It is likely that your Environmental Health Officer, (EHO) is applying Food Standards Agency (FSA) guidance aimed at controlling the growth of non-proteolytic Clostridium botulinum in vacuum-packed and MAP-packed food stored between 3 and 8°C; this sets a limit on safe shelf life of 10-days. You can read this guidance at https://www.food.gov.uk/ .Search for guidance documents.

The FSA guidance is based on recommendations by the Advisory Committee on the Microbiological Safety of Food
(ACMSF). The key guidance is summarised in the the 2006 Annual report of the ACMS; you can download this from https://www.food.gov.uk/ . Search for guidance documents.

Because of the complexity of this area FSA provide advice for enforcement officers (EHO’s), you can access this
at http://vacuumpackingtraining.food.gov.uk/module4/section1/?panel=18" rel="nofollow - http://vacuumpackingtraining.food.gov.uk/module4/section1/?panel=18

This advice is well written and clearly explains how an EHO should deal with a business like yours.

The onus is on you to demonstrate through appropriate risk assessments that your smoked cheeses do have long safe shelf lives! It is unlikely you will be able to do this on your own. However, the EHO or his/her colleagues may be able to help you to do this at no cost. And other businesses have done this already.

The advice for EHO’s contains a section that is highly relevant to your business, “Do all vacuum packed and modified atmosphere packed products present the same inherent risk?”

The FSA response to this question is given below (I have added the italics):

 “Different foods will vary in their inherent risk with respect to Clostridium botulinum, and as a result their priority for enforcement attention (for example, hot smoked fish would have a greater inherent risk relative to a hard cheese like cheddar).

The 1992 ACMSF report contains further examples and details of
inherent risk in respect of Clostridium botulinum. See Table 12 of the report or see an adapted version in Module 4, Section 3.

The ACMSF report identifies three categories of products in
respect of inherent risk:

low
medium
high

Industry guidance, produced by Campden BRI, also contains a table of examples of inherent risks. See Table 1 in 'A code of practice for the
manufacture of vacuum packed and modified atmosphere packed chilled foods' (Guideline No. 11) on the Campden BRI website via the link below. Please note
that the publication is not free. Campden BRI members can buy the guidelines at a reduced (members) rate.

See Table 1 in 'A code of practice for the manufacture of vacuum packed and modified atmosphere packed chilled foods' (Guideline No. 11)
on the Campden BRI website.”

You can access the above advice at http://vacuumpackingtraining.food.gov.uk/module4/section1/?panel=18" rel="nofollow - http://vacuumpackingtraining.food.gov.uk/module4/section1/?panel=18

I would expect to see only a low risk being allocated to an established food business (with staff who have expertise and nationally recognised
qualifications in microbiology, HACCP, food manufacture) vacuum-packing or MAP-packing most (not all) smoked-cheeses. Cheddar cheese for example has
several ‘hurdle’ factors including low pH, high level of lactic acid, fairly low water activity, high salt in moisture. In addition nisin may also be present. Only some of these will be accepted “as meeting other specified controlling factors” that I mentioned above.

I hope that this helps?

Please let us know the outcome of your discussions with your EHO.

Yes the shelf life of cheese is controlled by the salt content and the pH of cheese. The shelf life of refrigerated cheese depends on a number of factors which include cheese composition (higher moisture shorter shelf life, lower salt in moisture, shorter shelf life) and other controlling factors which are summarised below.

• Cheese composition (moisture, salt, salt in moisture, water activity, and pH) Hard lower moisture cheese has a longer refrigerated shelf life than high moisture, low salt cheese has a shorter shelf life).
• Cheese microbiological quality (e.g. yeast and mould count)
• Cheese type ( Texture, soft, medium,  hard, ripened or not, processed or natural, mould surface ripened, bacteria surface ripened, brine salted or not, etc)
• Temperature  of storage(frozen cheese can have a shelf life of twelve months but not all cheese is suitable for freezing)
• Hygiene, Cleaning, Sanitation and Equipment Design (to reduce sources of yeast and mould in the cheese factory, food contact surfaces, smoking facility and packing room)
• Vacuum packing machine (well maintained working parts, sealing bars, filters and pump,  optimum draw depth, pouch dimensions optimised to reduce folds, check seal integrity, check leakers)
• Packaging Film (thickness, weight and construction of film used is critical.  The oxygen transmission rate should be less than 8cm3/m2/24h/atm.)
• Residual Oxygen (best when less than 0.5% residual oxygen)
• Pack size (optimise volume of pack to volume of cheese to avoid excess plastic and avoid film creases and folds)
• Leaker Test (carry out tests to check for leaking packs)
• Temperature control (from receipt of the cheese through to distribution)
• HACCP (have a HACCP system in place from Receipt of Cheese, Storage, Debagging, Smoking, Chilling, Packing, Metal Detection, Storage, Despatch and Distribution)
• Smoking Process (hot or cold)
• Processing (production process, handling, cutting, slicing, etc)
• Preservative (with or without)

The food business operator has to justify and validate the shelf life of its products for is customers and the EHO.  A shelf life at refrigeration temperatures of two months can be achieved for smoked cheese that is vacuum packed in the correct manner.

I wish you every success with your venture.