C HAP T ER 1

An Introduction to the
Raw Milk Cheese Debate

B y virtue of my scholarly interests and employment, I have had a

front row seat in the raw milk cheese debate that has occurred
both here in the United States and abroad over the last 35 years. I have
personally witnessed the extraordinary renaissance in artisan cheesemaking
taking place in the United States, particularly in my home state of Vermont,
and also in England, Ireland, Quebec, Ontario, and throughout Europe.
The United States is the fastest-growing market for specialty cheese in the
world. Beginning in the 1980s, when the pioneers of the American artisan
cheese movement started making cheese, the industry has witnessed extraor-
dinary growth in the number of producers and products, with corresponding
improvements in quality and safety.1 Over the last decade alone, the expan-
sion has accelerated; since 2006 small-scale cheese companies, in some states,
have doubled or even tripled in number. A bona fide cheese culture has blos-
somed here in the United States, and much of the demand is local. American
cheeses now rival some of the very best produced worldwide. Artisan cheeses
produced in the United States have become so sought after that companies
based in Europe are buying US artisan cheese companies, seeing the poten-
tial for growth in artisan cheese consumption by US consumers. This should
be a good news story for the US dairy industry, right?
Through a grant from the United States Department of Agriculture
(USDA), I spent time in Ireland in 1990, learning from my colleague Dr.
Charlie Daly about assistance the University College Cork (UCC) was
 Ending the War on Artisan Cheese

providing to Irish artisan cheesemakers. We modeled our educational

programs at the Vermont Institute for Artisan Cheese at the University of
Vermont using the UCC model, and over a period of 13 years provided
education and training on cheese safety to over 2,000 US artisan cheese-
makers. We shared our educational resources with broader audiences,
and for a time engaged in collaboration with the Innovation Center for
US Dairy to promote artisan cheese safety. Things began to change on the
regulatory front, however, and the very information and advocacy we were
providing began to place the artisan cheese community under uncomfort-
able regulatory scrutiny. It became apparent that the regulatory approach of
the US Food and Drug Administration (FDA) toward artisan cheesemakers
was not based on sound science but rather on intimidation and fear, an
arbitrary and capricious approach that will be explained in the chapters
that follow. It is a fascinating and unfortunate history, one that should give
us pause as we consider who makes decisions about the foods we eat, and
the use of food safety as a guise for food choice. Forbes magazine said it best
when, in 2014, it ran a story titled “FDA May Destroy American Artisan
Cheese Industry.”2 This story has received over 216,000 views to date. For
many cheese lovers, this was their first introduction to the fight between the
FDA and the artisan cheese industry. However, as I will document, this has
been a war long in the making. This book will provide an in-depth analysis
of why Forbes was correct in its assessment.
Much of the growth of the US artisan cheese industry has been cham-
pioned by the American Cheese Society (ACS). I first attended an ACS
Annual Meeting in August 1993 at the invitation of its founder, Cornell
Professor Frank Kosikowski. The meeting was conveniently held at the
iconic Coach Barn on the grounds of Shelburne Farms, a bucolic estate
that sits on a landscape designed by Frederick Law Olmsted and was the
Vermont summer residence of Lila Vanderbilt Webb. Shelburne Farms
produces a farmhouse Cheddar cheese from the milk of Brown Swiss cows
that graze on the pastoral landscape of the farm. I participated as a cheese
judge, and as I recall, there were 50 cheeses entered in the cheese judging
and competition. I must admit that 10 of the 50 cheeses appeared defective
and I refused to judge them. Fast-forward to 2018 when, at its annual meet-
ing held in Pittsburgh, 1,954 cheeses were entered in the ACS competition.
Two Vermont cheeses, Harbison and Calderwood, received first and second

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 An Introduction to the Raw Milk Cheese Debate

