LAUSR

Abstract The U.S. Food and Drug Administration's (FDA) 2015 Domestic and Imported Cheese and Cheese Products Compliance Program Guidelines (CPG) (U.S. FDA, 2015) consider cheeses to be adulterated if non-toxigenic Escherichia coli levels of greater than 10 most probable number per gram (MPN/g) and less than 100 MPN/g are found in 3 or more of 5 subsamples. It is unclear if, or how, these standards impact food safety, and the extent to which these standards affect domestic and imported cheese commerce. We conducted a retrospective analysis of microbiological data from FDA's Domestic and Imported Cheese Compliance Program for cheese samples collected between January 1, 2004 and December 31, 2006. Out of 3,007 cheese samples tested by the FDA for non-toxigenic E. coli, 76% (2,300) of samples contained E. coli levels that exceeded 10/g. Of these samples, 68% (2,047) exceeded 2009 regulatory guidelines of 100/g. In comparison, only 7.7% (232) of tested cheese samples exceeded European Union (EU) standards (