101 guide – Cheese Regulation & Good Practice | Chapter one
What is Regulation and Good Practice?
Regulations around Cheese
Eating cheese is and should be an enjoyable experience. It can only be so, however, if the cheese you are eating or selling is safe for consumption. This is the criteria for all cheese producers and retailers, but one which is made harder when the main reason for foodborne illnesses are something that cannot usually be seen.
Food safety compliance is not an easy undertaking for any food business owner; it is full of rules and regulations, procedures and paperwork. But it needn’t be dreaded and most definitely should not be disregarded. The fate of any cheese business lies both in the quality, safety and reputation of its products.
What are Food Safety Agencies?
Pathogenic microorganisms that are responsible for foodborne illnesses live on the food you prepare as well as on the food handlers themselves. These microorganisms can then travel from one place to another and spread their potential to cause disease.
The main aim of food regulatory bodies is to protect public health and the interest of consumers. These bodies ensure that food businesses have clear, understandable, and workable regulations in place.
All regulatory bodies across the world have specific laws, code of practices, and guidance documents relating to the control of food stuffs. These cover all parts of the food production and distribution chain including:
- Food production and processing,
- Packaging and labelling
- Importing and distribution
- Retailing and catering
In addition to regulatory bodies, there are various specialist cheese industry bodies, which have been set up by industry experts and technical committees to offer codes of best practice, such as the Specialist Cheese Makers Association (SCA) in the UK, the American Cheese Society (ACS), the New Zealand Specialist Cheese Makers Association and the Australian Specialist Cheese makers Association.
Which Laws are Relevant to Cheese?
The framework for UK national legislation is set out in the Food Safety Act 1990, though this has been amended to bring it in line with European law. The general requirements of European food law are described in Regulation (EC) 178/2002 along with three additional regulations which are often referred to as the ‘hygiene package’. These include Regulation (EC) 852/2004, Regulation (EC) 853/2004 and Regulation (EC) 854/2004.
All businesses are required to meet the minimum legislative requirements of these regulations and will be subject to inspection and subsequent approval to be operational.
What are Pathogens and why are they relevant to cheesemaking, cheese maturation and cheese storage?
Milk is a highly nutritious medium for bacteria, and can support the growth of many pathogenic organisms; these are defined as those that cause disease, eg. food poisoning. The principal organisms associated with food poisoning outbreaks include:
- Listeria monocytogenes
- Salmonella
- Coagulase-positive Staphylococci (CPS)
- Shiga toxin-producing E. coli (STEC)
What is Cross-Contamination and what are the Hygiene Issues Surrounding Cheese Safety?
If a cheesemaker and retailer follow strict food safety procedures and have robust HACCP programmes in place, then their cheeses should reach the consumer free from pathogens. At this stage, the biggest risk then to human health is that which arises through cross contamination.
Cross contamination is the movement of harmful microorganisms and other pathogens that are spread unintentionally from the service area or equipment to the food being prepared. It is a way of spreading foodborne illnesses and can, potentially, cause an outbreak. Cross contamination can occur at any point in the food supply chain with several different routes, including:
- Dirty hands
- Contaminated equipment, surfaces & packaging
- Contaminants in the environment, such as chemicals, airborne spores and allergens
- Transporting and storing cheese with contaminated foods
What are the 12 Steps of HACCP
HACCP is is a systematic and scientific approach to food safety, built to address potential food safety hazards by analysing risks, establishing critical control measures and monitoring procedures to prevent their proliferation which may cause harm to public health.
Whilst there are 12 HACCP steps, the first five are known as “Preliminary Steps” and include (1) Assembling a Team; (2) Scoping the Process; (3) Identifying the Target and finally (4) Constructing and (5) Verifying a Process Flow to identify the production process from supply through to manufacture and delivery.
Steps 6 – 12 are known as the Principles of HACCP and are as follows:
6: Carry out a hazard analysis
7. Determine the Critical Control Points
8. Establish Critical Limits
9. Establish a system to monitor control of the CCP
10. Establish the corrective action to be taken when monitoring indicates that a particular CCP is not under control
11. Establish procedures for verification to confirm that the HACCP system is working effectively
12. Establish documentation concerning all procedures and records appropriate to these principles and their application
What are Food Labelling Laws?
All prepacked cheese requires a food label that displays certain mandatory information. Some of these are general requirements applicable to all foods, whilst others are specific to milk products.
There are general requirements, which must be accurate and not misleading, including:
- Name of the Cheese
- Net quantity
- List of Ingredients (although these may be omitted if the only added ingredients are lactic products, food enzymes, starter cultures and salt)
- Allergen information
- Use-by date
- Storage conditions
- Name and address of cheese producer or who the cheese is marketed by
- Country of origin
- Nutritional declaration (this may be omitted if the manufacturer only supplies small quantities to the final consumer or to a local retailer that may supply the final consumer)
What Happens When a Cheese is Withdrawn or Recalled?
The term product withdrawal means the removal of foods from the market, where it has not yet reached the final consumer.
The term product recall means the removal of foods from the market at all levels, including from the consumer.
Regulatory bodies can provide information on how to deal with food incidents which may require a product withdrawal or a recall.
What is Food Crime?
Whilst not a large topic within Regulation and Good Practice, food crime, or “food fraud” is becoming an increasing challenge for the food industry. There are opportunities to make money by unscrupulous suppliers of food which have false claims, origins, and certifications. Examples of food crime include:
- Adulteration/Substitution
- Waste Diversion
- Document fraud
- Theft.
There are systems, like those used in HACCP, that can be put in place to help prevent food crime, using the flow of production to identify hazards, assess the risk, and put controls in place.
How Does the Design of a Dairy Impact Food Safety?
When looking at the design of a dairy, the placement of a cheese cave, or perhaps the site of a cheesemongers, it is necessary to consider how the space will contribute to an effective, safe food environment. There are several design factors that will have an impact on food safety, predominantly from cross contamination and it is important to consider these when deciding whether to move into an existing building or create a purpose-built space.
101 Guide – Cheese Regulation and Good Practice