place Best in Show honors, an unprecedented achievement for the Cellars at

Jasper Hill, a company that first debuted its cheese at ACS in 2003.
Today, the ACS Judging and Competition, the largest of its kind for judg-
ing cheeses made in the United States, requires about 30 judges to spend 3
full days in evaluation of the almost 2,000 cheeses entered in the competi-
tion. Best in Show winners often win global praise, going on to earn World
Cheese Awards. The Festival of Cheeses, during which all entries from the
ACS Judging and Competition are displayed and available for tasting by
the general public, pays tribute to the remarkable efforts of US artisan and
farmstead cheesemakers.
American artisan cheese has become mainstream, providing big busi-
ness for retailers such as Whole Foods, Costco, Wegmans, Murray’s Cheese
(now owned by Kroger), and others. Despite the success enjoyed by US
artisan cheesemakers and the meteoric rise of artisan cheese production,
the American artisan cheese industry faces an existential threat: regulatory
overreach. Regulations that govern cheesemakers in the United States apply
equally to large industrial cheesemakers and small farmstead producers
who use traditional practices in their cheese manufacture. Over the past 30
years, the FDA has pushed for a mandatory requirement for use of pasteur-
ized milk in cheesemaking, claiming a public health risk for raw milk
cheese. Under such a requirement, all raw milk cheeses would be banned.
That would be a travesty for cheese lovers. Chemical and microbiological
analysis shows that raw milk cheeses are more complex and more flavor-
ful than their pasteurized counterparts. The now classic 2002 New Yorker
article “Raw Faith” by Burkhard Bilger provides an apt description of the
difference, as written from his perspective during a visit with maître from-
ager Max McCalman at New York City’s famed Picholine restaurant. From
Picholine’s high-tech cheese cave, Bilger writes:

McCalman reached over and cut wedges from two Reblochon-

style cheeses, one of pasteurized milk, the other of raw. We had
done a few of these comparisons already, with the pasteurized
invariably tasting milder, gummier, and less complex. But this
time the difference was more elemental. The pasteurized version
wasn’t bad, with its musty orange rind and rich ivory pâte. But
the raw-milk Reblochon seemed to bypass the taste buds and

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tap directly into the brain, its sweet, nutty, earthy notes rising
and expanding from register to register, echoing in the upper
palate as though in a sound chamber. I thought of something
one of the founders of the Cheese of Choice Coalition had said
when I asked her what difference raw milk could possibly make:
“One is a cheese; the other is an aria by Maria Callas.”

And as McCalman expressed to Bilger: “To eat a cheese like this was to
participate in the preservation of a dying culture.” 3
Why the difference in the taste of cheeses made from pasteurized versus
raw milk? Put simply, pasteurization kills off much of the natural milk
flora responsible for flavor development. Traditional cheeses are fermented
foods that are dependent upon the many microorganisms that contribute
to the texture, flavor, veins, rinds, wrinkles, smells, and terroir of cheese.
Additionally, in an artisan/farmstead system, milk that is produced from
animals fed on pasture and/or dry hay has a high microbiological qual-
ity, which is essential for making the best cheese. In an industrial model,
animals are confined indoors and often fed silage or other forage mixture.
Silage is the source of many microorganisms that are detrimental to milk
quality and safety. Milk is collected from many farms, transported in tanker
trucks, and stored in refrigerated silos for many hours or even days prior
to use. Spoilage organisms that grow under refrigeration produce heat-
resistant enzymes that begin to attack milk proteins and fats, producing
compounds that negatively alter the taste (the five senses perceived by the
tongue: sweet, sour, salt, bitter, and umami) and flavor (the smell, texture,
and expectation) of the milk. Government regulation requires pasteuriza-
tion for milk produced under this industrial model to ensure both quality
(destruction of spoilage organisms) and safety (destruction of pathogens).
In contrast, in an artisan production model, controlling feed quality, closely
monitoring animal health and hygiene, and transforming milk quickly into
cheese bypasses these destructive steps and results in a cheese that reflects
the superb attributes of the starting milk.
The debate over the safety of raw milk cheese has fiercely divided
American cheesemakers and government regulators, and outraged cheese
lovers. Currently, certain cheeses can be legally manufactured from raw
milk only if they are aged for 60 days or longer. Aged cheeses have enjoyed

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 An Introduction to the Raw Milk Cheese Debate

