Most food-safety rulemaking gets written with a plant floor in mind — conveyor belts, case lots, a receiving dock with a forklift. So when the federal food-safety regulator's proposed traceability recordkeeping rule landed in late September, a fair number of members skimmed the summary, saw "additional records for certain foods," and moved on. That was a mistake. Certain cheeses are named specifically on the draft list, and the comment window closes in January.
This isn't a rule about whether your cheese is safe. It's a rule about whether you can prove, fast, where a wheel came from and where it went if something goes wrong somewhere else in the chain. If you sell wholesale, ship direct, or move product through a distributor, this is worth twenty minutes of your November.
What the draft actually asks for
The proposal would require producers on the covered list to keep linked records for what it calls critical tracking events — receiving milk or cultures, transforming them into a lot of finished cheese, and shipping that lot out. The intent, as written, is to let investigators trace a contamination event back to its source in hours instead of weeks. For a plant running thousands of SKUs, that's a systems problem. For a two-person cave with a paper lot log and a Sharpie, it's a different kind of problem — the recordkeeping format assumes infrastructure that a lot of our members don't have yet, and may not need at their volume.
That gap is exactly what a comment period is for. The Food Safety Committee has been collecting examples from members who make and sell at small scale — how they currently track a lot, what a compliant version of that would cost them in time, and where the proposed thresholds might genuinely not fit a 40-wheel batch. If your cave uses a system that already produces this kind of trail — a batch-numbered aging log, dated wax or rind marks, a simple spreadsheet tied to a delivery receipt — we want to see it. The strongest comments aren't "this is hard." They're "here's what we already do, and here's where the draft language doesn't recognize it."
Tom Reyes, who runs Speltmoor Farmstead and has testified on raw-milk recordkeeping rules more times than most of us can count, put it plainly on a committee call this week: the record you keep for yourself when something goes wrong is usually most of the record a regulator wants — it just isn't in the format they're expecting yet. That's the gap worth writing about.
How to weigh in
The comment period runs through late January, which sounds like plenty of runway until the holidays eat six weeks of it. The Food Safety Committee is putting together a short template members can adapt — three questions about your current recordkeeping, your batch sizes, and what a compliant system would realistically take to stand up. We'll have it out before Thanksgiving. If you make or handle a cheese variety and you're not sure whether it's on the covered list, email the committee and we'll check for you rather than have you guess from the draft text.
If this is your first time commenting on a proposed rule, you're not behind. The record only closes once, and a plainly written paragraph from a working cheesemaker carries real weight next to a page of legal boilerplate. Tell us what your lot log actually looks like. That's the comment that gets read.
The International Cheese Federation (ICF) and More Cheese are entirely fictional. This post is demonstration content created for MemberJunction. All people, organizations, events, courses, certifications, figures, and quotations in it are invented, and nothing here represents a real association, a real business, a real person, or real professional advice.