Briefing on Errington Cheese
- Food Standards Scotland’s microbiological case against Errington cheese is in tatters. Three leading authorities say that the agency has got its science wrong.
- FSS’s epidemiological evidence against Errington cheese has been withheld and the published reasons allegedly linking the cheese and the outbreak of illness appear paper thin and full of holes.
- Food Standards Scotland (FSS) claim “serious deficiencies” exist in Errington Cheese processes despite the fact that FSS and the Environmental Health Officer’s inspection this year gave the company almost unqualified approval for its hygiene controls.
- FSS is lying to the public about the safety of raw milk cheese to suit its pre-existing bias against this artisan product.The latest robust science shows that raw milk cheese is a very low risk food and that it compares very favourably to many other categories of food we consume daily. FSS has chosen to ignore this.
An outbreak of E.coli O157:H7 illness occurred in July affecting people in various parts of Scotland. Perhaps 26 people were ill and a three-year old child died.
Food Standards Scotland (established in 2015 as an agency separate from the Food Standards Authority in England) in tandem with Health Protection Scotland set up an Incident Management Team (IMT) on 26th July and immediately blamed this outbreak on Dunsyre Blue cheese, which is made by Errington Cheese Limited, who were informed on 27th July that the only cause of illness being investigated was their cheese.
This Scottish outbreak followed a larger E.coli O157 incident in England the same month, which affected around 200 people, and killed two. The Food Standards Agency in England, which has been in existence since 2000, later attributed this English outbreak to contaminated salad leaves. No action was ever taken against any supplier.
Since July, Food Standards Scotland has continued to blame Errington Cheese for the Scottish outbreak having, at the outset of its investigation, excluded all other possible sources of contamination. It has based its case on results for batches of Errington cheese from tests which it commissioned, and what it refers to as epidemiological ‘evidence’.
What the tests actually show
Tests on “suspect” batches of Errington cheese, the same cheese tested by Food Standards Scotland-appointed labs, were carried out in September by the Actalia company. This is THE top cheese safety testing company. It has expert laboratories throughout Europe and sets all the cutting edge testing protocols and regimes for microbiological testing of dairy foods in the EU. Actalia represents the scientific gold standard for food safety testing of cheese. Actalia laboratories have found no highly pathogenic bacteria in any of the Errington cheeses tested.
Actalia carried out state-of-the-art tests on Errington cheese and concluded that the E.coli strains present were not pathogenic because they lacked the necessary genes that would make them pathogenic (poisonous).
In the face of this scientific embarrassment, Food Standards Scotland persisted in its allegations against Errington cheese, still insisting that tests carried out at its behest demonstrated proof of toxicity. It bases these claims on “presumptive positives”, that is, the assumption that because some genes required to make E.coliO157 pathogenic were identified in the cheese, this proved that the cheese was the culprit. These genes are often identified in cheese, even pasteurised cheese, and finding them proves nothing; what you have to do to show pathogenicity is to identify an E.coli organism with these genes attached to it—and this FSS have not done.
Hugh Pennington, Emeritus Professor, has since examined in detail all the tests carried out on Errington cheese for Food Standards Scotland. Professor Pennington is THE UK (and probably global) authority on E.coli O157 food poisoning. He has led the two largest public enquiries into outbreaks of this type in the UK. His report concludes that Food Standards Scotland has “no microbiological evidence” to link Errington cheese to the Scottish outbreak. He writes:
“The outbreak was caused by E.coli O157/phage type 21/28. I have seen the results of many microbiological tests on numerous samples of Dunsyre Blue cheese. None are positive for this organism.”
Professor Pennington believes that the incident investigation team appear to have confused two different strains of E.coli and misinterpreted its findings. _Dr Colin Fink a clinical research virologist at Warwick University who has been liaising with Actalia has also said_ that the interpretation of these tests is highly complex and, therefore open to error. His conclusion is as follows:
“I think they’ve [FSS] have actually identified it [the E.coli strain] wrongly…..”I think their science is in error”.
