Consensus categorization of cheese based on water activity and pH-A rational approach to systemizing cheese diversity

Development of science-based interventions in raw milk cheese production is challenging due to the large diversity of production procedures and final products. Without an agreed upon categorization scheme, science-based food safety evaluations and validation of preventive controls would have to be completed separately on each individual cheese product, which is not feasible considering the large diversity of products and the typically small scale of production. Thus, a need exists to systematically group raw milk cheeses into logically agreed upon categories to be used for food safety evaluations. This paper proposes and outlines one such categorization scheme that provides for 30 general categories of cheese. As a base for this systematization and categorization of raw milk cheese, we used Table B of the US Food and Drug Administration's 2013 Food Code, which represents the interaction of pH and water activity for control of vegetative cells and spores in non-heat-treated food. Building on this table, we defined a set of more granular pH and water activity categories to better represent the pH and water activity range of different raw milk cheeses. The resulting categorization scheme was effectively validated using pH and water activity values determined for 273 different cheese samples collected in the marketplace throughout New York State, indicating the distribution of commercially available cheeses among the categories proposed here. This consensus categorization of cheese provides a foundation for a feasible approach to developing science-based solutions to assure compliance of the cheese processors with food safety regulations, such as those required by the US Food Safety Modernization Act. The key purpose of the cheese categorization proposed here is to facilitate product assessment for food safety risks and provide scientifically validated guidance on effective interventions for general cheese categories. Once preventive controls for a given category have been defined, these categories would represent safe havens for cheesemakers, which would allow cheesemakers to safely and legally produce raw milk cheeses that meet appropriate science-based safety requirements (e.g., risk to human health equivalent to pasteurized milk cheeses).