In my first note to you as ACS President, I would like to begin by extending a huge thank you to a few special people. For those of us who were able to attend the ACS Conference in Sacramento, I am sure that you will agree that it was fantastic. The seminars were thought-provoking and informative; the Awards Ceremony as well as the Festival of Cheese were dramatic, exciting, and professional; and of course the time that we all spend together talking cheese is invaluable. A huge thank you goes out to the Conference Co-Chairs, Lynn Giacomini Stray, Jill Giacomini Basch, and Juliana Uruburu, for the hours they spent working to make it great. As you all should know, none of that could happen without the dedication of the ACS team, led by the Executive Director, Nora Weiser, along with Michelle Lee, Becca Orozco, Jane Bauer, Jana Hemphill, Steve Binns, and Anna Casper. Truly a job well done. And I would like to send out a major thank you to all of the numerous volunteers who give of their time, working behind the scenes to make everything appear so magically. Without the good will of so many, our Conference could never be as sensational as it is. We had nearly 1,000 attendees in Sacramento -- an amazing turnout for what was an amazing conference.

The day before the Conference started, ACS leadership met with a group of directors from the Food and Drug Administration (FDA). It was a good meeting, and we were able to establish a foundation for ongoing communications, with the agreement to have sit down-meetings to discuss issues that are affecting the cheese industry. We hope ACS now has a seat at the table in the discussions of policies that will impact our members. We see this meeting as a huge move forward. We will need to be vigilant in our persistence to be viewed as a partner to FDA. Already, the groundwork we laid in Sacramento is proving valuable as we work collaboratively with FDA on several issues now impacting our industry. 

I would also now like to acknowledge members of the ACS Board of Directors who have fulfilled their terms of service. Christine Hyatt has given eight years to ACS, with her last two as Chair, and before that, two years as President. Christine led us through great change, and established American Cheese Month. Sasha Davies served as Secretary throughout most of her tenure, and is one of the sharpest people I have ever met. The ACS Certified Cheese Professional™ program simply would not exist had Sasha not carried that torch for so many years. Jill Giacomini Basch shared her marketing genius with ACS, and helped to re-envision and re-design much of the organization's marketing materials, as well as ensuring a clear and consistent voice in many of our important communications.

Lastly, I would like to thank Greg O'Neill for his tireless dedication as past President, and his willingness to serve as Chair during my presidency. He has placed himself on the front line for many of the issues that have faced ACS in the past few years, and he has managed these challenges while pushing the organization forward. We are now in a much more prominent position. With that comes a more responsible role in the world of cheese. It has been a pleasure to work with him, and I look forward to his insights in the years to come.

Joining me and Greg on the Executive Committee is a roster of industry professionals who are true leaders and true stewards of our community: Dick Roe as Vice President, Pat Ford as Secretary, and John Antonelli as Treasurer. With this team on my side, I look forward to a strong and productive presidency, and I will strive to represent you -- our members -- in the manner in which you have entrusted me.
 

Peggy Smith
President 
 

The kids are back in school. The mornings have turned cool. The trees are hinting that autumn is around the corner. This is the time of year when we gear up for shorter days and more time spent inside. For ACS, it will be time spent pushing forward initiatives started earlier in the year, and building our capacity as advocates for the industry.

You have surely noticed recently that FDA's pilot testing program, which includes raw milk cheese, is in full swing. In addition to the impact on domestic producers, importers are finding that their cheeses are also being held up due to testing, among other reasons. After meeting with FDA in Sacramento, and with the assurance that we would maintain open lines of communication, I am pleased that thus far this has been the case.

With the issue of acceptable limits for non-toxigenic E. coli of growing concern to our members, we reached out to FDA for clarification. FDA got back to us in a timely fashion, explained their thinking, and appear open to revisiting the limits currently being enforced for non-toxigenic E. coli in raw milk cheese.

At issue is a 2010 Compliance Program Guideline (CPG) for Dairy Products-Microbial Contaminants and Alkaline Phosphatase Activity that calls for all milk products to have <10 MPN/g of non-toxigenic E. coli in at least 3 of 5 subsamples, with no samples greater than 100 MPN/g. This is lower than the amount allowed in the existing compliance program (<10,000 MPN/g), and also lowers the amount cited in the 2009 Draft version of the guidance, which proposed a higher limit for raw milk cheeses of <100 MPN/g in at least 3 of 5 subsamples, with no samples greater than 1,000 MPN/g. ACS asked that FDA explain their reasoning for lowering the permissible levels, and for removing language specifically addressing raw milk cheese, which had been included in the 2009 Draft of the guidelines. 

In a letter of response sent to ACS on August 29, 2014, FDA noted an error in its testing protocol and subsequent interpretation and have made a correction. They have also increased the number of subsamples allowed to exceed the <10 MPN/g limit from 2 to 3, as long as no sample exceeds 100 MPN/g. Based on the results of FDA's pilot testing program, when applied correctly, 95% of raw milk cheeses would meet these guidelines. FDA feels that it is still premature to change the allowable levels back to those in the 2009 Draft without additional information, and they are looking to ACS to assist in that process.  

FDA has provided ACS with some of the information we requested, and has opened the door to reconsidering higher non-toxigenic E. coli limits should data bear out the efficacy and safety of doing so. ACS will now seek additional clarity on the data that led to the limits being lowered. We will keep you posted with a Member Update as soon as we receive additional insight.

FDA also writes that, in our Sacramento meeting, "ACS committed to providing comment(s) and further industry information to the 2010 CPG through the docket as stakeholder comments on guidance are always open." Now is the time for you to prepare your comments! Once we hear back with more details, we want to ensure that FDA receives the information they need in order to re-evaluate this issue. 

Here's what you can do now:

Cheesemakers: Compile your thoughts on the issue by drafting a comment which includes, for example:

1. How your business will (or has been) impacted by enforcement of the 2010 CPG (limiting non-toxigenic E. coli to <10 MPN/g in at least 2 of 5 subsamples, with no samples greater than 100 MPN/g).  How does this guideline compare to the impact of the levels proposed in the 2009 Draft?
2. The financial impact on your business should you no longer be able to make raw milk cheese.
3. Procedures and protocols you use to ensure a safe raw milk product.

Retailers/Distributors/Importers: Compile your thoughts on how the issue impacts your business including, for example:

1. Consumer demand for cheeses to which you now have limited access.
2. Financial losses due to lack of inventory and/or delayed shipments leading to waste.
3. Other challenges you face due to enforcement of the <10 MPN/g guideline.

Save up your comments, and we'll send out a Call to Action to let members know when it's time to submit them to FDA.

Please feel free to contact me with your thoughts and concerns at nweiser@cheesesociety.org.

Best,

Nora Weiser

Executive Director