Flimsiness of the epidemiological case
Epidemiological evidence is generally held to be the weakest type of scientific evidence. It tries to establish associations between events/factors. But association is not the same thing as causation. Food Standards Scotland has persistently said that Dunsyre Blue was “the most likely source” of the Scottish E.coli outbreak. FSS has only released limited material supporting its case against the cheese, based on retrospective food questionnaires completed by those affected and which they have refused to disclose even with names and addresses redacted. This type of food questionnaire is notoriously unreliable. People often forget what they ate exactly, and when.
From the data released we know that fewer than half of those who became ill might have eaten blue cheese. Having pointed the finger of blame at Dunsyre Blue, FSS then excluded, and so failed to consider, other possible sources of contamination. The two most common causes of E.coli food poisoning in the UK are salad leaves, and burgers, both of which are frequently served along with blue cheese. Celery sticks, another common ingredient on cheese plates, are another well-known cause.
Raw milk cheese is a safe food
Food Standards Scotland continues to repeat its view that cheeses made from raw (unpasteurised) milk pose a greater risk to public health than pasteurised ones, and advise the public accordingly. This is factually wrong, and amounts to an old-fashioned prejudice, one that is not shared by the Food Standards Agency in England, which makes no distinction in risk terms between unpasteurised and pasteurised cheese.
The latest, most robust, and extensive scientific study on the safety of raw milk cheese was conducted by the US Food and Drug Agency. In 2016 it bought 1,606 raw milk cheeses and tested them for food-poisoning pathogens. It found no toxic or pathogenic strains of E.coli in any of these cheeses. “The FDA did not detect E.coli O157 H7 in any of the 1,606 samples it tested, irrespective of origin or type/ texture.” The FDA concluded that the overall pathogenicity (presence of food poisoning bugs) in this category of cheese was less than 1%, which compares very favourably to many other categories of food we consume daily. “The FDA found the overall contamination rates for each of the pathogens to be less than one per cent.”
Food Standards Scotland has chosen to ignore this study, but the facts speak for themselves: there have been no cases of E.coli food poisoning in Scotland traced back to raw milk cheese in the last 15 years and none even in France since 2005.
The effect on the Erringtons
The actions of Food Standards Scotland have brought the Erringtons to the brink of bankruptcy. Their cheesemaking has been closed down and seven people have been laid off. The total legal bill to date of defending Errington cheeses against the draconian actions of Food Standards Scotland has been in excess of £72,000 and will rise further as the case goes to court.
Throughout Scotland, the UK, and Ireland there are legions of disappointed retail, wholesale, and catering customers who want to buy Errington cheeses and cannot. Prior to this incident, Errington cheese was one of the jewels in the crown of Scotland’s artisan food culture, with a thriving business at home and abroad. Humphrey Errington was widely lauded as a pioneer of artisan cheesemaking in Scotland, and won many medals at the British and World Cheese Awards. Over 30 years, Errington Cheese has passed with flying colours every stringent annual government hygiene inspection. Only last year, First Minister Nicola Sturgeon used Errington cheese as an example of the excellence of Scottish Food at the launch of an export-promotion campaign.
Who polices Food Standards Scotland?
FSS was established by the Food (Scotland) Act 2015 as “a non-ministerial office part of the Scottish Administration, alongside, but separate from, the Scottish Government.” It is mainly funded by the Scottish Government, that is by Scottish taxpayers’ money.
While everyone appreciates that FSS should have strong powers to protect public health, this agency should be accountable to the public for its actions. It would appear that FSS has acted with a mixture of incompetence, bias, and belligerence. It appears to have the right to force a company, of longstanding high repute, out of business on the basis of spurious associations and discredited scientific ‘evidence’. To whom does FSS report? Is this quango only accountable to its hand-picked board, despite being largely government funded?
The outcome of the present action against Errington Cheese will have real implications not only for Scottish artisan cheesemakers but for other makers of a wide variety of foods. Success for FSS will only be good news for cheesemakers in France, Italy and Spain whose products will replace the homemade cheeses closed down by FSS. The irony is that, despite these imported cheeses being produced in ways which FSS explicitly condemn, there is nothing FSS can do to stop them being sold in Scotland.