A cheese plant's HACCP plan rests on two facts. Pasteurization is the kill step: federal rules define it for milk as every particle held at 145°F for 30 minutes in a vat, or 161°F for 15 seconds, and milk products crossing state lines must be pasteurized unless a cheese standard allows curing instead, such as 60 days at 35°F or more for a raw milk cheddar. And Listeria is the hazard after pasteurization: fresh cheese is ready to eat, it supports Listeria, and contamination comes from the room, so cold holding and sanitation carry the plan from there. FDA doesn't require HACCP by that name for cheese; a registered plant follows the preventive controls rule, and one under $1,000,000 in food sales files an attestation instead. Buyers ask for a HACCP plan anyway. In the example below, a small creamery's fresh goat cheese comes down to two critical control points: vat pasteurization and cold storage. Below are the rules, the hazard analysis, the plan, a week of records, and a free worksheet.
The short version
- Pasteurization: 145°F for 30 minutes in a vat, or 161°F for 15 seconds, 5°F higher at 10% fat or more.
- Milk products in final package form crossing state lines are pasteurized or made from pasteurized ingredients, unless a cheese standard allows curing.
- Raw milk cheddar: cured at not less than 35°F for at least 60 days.
- After pasteurization, Listeria from the room is the hazard: sanitation, environmental swabs, cold holding.
- A registered cheese plant follows FDA's preventive controls rule; one under $1,000,000 in food sales attests instead.
- Your state dairy program licenses the plant and sets its pasteurizer rules.
- TaroStack keeps each vat's chart readings on its batch record, with its lot. More below.
When a creamery needs a plan
A cheese plant registered with FDA needs a written food safety plan under the preventive controls rule, 21 CFR part 117, unless it's a qualified facility: a business averaging under $1,000,000 a year in human food sales, adjusted for inflation, files attestations with FDA instead (117.201), either that it has identified its hazards and runs preventive controls, or that it complies with state food safety law. Either way, the state dairy program licenses and inspects the plant, and cheese shops and distributors often ask for a HACCP plan by name. What a food safety plan holds is in what is a food safety plan, and how the small business rules work in FSMA requirements for small food businesses. This is general information, not legal advice.
The rules for milk and cheese
| Rule | What it says |
|---|---|
| Pasteurization | Every particle heated to 145°F for 30 minutes, 161°F for 15 seconds, or a higher temperature for less time, per 21 CFR 1240.61 |
| Fat or sweeteners | 5°F higher when fat is 10% or more or sweeteners are added |
| Interstate sale | Milk products in final package form pasteurized or made from pasteurized dairy ingredients, except where part 133 allows curing |
| Raw milk cheddar | Cured at not less than 35°F for at least 60 days (21 CFR 133.113) |
Other cheese standards in part 133 set their own curing rules. How a creamery plans its milk, vat and cave is in cheese making business plan.
An example: the hazard analysis
Housatonic Creamery, the made-up creamery in Great Barrington, Massachusetts, I use in these examples, makes fresh goat cheese, an aged tomme and cheese curds, and pasteurizes all its milk in its own vat:
| Step | Hazard | Reasonably likely? | Control | CCP? |
|---|---|---|---|---|
| Receiving raw milk | Pathogens; antibiotic residues | Yes | Pasteurization; the dairies' tests and a residue test on each load | No |
| Raw milk storage | Growth before pasteurizing | No | Kept cold, pasteurized within the plan's hours | No |
| Vat pasteurization | Pathogens surviving | Yes | 145°F for 30 minutes on the chart | CCP 1 |
| Culturing and draining | S. aureus if acid stalls | No | pH checked at set times | No |
| Molding and packing fresh cheese | Listeria from the room | Yes | Sanitation, environmental swabs | No |
| Cold storage of fresh cheese | Listeria growth | Yes | 41°F or below | CCP 2 |
| Aging tomme | None beyond the above | No | Cave sanitation and swabs | No |
The plan
| CCP | Critical limit | Monitoring | Corrective action | Verification |
|---|---|---|---|---|
| CCP 1 Vat pasteurization | Every particle at 145°F or above for 30 minutes | Recording chart and indicating thermometer, at the start and end of the hold | Re-pasteurize, or divert to non-food use; find the cause | Charts signed and reviewed before release; thermometers checked as the state requires |
| CCP 2 Cold storage | 41°F or below | Cooler thermometer, twice a day | Assess, hold or discard warm cheese; fix the cooler | Thermometer checked monthly; records reviewed weekly |
The environmental swabs, cleaning and the residue test are prerequisite programs: logged, but not CCPs. How a monitoring record is kept is in HACCP record keeping form example.
A week of records
| Date | Lot | CCP | Reading | Limit | OK? | Action |
|---|---|---|---|---|---|---|
| Oct 5 | CH-1005 | Pasteurization, hold | 30 min | 30 min or more | Yes | |
| Oct 5 | CH-1005 | Pasteurization, lowest temperature | 146°F | 145°F or more | Yes | |
| Oct 5 | CH-1005 | Cold storage | 38°F | 41°F or below | Yes | |
| Oct 7 | CH-1007 | Pasteurization, lowest temperature | 144°F | 145°F or more | No | Dipped at minute 12; hold restarted from the beginning at 145°F |
| Oct 7 | CH-1007 | Pasteurization, hold | 30 min | 30 min or more | Yes | The restarted hold |
Get the worksheet
Download the cheese HACCP plan worksheet. Four sheets: the hazard analysis, the HACCP plan with a place to sign, a monitoring log that checks each reading against its limits, and a read-me. It's a worksheet to organize your own plan, not a plan to copy. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
Every vat has a chart, every tub of fresh cheese has to trace to its vat, and if a swab comes back positive for Listeria, you need to know which lots came off that room's line and where they went.
How TaroStack does it
TaroStack keeps each vat's readings on its batch record, with its lot.
Readings on the batch. Fields of your own on the batch record hold the vat's hold time and lowest temperature, and printable batch-record forms carry the sign-off for the chart review.
Milk lots consumed. Each batch notes which milk lots it used, automatically, so a dairy's residue problem points to the batches it touched.
Where it went. Each shop's and restaurant's order records the lots it got, so one recall report shows every customer a lot reached.
| The job | Binder | In TaroStack |
|---|---|---|
| A vat's chart readings | A chart in a folder | Fields on the batch record |
| Which milk went into a vat | The tank log | Recorded on the batch |
| Which shops got a lot | Invoices | One recall report |
Lots, batches and orders are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.