows so many egregious violations, and I simply cannot support anyone who is that just plain sloppy and filthy. The second is that I realize one of my major assumptions about E. coli 0157:H7 may in fact be wrong.
I have to confess that I am one of those annoying foodies who tends to quote Michael Pollan. As they say about rock stars, I liked him before he was cool, back in his Botany of Desire days. Yeah, I love his early stuff. One of the things that I have been guilty of quoting of Pollan’s is this, (and this comes right from his website):
The lethal strain of E. coli known as 0157:H7, responsible for this latest outbreak of food poisoning, was unknown before 1982; it is believed to have evolved in the gut of feedlot cattle. These are animals that stand around in their manure all day long, eating a diet of grain that happens to turn a cow’s rumen into an ideal habitat for E. coli 0157:H7. (The bug can’t survive long in cattle living on grass.) Industrial animal agriculture produces more than a billion tons of manure every year, manure that, besides being full of nasty microbes like E. coli 0157:H7 (not to mention high concentrations of the pharmaceuticals animals must receive so they can tolerate the feedlot lifestyle), often ends up in places it shouldn’t be, rather than in pastures, where it would not only be harmless but also actually do some good. To think of animal manure as pollution rather than fertility is a relatively new (and industrial) idea.
Now I have a yard full of “fertility” and I have to say that, most days, I have a lot of “fertility” on my shoes. I have reveled in this poop. I am making some amazing compost, and making what is in effect fertile soil is as close to being God as you can get in my book. But now I find out that two small, artisanal producers have E. Coli 0157:H7 in their cheese, and while I do not know that the animals from which the milk came are strictly grass-fed, I do know that they are not from CAFOs or feed lots. In fact Sally Jackson has their own cows, which they raise themselves.
So what is going on here? I have been trying to find more information about E. Coli 0157:H7. I did find out that Pollan’s assertion that E. Coli 0157:H7 was unknown before 1982 is wrong: 1982 was the date of the first major outbreak of illness blamed on it, but CDC knew about it in the 1970’s and they are not sure where it came from. One other site I found – and admittedly this is a site from a personal injury lawyer who sues people over food borne illness, but bear with me – gave me the following:
E. coli O157:H7 bacteria and other pathogenic E. coli is believed to mostly live in the intestines of cattle (Elder, et al., 2000) but has also been found in the intestines of chickens, deer, sheep, and pigs. A 2003 study on the prevalence of E. coli O157:H7 in livestock at 29 county and three large state agricultural fairs in the United States found that E. coli O157:H7 could be isolated from 13.8% of beef cattle, 5.9% of dairy cattle, 3.6% of pigs, 5.2% of sheep, and 2.8% of goats. Over seven percent of pest fly pools also tested positive for E. coli O157:H7 (Keen et al., 2003). Stx-producing E. coli does not make the animals that carry it ill. The animals are merely the reservoir for the bacteria.
Now again, please forgive the source, and take the information with as many grains of salt as you like, but I am seeing multiple sources that are indicating that E. Coli 0157:H7 ain’t just for feed lots anymore. And this is just part of a larger problem that those of us in the rarefied world of food snobbery face. Another example is Joel Salitan, who I like a lot, who said in the movie Food Inc., that there was a study done that indicated that if chickens eat as little as a single blade of grass a day they will develop an immunity to salmonella. You can believe that if you like, but I would like a little more evidence than Joel’s testimonial or one study done by God knows who.
The world is changing, and even those of us raising pasture eggs and grass-fed goats for milk and meat cannot put our faith in fairy tales or bury our heads in the sand. We need to realize that even if a horrible pestilence like E. Coli 0157:H7 came from the Evil Feed Lots, now it has been loosed on the world at large and we all have to deal with it. We are not, as we hoped we might be, exempt from the decay of our global food system. There is a lot of fear out there that new regulations might harm small businesses. We will have to wait and see if the new, more powerful FDA under the new food safety law enacted this year, will actually make us safer. I do not know that it will, but I do know that their stronger ability to recall foods quickly could be a good thing.
Microbes far surpass us in creating novel genetic forms in the war of adaptation. They also have novel ways of meeting mates and trading information. We are stuck with slow and inefficient sex. We all know how poorly that strategy can sometimes go!
So while flies can act as go betweens and ind distant colonies of microbes, we can not do anything close to that, even with on line dating. Its no wonder the world is changing so fast. And this does not even bring up transponded or virally shuffled genes. We are literally left standing at the starting gate.
It is no great stretch to accept the ubiquity of this nasty E-Coli. It is not an ‘extraordinary claim.” Then we have the truly extraordinary claim about the “one blade of grass a day” prophilactive. It is a stretch and does require “extraordinary” proof. Or, at least, a citation of the study!
Dead customers is more harmful to enterprise than regulation. As Temple Grandon writes, regulation need not be complicated. In fact simple is more robust and enforceable and is tolerated more easily by the regulated industry (she inspects cattle walking into slaughter- if the cow falls, the line stops. period. then the company gets to work fixing the situation, not arguing why the cow fell, how many fell…ad infinitum)
So a simple metric should be: If a customer dies….not how much damage we will accept to profit in the industry.
Walt,
I hope that most of the issues we face in food safety can be addressed with more common sense mesures, like good hand washing, paying attention to potentials of cross contamination – which was almost certainly the issue at Sally Jackson Cheeses – and good sanitation practices.
In industry, because the liability is so high (deep pockets to be sued) and because the system is so grand in scale (so many cows, for example, in to the maw and so much meat shipped to the four corners of the earth) the tendency is to add layers of irradiation, for example, rather than to get the shit our of the food in the first place.
I stand for shit prevention rather than shit sterilization. I want to still be able to make and eat fermented sausage, for example, and since, for the time being at least, the middle of muscle tissue is essentially sterile and good handling can keep crap off of it, I can do so. At least until we get E. coli 0158:H8, if you know what I mean.
V
I agree that the overriding issue in producing safe food is unrelenting sanitation practices. The simpler, the better – keep the poop out of the food. We have to constantly ask ourselves about cross-contamination potential, and look hard at the infinitesimally remote routes that pathogens can take to contaminate our facilities. Analyze hazards, establish critical control points and best manufacturing practices, and follow them relentlessly.
I adore the old world practices, want to preserve them, and I acknowledge that we must make accommodations to address the new world pathogens.
I am committed to the safe, healthful production of aged, raw milk cheeses, and will do everything possible to bring pathogen free products to our customers.
G.S.