We've been telling members since fall that a new federal food-safety proposal was coming, and this month it's finally in front of us in enough detail to comment on. The rule would add recordkeeping requirements for foods the regulator considers higher-risk for outbreaks, tracked at specific points as they move from farm to counter. Soft cheeses are on that list. Hard and aged cheeses generally are not, at least in the draft as written, but the comment period covers the whole list and members have opinions about where the lines were drawn.
If your creamery makes anything soft-ripened, fresh, or otherwise sits inside the proposal's food category, this is worth ten minutes of your time before the window closes. The recordkeeping asks for more than most small operations currently track by default: lot codes at specific transformation points, not just at receiving and shipping. That's a bigger lift for a two-person creamery than for a plant with a warehouse management system already doing it.
What we're asking members to weigh in on
Two things, specifically. First, whether the proposed recordkeeping points make sense for a small-batch operation where a single vat becomes several lots by hand, not by scanner. Second, whether the compliance runway — the time between a final rule and the date it takes effect — is realistic for a creamery that would need to change its record forms, train staff, and in some cases add software it doesn't currently use.
We are not taking a position on whether traceability itself is a good idea. It is. Every member we've talked to over the years who has lived through a real or near-miss recall wants better records, not fewer. The comment period is about getting the specifics right for shops that don't look like a national producer's plant floor — different batch sizes, different staffing, different existing systems.
Where to start
If you make a covered product, start with your own current recordkeeping. Pull last month's lot codes and trace one wheel, on paper, from milk delivery to a sold case. Time how long it takes and note where you had to guess or cross-reference two logbooks instead of one. That exercise will tell you more about how the rule would land on your operation than reading the text cover to cover, and it gives you something concrete to put in a comment if you choose to file one.
Our Food Safety & HACCP Certificate coursework covers recordkeeping and lot-tracking fundamentals if you want a refresher before you write anything down. Members whose forms already separate a make into distinct lots at cutting, rather than only at packaging, will have an easier time here — worth building into your January planning either way, whether or not the final rule lands as written.
We'll keep the comment period open on our advocacy page through the window and will summarize what members raised once it closes. If you want your specific experience reflected in what we file collectively, reach out to the Food Safety Committee before the deadline rather than after. That committee has spent the pandemic fielding a steady stream of questions on cleaning protocols and inspection schedules, and a proposal like this one — asking small operations to formalize records that used to live in someone's head — is squarely in its lane.
One more practical note. If your creamery sells through a shared regional distributor, ask now whether that distributor is already planning changes to the paperwork it expects from suppliers. A rule written at the federal level often shows up first as a new form from whoever handles your logistics, well before the compliance date arrives, and it's easier to plan for that conversation in December than to be surprised by it in a busier month.
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.