OVERVIEW

·    The regulations require that cheese making establishments and products be controlled in two ways: by official controls and by auto controls.

·    Official controls are done by the administration for the producer.

·    Auto controls are done by the producer at his cost.

·    The frequency of the auto controls varies according to the average daily milk production and the animal species.

 

 

DEFINITIONS

 

Official controls:

 

These are done by agents of the official departmental services: the Veterinary Service (DSV) and the Services of the DGCCRF, who are qualified to:

·    verify conformity to regulations for livestock, facilities, and conditions for making and selling cheese.

·    take samples of cheese for analysis (at the cost of the administration)

·    impound lots of suspect cheese and remove cheese from the market which doesn’t conform to regulatory standards

 

Auto controls:

 

These are done by the producer at his cost (for analysis) and are:

·      obligatory when required by officials for regulations concerning farm cheese.  The results are kept for official review.

·    voluntary for surveillance of cheese sanitary quality or to provide information about accidents in the production of cheese

 

 

            The frequency of official and auto controls for both milk and cheese is based on average daily production volumes after considering the annual milk production and species.  Recommendations for frequency of analysis are given in the following table.

         

 

            Table 3.  The frequency of analysis for auto and official controls.        

  These controls apply to all stages of the production of milk, the fabrication of cheese, treatment, packaging, storage, transportation, distribution, and sales.  They consist of one or many of the following operations:

·      inspection

      - of facilities (buildings and grounds, equipment, means of transportation)

      - raw ingredients and finished products

      - cleaning and maintenance procedures

      - fabrication and milk treatment procedures

      - means of labeling and packaging

·    sampling and analysis

·    control of personal hygiene

·    review of records and documents

·      examination of auto control system and results

  These controls are identical for all foodstuffs destined for sale in national and EU markets.  The Directive 92/46 EEC of June 16, 1993 specifies the nature of these controls for farmstead cheese production.  The goal of these controls is guarantee the safety of cheese products.

In farm cheese production the official controls pertain to:

  1.   The farm:

·    the veterinary control of milking animals with respect to their health relative to raw milk (absence of brucellosis, tuberculosis, and contagious diseases transmissible to humans, and the cleanliness of livestock)                          

·    the periodic hygienic control of the farm, essentially the condition  of places for milking animals

·    the control of raw milk by taking samples for analysis to verify compliance with regulations for microbiological quality, and to try to find drug residues (pharmacological and hormonal, e.g., antibiotics)

     

2.   The cheesemaking facility:

·    the state of the buildings and grounds, facilities, and equipment

·    the personal hygiene

·    the fulfillment and effectiveness of the auto controls

·    the conditions of storage and transportation

·    the fulfillment of the guarantee of safety (healthiness) of products by taking all necessary samples for laboratory analysis

     

3.   The cheeses:

·    the hygienic and microbiological quality by taking all necessary samples for laboratory analysis

·    the absence of drug residues (pharmacological and hormonal, e.g., antibiotics)

THE AUTO CONTROLS

These are self controls initiated by the producer with respect to the sanitary and hygienic characteristics of products destined for the market.  The auto control is a regulatory obligation except for producers who sell their entire cheese production directly to the final consumer.  It is always recommended for producers who sell directly, who are otherwise submitting to official controls, to carry out auto control analyses of cheese to verify that their operations conform to regulations.

The auto control consists of:

·    Taking and arranging analysis of samples of milk and cheese in a certified laboratory chosen by the producer at his cost.  The results of analyses should be kept to present to the administration if the case arises.

·    monitor the conditions of milk and cheese production and sale (critical points of contamination)

·    inform the Veterinary Service if results of analyses indicate grave risks to consumer health (if necessary, recalling products from the market)   

HOW TO IMPLEMENT AUTO CONTROLS

1.   Consult with the Veterinary Service for necessary forms and procedures.

2.   Choose a laboratory: generally the departmental veterinary lab but, if possible, choose another certified private lab.

3.   Take samples of milk and cheese, respecting the appropriate procedures for sampling and transportation.

4.   Keep the results on file to present to officials.  In case of exceeding the limits, notably for pathogens: Listeria monocytogenes and Salmonella, when there is a grave risk to the consumer, notify the Veterinary Service.

5.   Respect the regulations for hygiene a every step in the process: from milk production and cheese making  to selling the products, particularly to control the critical points of contamination.

  TAKING SAMPLES OF MILK AND CHEESE AND SENDING TO THE LABORATORY

  Milk Samples

  The milk is filtered and the sample is taken before the start of cheese making.

The sample is transported to the laboratory on the same day as it is taken.  In case this is not possible due to an emergency, the sample should be at stored at 0 to 4 °C  for as short a time as possible before it is transported by the producer or by postal service.  Samples should arrive at the lab at the beginning of the week.

