Raw milk cheese – an opportunity beckons

Food Standards Australia New Zealand is currently considering a proposal that, if successful, will permit the manufacture and sale of raw milk cheeses in Australia within strict safety parameters. If the Ministers responsible for food regulation agree to the changes, it is anticipated they would come into effect in early 2015.

Raw milk cheeses are made from milk that has not undergone a pasteurisation process which typically involves heating raw milk to 72°C for 15 seconds or equivalent. Pasteurisation eliminates most pathogenic bacteria that may be present in raw milk, and has a long history of safeguarding consumers of dairy products.

Food aficionados and certain sectors of the dairy industry are understandably excited about the prospect of a greater range of raw milk cheeses being available in Australia. Hence there has been some recent media coverage about the opportunities this will permit.

What is not so well known is the fact that the Food Standards Code already allows the production of certain types of raw milk cheese (See Standard 4.2.4). These are predominantly very-hard grating cheeses and specific types of cheese which involve a cooking step during the preparation of the curd.

The proposed changes will allow the sale of cheeses made from raw milk in circumstances where there is increased control over, and supervision of, the quality of raw milk on farm, and where it can be demonstrated that:

• the physico-chemical characteristics of the raw milk cheese do not support the growth of pathogens, and
• there is no net increase in pathogen levels during processing.

This is where the whole issue becomes complicated and cheese makers will need access to high level technical guidance and support to realise a market opportunity. Importantly, the changes will only allow manufacture of raw milk cheese in specific circumstances.

For example, a cheese maker will need to demonstrate that their cheese will not allow the growth of pathogens. The scientific literature shows that soft, mould-ripened, and many semi-hard internally bacterial-ripened and fresh cheeses will allow the growth of pathogens. These cheeses are generally not highly acidic, and provide nutrients and sufficient moisture for pathogens to grow. Manufacturers will not be able to make these classes of raw milk cheese.

Therefore they will need to provide scientific evidence demonstrating that the cheese they wish to make will not support the growth of pathogens. Evidence to support this requirement may take the form of analytical data, predictive microbiological modelling, and even challenge studies. The cheese maker must also demonstrate they can consistently make that product so that is meets this requirement.

The requirement that there is no net increase in pathogen levels will also require the production of scientific evidence to confirm this position.

The protection of public health is the principal goal of the Australian food regulatory system. Food manufacturing operations are required to have food safety plans in place that demonstrate their through-chain management of food safety.

This proposed amendment to the Food Standards Code opens up opportunities for the production of cheeses that are equivalent in safety to cheese made from pasteurised milk. Pasteurisation represents a critical control point in the manufacture of dairy products, because it eliminates pathogens in raw milk. So a cheese making operation which doesn’t involve pasteurisation must demonstrate product safety through rigorous monitoring and testing of raw materials and finished products, and provide evidence of control over every stage of the cheese-making operation.

The changes will offer an opportunity for innovation in theAustralian dairy industry. But we should not lose sight of the fact that we have some excellent cheese makers in Australia producing some fabulous specialty cheeses using pasteurised milk. This is demonstrated by various awards given at international cheese judging events such as the 2014 World Cheese Awards (BBC Good Food Show London, November 2014) which included a super gold.

The long and colourful history of transforming milk into a delectable cheese involves an amalgamation of art, science, and ongoing innovation. The opportunity to produce Australian raw milk cheeses is an exciting development, but must not compromise public health.


Food Standards Australia New Zealand (2014) – Proposal P1022: Primary Production and Processing Requirements for Raw Milk Products
Food Standards Australia New Zealand (2014) – Standards 4.2.4 and 4.2.4A

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