Raw-milk based cheeses, like the gouda made by Bravo Farms that is currently linked to at least 25 E. coli O157:H7 illnesses in Arizona, New Mexico, California, Nevada, and Colorado, must be aged for a minimum of 60 days.  The requirement appears at Title 7 of the Code of Federal Regulations, section 58.439. 

One has to believe that the requirement is solely an issue of public health–i.e. pathogenic bacteria in raw milk-based cheeses aged less than 60 days may survive the aging process.  Is the inverse also true?  Will pathogenic bacteria be totally inactived, or killed, by an aging process longer than 60 days?  Or is there some wiggle room?

One of several things happened to cause the Bravo Farms cheese E. coli outbreak.  Maybe Bravo was following the law and aging at least 60 days; if so, the 60 day aging requirement certainly needs to be re-examined, particularly if even consumers knowledgeable about the rationale behind the 60 day aging requirement can’t even rely on the adequacy of the requirement, much less consumers who do not know what they are eating.

But many artisan cheeses are aged less than 60 days, and my guess would be that most of those cheeses aged less than 60 days don’t carry a plain written warning on the label stating as much.  Is it possible that Bravo was not following the requirement of 7 CFR 58.439 (there is no indication how long Bravo’s gouda is aged on its website)?  Did Costco know it, and if so, was it telling consumers about it?  

Much more to be learned in this outbreak.  Notably, the CDC and FDA investigations are ongoing; CDC’s update from yesterday states that it is still "Investigating where in the distribution chain the point of contamination could have occurred."