  Identification of the sample:

  The identification is a document, which accompanies the sample to the laboratory.  It contains the following  information:

·    name of the producer

·    address

·    number of agreement (EU communal agreement for sale and trade)

·    type of sample and number (in order of all samples taken for the year, e.g., first sample of raw milk taken for the year = RM-01)

·    sample date

·    animal species

·    requested analysis: auto control,

·    details of the analysis requested (types of tests)

·    date of arrival at the lab

·    date of analysis

·    date of results

·    type(s) of corrective measures put in place, if necessary

  The document is returned to the producer with the results of the analysis.  It is kept by the producer for at least one year.

  Analyses:

  1.   For raw milk cheese:

·    cow milk

            - total bacteria (30 °C)

            - somatic cells

            - Staphylococcus aureus

·    sheep and goat milk

            - total bacteria (30 °C)

            - Staphylococcus aureus

  Also recommended, but not required, are the following tests in order to monitor the production:

·    pH

·    fecal coliforms

  2.      Pasteurized milk:

·    cow milk

            - total bacteria (30 °C)

            - somatic cells

·    sheep and goat milk

            - total bacteria (30 °C)

Regulations:

  ·    In case regulatory limits are exceeded (in two consecutive analyses) it is necessary to inform the Veterinary Service.  Measures must be taken to determine the cause(s) of poor results.

·    It is required that a risk analysis of critical control points is put in place.  This analysis identifies and monitors the risks of contamination (sanitary quality of the production) at each step of the production process.  The corrective measures used to prevent contamination are defined in the analysis plan.

·    For regulatory limits for milk refer Table 4 (page 41).

Cheese samples

  The sample is always taken at the end of the fabrication, in other words at the moment of the shipping or of the sale.

The protocol for auto control differs depending on the type of cheese.

·    Cheeses from primarily lactic fermentations and hand ladling (small cheeses) require five cheeses from the same day of production.

·    Cheeses from primarily rennet coagulation (large cheeses) require five samples of 100 g each from two cheeses from the same day of production.

·    Samples are immediately placed in a sterile pouch furnished by the laboratory (on demand).

·    Samples are transported to the lab on the same day they are taken.  If this is not possible due to an emergency, the cheese samples should be kept at 4 to 6 °C:

            - fresh cheeses: 4 °C, and

            - other cheeses: 6 °C is recommended.

·      Transportation procedures are the same as for raw milk.

  Identification of the sample:

  The identification is a document, which accompanies the sample to the laboratory.  It contains the following  information:

·    name of the producer

·    address

·    number of agreement (EU communal agreement for sale and trade)

·    type of sample and number (in order of all samples taken for the year, e.g., first sample of cheese taken for the year = C-01)

·    sample date

·    animal species

·    age of the product in days (from the day of renneting)

·    analysis requested: auto control,

·    details of the analysis requested (types of tests)

·    date of arrival at the lab

·    date of analysis

·    date of results

·    type(s) of corrective measures put in place, when necessary.

  The document is returned to the producer with the results of the analysis.  It is kept by the producer for at least one year.

      Analyses:

  For all types of cheese:

·    Listeria monocytogenes

·      Salmonella

These bacteria are the most dangerous to the health of the consumer.

  ·      Staphylococcus aureus

·    E. coli

These bacteria indicate faults in hygiene (sanitation).

  Regulations:

  ·    In case regulatory limits are exceeded (in two consecutive analyses) it is necessary to inform the Veterinary Service.  Measures must be taken to determine the cause(s) of poor results.

·    In the case of Listeria monocytogenes or Salmonella, the incriminated lot of cheese should be taken off the market.

·    In the case of Staphylococcus aureus or E. coli, if there is evidence of the presence of enterotoxins, the incriminated lot of cheese should be taken off the market.

·    It is required that a risk analysis of critical control points is put in place.  This analysis identifies and monitors the risks of contamination (sanitary quality of the production) at each step of the production process.  The corrective measures used to prevent contamination are defined in the analysis plan.

·    Refer to Tables 5a, 5b, and 2b (pages 42 and 20) for microbiolobical standards.

  The Environment

  Although the producer is not required to take environmental samples, it is essential to carry out in case of unsatisfactory results.

Sampling is done on:

  ·    milking and cheese making equipment

·    water

·    facility: floors, walls, ceiling, etc.

·    ambient air

  Petri films are used, which can be furnished by the lab.  It suffices to sample the environment and then place the films in sterile pouches.  Conserve the films at 4 °C.  Sampling should be done with single service gloves.  Water samples should be taken in the same manner as those for raw milk.

  Frequency of sampling:

  ·    in case of problems with contamination, one analysis per month for each piece of equipment for three months

·    in case of satisfactory results, one analysis per four months

            - facilities: two analyses per year

            - water: one analysis per year

  Types of analyses:

  ·      systematic testing of total bacteria (30 °C)

·    two times per year: research of Salmonella, Listeria, and Staphylococcus

  Samples are cultured and identified at the lab. This type of auto control aids in evaluating the quality of cleaning and disinfection (sanitation).