a long and well-documented record of food safety, and the FDA’s attempts
to mandate pasteurization of all milk intended for cheesemaking comes
despite scientific evidence supporting this record of safety. The FDA’s
activity has escalated recently, with the establishment of stringent micro-
biological criteria that only cheeses made from pasteurized milk can easily
meet. When artisan and farmstead cheesemakers voiced their concern to
the FDA through their congressional representatives in late 2015, the FDA
temporarily backed down, but these cheesemakers remain extremely fear-
ful for their regulatory future.
That is because, besides making our cheese more bland and the range
of available cheese styles much narrower, a ban on raw milk cheesemaking
would economically devastate nonindustrial cheesemaking in the United
States. This is particularly true in states like Vermont, New York, California,
Washington, and Wisconsin, where artisan cheese producers use raw milk in
the production of aged Cheddar and other value-added cheeses. The artisan
cheese renaissance is creating precious opportunities for small-scale dairy
farmers and cheesemakers, who are often in rural economies facing chal-
lenging times. Jasper Hill Farm is one example of an artisan creamery that
is flourishing in the Northeast Kingdom of Vermont, a region where until
recently many barns hadn’t seen cows in 40 or 50 years because the low price
of milk bankrupted farmers. If artisan and farmstead cheesemakers are not
able to differentiate their products from industrial, pasteurized processed
cheeses, things will head south for them once more, and consumers will be
deprived of the delicious cheeses that artisans produce. Mateo Kehler, the
cofounder of Jasper Hill, put his frustration bluntly in the foreword to The
Oxford Companion to Cheese: “I used to believe that the greatest threat to our
business was a microbiological threat, but have learned the microbiological
risk can be managed. I now believe the biggest risk to the cheeses that are the
foundation of our business is a regulatory risk.”
The weight of scientific evidence does not land in the FDA’s favor.
Most outbreaks occur as a result of post-process contamination, which is
when cheese is recontaminated at some point along the production and
distribution chain, negating the safety impact of pasteurizing the milk.
Additionally, studies of several cheese styles have documented the ability
of a host of bacterial pathogens—including Listeria, Salmonella, E. coli,
and Staphylococcus aureus—to survive the current 60-day aging period,

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and yet outbreaks of human illness linked to raw milk cheese consumption
are rarely reported. This remains true despite the tremendous growth in
sales and consumption of artisan and traditional cheeses worldwide, which
has exponentially increased consumer exposure to raw milk cheeses with
limited adverse consequences.
This is not just an issue for American cheesemakers: A raw milk cheese
ban could eliminate the ability of cheese retailers such as Whole Foods to
import traditional cheeses from Europe and the rest of the globe because
their PDO (Protected Designation of Origin), AOP (Appellation d’Origine
Protégée), and former AOC (Appellation d’Origine Contrôlée) statuses
often require these cheeses to be manufactured from raw milk. Beloved
European cheese varieties such as Parmigiano Reggiano, Grana Padano,
Gruyère, Comté, Emmental, and Roquefort would all be affected by
proposed FDA regulations, and the importation of traditional cheeses such
as Tomme de Savoie, Morbier, Abbaye de Belloc, St. Marcellin, Montbriac,
Tomme de Bordeaux, and St. Nectaire fermier is already being restricted, or
altogether eliminated. The issue has the potential to affect global trade and
to further divide the United States from the rest of the world when it comes
to views on food production and food safety.
Nor is America alone in imposing regulations that imperil the artisan
cheese industry. Europe’s beloved small producers are going belly-up
or being bought out at unprecedented rates, in large measure because
industrial dairy giants have lobbied regulators to be allowed to place PDO,
AOP, or AOC labels on their products—designations that were intended
for traditional products. In France in 2007–2008, Lactalis and Isigny
Sainte-Mère, which together make more than 80 percent of traditional raw
milk Camembert in Normandy, announced that they would begin using
thermized and industrially treated milk in their Camembert production.
Camembert’s AOC standard requires the use of raw milk, but the dairy
giants applied to have the standard rewritten so that they could keep the
valuable AOC label while dramatically reducing the cost of their inputs—
much cheaper milk, and fewer inspections now that they weren’t using
lait cru (raw milk). Lactalis and Isigny Sainte-Mère cited a public health
concern in seeking the change: a 2005 case in which six children became
ill after eating Camembert. What became known as the Camembert wars
ended with the brands devastated by public perception that they had sold

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 An Introduction to the Raw Milk Cheese Debate

out their nation’s gastronomic treasure for a cheap knockoff, imperiling

the little producers who couldn’t compete on price with mass-produced
Camembert. Real Camembert activists marshaled the public opinion force-
fully against the dairy giants, and Lactalis and Isigny Sainte-Mère dropped
their pursuit of the AOC label. Instead, they were permitted to label their
product Fabriqué en Normandie, or Made in Normandy, with pasteurized
milk from any breed of cow permitted for use in Camembert manufacture.
The seeming victory of David over Goliath to preserve the AOC stan-
dard may have been short-lived, however. In February 2018, as reported by
Forbes in the article “Why Your Genuine French Camembert Cheese Is in
Danger,” France’s Institute of Origin and Quality announced that beginning
in 2021 there will be a single AOP Normandy Camembert that includes
cheese made with pasteurized milk, provided that at least 30 percent of the
milk is obtained from Normande cows that graze in the region.4 To many,
this signaled the death of Normandy Camembert. An article published by
Bloomberg titled “Why Camembert, One of the World’s Great Cheeses,
Might Soon Be Extinct” described what is at stake for Camembert du
Normandie AOC producers. As the author, Larissa Zimberoff, writes:

