An open letter to Mark DeNittis: Why is Il Mondo Vecchio closing?
2) Starter Cultures
On your site, you also mention that there is no use of starter cultures. How do you ensure the proper drop in pH to achieve the necessary decrease in water activity that is required to halt the growth of pathogens? Do you measure pH to ensure a Log7 (99.99999%) reduction of fecal coliform? Everything I've read dictates that a starter culture is crucial to the prevention of unwanted bacteria, as well as to break down any nitrates present into nitric oxide. Without the use of cultures, it's been my experience that there is significant wasted product due to lack of consistency in the end product. Furthermore, in European traditions, there is often a practice employed that when good cultures are discovered, they are scraped from the finished product and inoculated in pieces of wood and/or cloth to ensure that they consistently present during the drying process. So is your object to only to purchased starter cultures" or do you also oppose starter cultures made by traditional "Old World" methods?
"Il Mondo Vecchio essentially hit an impasse. They could either change their methods to a process that has been validated by the USDA such as fermenting (cooking the product) or adding nitrites, nitrates, acids or copious amounts of salt, all resulting in what IMV believes to be an inferior product or stop production."
In the above quote from the press release, you say that fermentation is the equivalent of "cooking the product ", which is entirely not true. Fermenting is done at temperatures between 66 - 75 degrees and a humidity of approximately 90%. The process does not produce enough heat to raise the temp enough to cook or kill bacteria. The process of fermentation is simply the production of lactic acid within the meat to produce the desired acidity and sourness by increasing the amount of lactic acid producing bacteria.
3) USDA Challenges
"One option the USDA did make available to Il Mondo Vecchio, DeNittis tells me, was to pay $7,000 to conduct a "challenge study"--essentially a test that would prove the USDA wrong. But even that might not be enough for the agency.
"You can do the challenge study," DeNittis says the agency told him, "but we may not accept the results."
In the articles and mass emails sent, you state that USDA challenges were costly and time-consuming and thus weren't something you were going to pursue. You list a figure of $7,000 as the cost. While this is not a small sum for most folks, as a producer with three years of business at stake and presumably millions of dollars invested, it seems a small sum to pay. I would think at least a single attempt would be made to protect your methods, product integrity and your business. There have been quite a few challenges that have been accepted, one more notably being Salumeria Biellese in NYC, which submitted their challenge to the USDA and won (They don't use nitrates either, so it is not impossible to win). I struggle to understand not even a single attempt on your part, especially with as detailed a records you reference in the articles, as well as confidence in your methods.
" In a recent audit of their procedures, the USDA required Il Mondo Vecchio to provide a scientific study or additional support documentation to further prove the validity of their procedures or change their procedures to fit a standard USDA production method. Because Il Mondo Vecchio was essentially producing salumi in a manner that no one had previously successfully validated under the USDA and because the USDA is not set up for artisanal producers, the USDA regulators put the burden on Il Mondo Vecchio to prove the procedures were in compliance. "
As I understand the law, there are opportunities to change the level of nitrates and/or salt to be used for dry curing from the defaults provided by the USDA. The USDA does however require you to provide adequate proof that your process would achieve Log7 (99.99999%) reduction of coliform bacteria. If you can't prove this with your methods, it opens up the questions:
Are the methods in place in fact adequate and safe?
Why not use nitrates until you can prove your methods through the challenge submission?
With precedents in place, and a clearly loyal customer base, why not challenge? Again, faith and evidence in the safety of the process has clearly been demonstrated in previous cases. (http://www.leaveitbetter.com/blog/the-salumeria-biellese-takes-its-salumi-seriously-sustainably-an/)