Sunday, June 3, 2007

Free Choice or Safety of the Population?

Governments and regulators are always in a difficult position. Do they allow total freedom of choice, or does their responsibility to the population require them to make restrictive decisions based on the greater good of the people? The government then performs a balancing act, running the risk of being labelled as Big Brother (or at least Nanny Government) or as being irresponsible. For example, should we all be allowed to use any chemical we can obtain to relieve the monotony of our daily lives, or should there be regulations to control the use of mind-altering substances and thus protect us from ourselves? If we allow unfettered use of any substance and thus maintain personal freedom, how do we protect the innocent - those who are too young or too poorly educated to know that these materials may be harmful?

Most people would probably come down on the side of some restrictions for the use of drugs, though some would argue for freedom of choice. The same applies to the sale and consumption of raw milk and raw milk products.

I have discussed raw milk before in this blog. I might have left it at that, but the New Zealand Government, in the form of the New Zealand Food Safety Authority has now called for submissions on a proposal to permit direct imports of Roquefort, a soft raw milk cheese made in France, and extra hard Parmesan-style raw milk cheeses Grana Padano, Pamigiano Reggiano, Romano, Asiago and Montasio. An extensive programme of risk assessment has already been undertaken and the Authority is now consulting with industry groups.

This development may lead some members of the community to believe that Big Brother has been wrong all along and is now backing down. Extra hard cheeses have a low water activity* of about 0.693 that prevents the growth of most bacteria. Soft cheeses, such as Brie, Camembert and Roquefort have much higher water activities and thus may permit the growth of pathogens such as Listeria monocytogenes (see post To Pasteurize or not? - 10th December 2006). The truth is that cheeses made from raw milk are not as safe as those made with pasteurized milk.

European Community (EC) legislation sets microbiological, food safety and process hygiene criteria that reduce the risks in consumption of raw milk cheeses. NZFSA has recommended that if these products are to be directly imported and ultimately manufactured in New Zealand, additional risk mitigation measures should be introduced:

100% verification of certificates attesting that the relevant EC standards have been met

continuing monitoring of products to check for E. coli levels, which can indicate unsafe manufacturing conditions leading to faecal contamination of the cheese.

It is expected that leaflets, posters and point of sale brochures will be required to educate the consumers on the risks of eating cheeses made from unpasteurized milk and that labelling of the products will be mandatory. Yet another acronym has been added to our lexicon: YOPI - Young, Old, Pregnant or Immunocompromised. This group of the population should not consume raw milk products.

*Water activity is a measure of the ability of water to take part in biological and chemical reactions. It is measured as a ratio of the partial vapour pressure of the food to that of pure water. That sounds complicated, (it's not) but it results in a scale of water activity running from 0 to 1. Generally speaking, the lower the water activity, the harder it is for micro-organisms to grow. Water activity in foods can be controlled by salts and sugars. So we can formulate food to have a particular water activity and thus preserve the food.