A PDO Camembert de Normandie must be made with unfil-

tered raw milk, with a fat content of at least 38 per cent that
comes from cows from France’s northern Normandy province,
fed under strict conditions—grass and hay from local pastures.
The milk must be hand-ladled in four or more layers into specific
moulds. Milk is transported no farther than the distance that
cows can slowly dawdle in search of a fresh blade of grass.5

Corroler and others conducted an ecological study to determine the effect

of the geographic origin of specific bacterial strains on the manufacture and
ripening of a traditional Camembert du Normandy cheese.6 The consistent
and specific presence of wild-type strains of the bacterium Lactococcus
lactis isolated from raw milk produced within the AOC Camembert region
confirmed the dairy significance of the Camembert region. As the authors
stated: “It is well known that traditional cheeses made with raw milk ripen
faster and develop a more intense flavor than cheeses made with pasteur-
ized or microfiltered milk.” Understanding the biodiversity of the microbial

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population associated with artisan cheese affords a look into the uniqueness
that artisan production contributes to a biodiverse microflora in cheese,
which in turn imparts unique sensory attributes.
My dear friend and colleague Dr. Sylvie Lortal, research director at the
French National Institute for Agricultural Research (INRA), describes AOP
as “gastronomic precious heritage.” Meanwhile, centuries-old cheese styles
like Fourme d’Ambert and Cantal are at risk of being lost because new health
ordinances make them unaffordable or illegal to produce. In an impas-
sioned speech to France’s Institute of Sciences and Arts in acceptance of the
François Rabelais prize for his organic farming efforts, the Prince of Wales,
HRH Prince Charles, decried the “ ‘bacteriological correctness’ of European
regulators.” He asked, “In a microbe-free, progressive, and genetically engi-
neered future, what hope is there for old-fashioned Fourme D’Ambert, the
malformed Gruyère de Comté, or the odorous Pont L’Eveque?” He went on
to eloquently state, “The distinctiveness of local cuisine is one of the most
important ways we identify with the places and regions we love,” adding
that “a very important part of the whole magnificent edifice of European
civilization rests on the inherited genius and craftsmanship of the people
who make such distinguished concoctions” referring, of course, to those
magnificent products we call cheese.7
Milk pasteurization is not the only issue at play in the global assault on
traditional cheesemaking. In addition to the FDA’s attempts to ban the use
of wooden boards in cheese aging (many traditional cheeses made from
both raw and pasteurized milk use aging on wooden boards to control
cheese moisture levels and to allow development of flavor and character),
the FDA has also tried to ban the use of ash in cheesemaking, a traditional
practice that selects for important microbial groups during ripening of
some bloomy rind cheeses made from pasteurized milk. And the FDA and
other governments have established stringent E. coli standards that many
artisan cheeses, regardless of whether produced from raw or pasteurized
milk, simply cannot meet. Additional challenges artisan cheesemakers
face include the FDA’s Listeria swabbing assignments, the Food Safety
Modernization Act (FSMA), and the harsh criminalization of outbreaks
that are traced to their facilities.
Writing about raw milk cheese presents an opportunity to explore centu-
ries-old food traditions, and to sound a warning to consumers that without

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vigilance these traditions may be eliminated for reasons that are simply not
scientifically justified. Ending the War on Artisan Cheese ultimately provides
focus on the politics of this issue, through an exploration of ways in which
the public is rarely, if ever, consulted about the foods that they are allowed
to consume. Simply put, it is highly unlikely that food safety concerns
alone are at the heart of this complex issue. Governments taking part in the
punishing regulatory activities have large industrialized dairy processors
to please (Kraft, Fonterra, Lactalis, and the like). Most critical, however,
is the unprecedented new regulatory authority given to the FDA under
the FSMA to ensure food safety. With this new authority, there must be a
system of checks and balances to ensure that this power is not abused, and
that regulatory decision-making is based on sound science. The raw milk
cheese debate provides a convenient and cautionary lens through which we
can examine the FDA’s functioning. As evidenced throughout the chapters
that follow, I maintain that the FDA is not the right agency to oversee food
safety. I hope this book will energize cheese lovers and, through their advo-
cacy, lead to a new system of regulation that is grounded in science and
that simultaneously supports food safety and promotes our precious rural
working landscapes here in the United States and across the globe.

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