 Standards:

  The standards for pathogens in cheese reflect the health risks associated with different cheese varieties. There is also a standard for general coliforms but this only applies to soft-ripened cheeses from pasteurized milk (see Tables 5a, 5b and 2b;  pages 42 and 20). 

Table 4.  Standards for raw milk intended for the manufacture of milk-based products (maximum limits per ml of milk)

 

Type of micro-organism	Hard cheeses	Other cheeses
Listeria monocytogenes	Absence in 1 g n=5, c=0	Absence in 25 g (a) n=5, c=0
Salmonella spp	Absence in 25 g, n=5, c=0
In addition, pathogenic micro-organisms and their toxins must not be present in quantities such as to affect the health of consumers

 

(a)  the 25 g sample consists of 5 specimens of 5 g taken from different parts of the same product

 

Type of micro-organism	Cheeses made from raw milk and from thermized milk	Blue cheese made from pasteurized  milk	Soft cheese made from pasteurized milk	Fresh cheeses made from pasteurized milk and made from whey
Staphylococcus aureus per g	m = 1 000 M = 10,000 n = 5, c = 2	m = 100 M = 1,000 n = 5, c = 2	m = 100 M = 1,000 n = 5, c = 2	m = 10 M = 100 n = 5, c = 2
Escherichia coli per g	m = 10,000 M = 100,000 n = 5, c = 2	m = 10,000 M = 100,000 n = 5, c = 2	m = 100 M = 1,000 n = 5, c = 2	-

The standards for indicator micro-organisms are the same as in Directive 92/46/EEC (see Table 2b, page 20).

Labeling and Storage of Cheeses

  Conditions:

  1.   for Direct sale:

Þ                labeling is not required for sales at the farm

Þ    it is necessary to inform the consumer about the product

Þ    a sign, in plain view at the entrance to the establishment, which indicates the nature of the product is sufficient, e.g., “Farm cheeses for sale”

Þ    for direct sale and delivery of products handed directly to the consumer there is a maximum storage temperature requirement:

·      4 °C for raw milk, fresh products from raw milk, and cut and sliced cheeses

·      8 °C for other fresh dairy products

·    for ripened cheeses, the storage temperature is the responsibility of the producer

 

2.   for Direct sale at the market or other places:

Þ    it is necessary to inform the consumer about the product

Þ                generally, the cheese is packaged before handing over to the consumer

Þ                individual labeling of cheeses is not required, however a sign shall indicate:

·      type of cheese, e.g., farm-made goat cheese (non-defined), St. Marcellin (defined)

·      fat-in-dry-matter for defined cheeses (e.g. St. Marcellin as opposed to non-defined, “farm-made goat cheese”)

·      place of fabrication for defined cheeses: name of county or region, name of farm or village

 

3.   Sold by an intermediary:

Þ    for cheese in bulk, individual labeling is not required

Þ                information may be present at the retail outlet

Þ    self-service counters must have cheeses protected with a wrapper or paper

Þ    each cheese shall be labeled individually

  Labeling requirements:

·    name and address

·    place (county) of fabrication for defined cheeses

·    net weight except for non-defined cheeses sold by the piece

·    list of ingredients

·      expiration date:

      ---for ripened cheeses, <preferably consumed before --/--/-->

      ---for highly perishable (fresh) cheeses, <for consumption until --/--/-->

·    lot number = date of fabrication but is not required if the expiration date can indicate the lot number

·    minimum level of fat-in-dry-matter as a percentage except for A.O.C. and non-defined cheeses with the designation “fermier” (farm-made), which must have a “non precise” fat-in-dry-matter

·    mixed milk percentages

·      denomination of sale, e.g., A.O.C. cheese - Ossau-Iraty A.O.C., defined cheese - St. Marcellin, non-defined cheese - “fermier”

·      conditions for storage (recommended temperature)

·    “lait cru” (raw milk) cheese if milk used in fabrication is not heated to more than 40 °C (104 °F) but is not required for cheeses ripened for more than 60 days

·    health mark (from community sanitary approval)

 

  Transportation of Cheeses

  Documentation:

            Before transporting foods, the transporter must indicate the following points on an “accompanying document”:

·      types of products

·      state of the products (refrigerated, frozen,...) and required temperature for transport, when not defined by regulation

·      point of departure

·        destination

This document must be available for inspection by agents in charge of controls.

  Temperature:

            The temperature, which is required during transportation, is dependent on the type of product and the conditions and distance of the transit.  See Table 5 on the next page.

  Auto controls and verification:

  The transporter carrys out regular controls to assure the following:

Þ    that the equipment being used is suitable for transporting foods and is functioning properly

Þ    that the required temperatures are maintained

Þ    that the methods of cleaning and disinfecting the containment area are effective

              The transporter shall identify all aspects of his activities that affect the security of the foods and make sure that proper procedures are used.  In order to establish the nature and frequency of the controls, the transporter shall:

Þ    refer to a guide of good hygienic practices certified by the public health authorities

Þ    use the self control system based on the principles of HACCP.

Table 5:  Requirements for maximum temperatures and means of transport