Two Types of Raw Milk

My family has been drinking raw milk for over 18 years. I drank raw milk through both of my pregnancies and raised both of my kids on raw milk since they were weaned from breastmilk as toddlers. I have purposely chosen raw milk for my family because of its exceptional health benefits and animal welfare.

Studies performed in Europe have shown that children who drink raw milk have decreased rates of asthma, allergies, eczema, ear infections, fever, and respiratory infections. Nonetheless, when I tell people that my family drinks raw milk, I often hear responses such as:

“Raw milk is dangerous!”

“Doesn’t raw milk make people sick?”

“I heard that raw milk was bad for you.”

The reason for raw milk’s negative reputation is that there are two types of raw milk!  Raw milk that is intended for pasteurization is quite different than raw milk produced for direct human consumption.

Raw Milk Intended for Pasteurization

When my family drives past a nearby dairy that produces milk for pasteurization, we are struck by the horrendous smell and filthy living conditions.  The animal yard is completely covered with manure. The cows have no choice but to lie and stand in manure all day. It is disgusting to think that this operation is producing food for families.

Raw milk that is “intended for pasteurization” is typically sourced from Concentrated Animal Feeding Operations (CAFOs). This type of milk is actually defined under the Federal Grade A Pasteurized Milk Ordinance (PMO).  Such milk is being produced in conditions where animal health is often compromised and mastitis (udder infection) is common.  Antibiotics are often utilized in these herds, and hormones are used to stimulate higher levels of milk production. The animals are housed in an abundance of manure, and there is a corresponding high rate of pathogens.

This milk is intended to be pasteurized to kill pathogenic bacteria, and as such, it is often produced with little care towards preventing contamination with pathogens. Furthermore, this type of milk is generally commingled with milk from multiple dairies, which increases the risk of pathogenic exposure. Studies have shown that up to 33% of this type of milk tests positive for pathogens. This type of raw milk is clearly unsafe to consume. I would never feed this type of raw milk to my family.

Raw Milk Intended for Direct Human Consumption

When my family visits the dairy that produces the raw milk that we drink, we see a very different setting from the CAFO dairy. The cows at the raw milk dairy are happily grazing on lush pastures. The cows look clean and healthy. The milk is bottled on-farm, and we can see that the milk bottling room is clean and neat. There is a stark contrast between the CAFO dairy and this raw milk dairy.

Raw milk that is carefully and intentionally produced for direct human consumption is wholly different from raw milk being produced for pasteurization. Raw milk farmers carefully manage the cleanliness and hygiene of the farm from grass-to-glass, with much care to ensure that the animals are healthy and the milk is clean.

From the health of the herd, to cleanliness of the milking parlor, to the specific cleaning processes for the milk line, to ensuring rapid milk chilling, to regularly testing their milk, and everything in between, raw milk farmers are dedicated to taking their farm management to the next level in order to ensure that their raw milk is safe to consume.

Although there are no federal standards for raw milk, the Raw Milk Institute has established Common Standards for raw milk that is intended for direct human consumption.  This type of raw milk is tested often and held to rigorous standards to ensure that it is being produced in a way that discourages pathogen growth.

Where Do Pathogens in Milk Originate?

The four main pathogens in milk that can cause human illness are E coli 0157:H7, listeria mono, salmonella, and campylobacter. The two most common sources of pathogens in milk are manure and mastitis. It is estimated that one-third of CAFO dairy cows have mastitis, and the cows in CAFOs stand and lie in manure all day. Clearly, this type of dairy environment is primed for pathogen growth.

On the other hand, the raw milk dairy environment is carefully managed to prevent pathogens in the milk. These farmers manage the health of their herd to prevent mastitis. They ensure that the milk from any animals that are showing signs of mastitis is not used for direct human consumption. Raw milk farmers meticulously clean the udders before milking to ensure that no manure or other contaminants are present. They also rigorously and frequently clean their milking machines, milk lines, and milk tanks.

Take a look at the milk filters shown below.  Even with just a quick look, it is apparent that the milk being produced with the intent to be pasteurized is clearly not clean, whereas the milk filter from the intentionally-produced raw milk looks impeccable. (To be fair, there are some dairy farmers who produce milk for pasteurization that is much more hygienic than most others. However, that milk is still commingled with milk from other dairies, many of which are likely to not use hygienic practices.)

Comparison of Bacterial Test Standards for Two Types of Raw Milk

Okay, I’m gonna get technical here.  If reading about standards and looking at charts is not your thing, you can skip ahead to the last section. :)

Two important types of bacterial testing for milk are Standard Plate Count (SPC) and coliform count. The SPC is a measure of the total number of aerobic bacteria in the milk. High SPC numbers can indicate dirty milking equipment, poor milk chilling, and/or poor udder preparation.

Coliform count measures the amount of coliform bacteria present in the milk. Coliform counts measure the overall hygiene and cleanliness of the milk. High coliform counts generally indicate the presence of manure or other environmental contaminants on the udders or milking equipment. High coliform counts are likely to correspond to the presence of pathogens in the milk.

According to the PMO, pre-pasteurized milk is allowed to have up to 100,000 colony-forming units (cfu) of bacteria per mL in SPC testing. The PMO does not have a standard for how many coliforms are allowed in pre-pasteurized milk, but the state of California allows coliforms up to 750 cfu/mL of milk.

In comparison, the Raw Milk Institute Common Standards call for <5,000 cfu/mL for SPC testing, and <10 cfu/mL in coliform testing. As you can see in the chart below, intentionally-produced raw milk is measurably quite different from pre-pasteurized raw milk, and even meets stricter standards than pasteurized milk.

The Raw Milk Institute has been collecting monthly Standard Plate Count and Coliform Count data from its LISTED raw milk dairies since 2012.  This dataset of thousands of test results shows that raw milk farmers who have been properly trained can routinely meet the stringent standards set forth in the Common Standards.

Research on Raw Milk Safety

Researchers from Canada and Europe have studied the safety of raw milk intended for direct human consumption. They have found that carefully produced raw milk is a low-risk food which is fundamentally different from pre-pasteurized milk. 

The table below contrasts pathogen test data from pre-pasteurized milk vs. raw milk intended for direct human consumption.  As illustrated in the table, pathogen testing of pre-pasteurized milk samples has detected pathogens in up to 33% of samples.  In contrast, there were zero pathogens detected in thousands of milk samples from raw milk intended for direct human consumption. It is clear from this test data that pre-pasteurized milk is categorically different from raw milk intended for direct human consumption.

Data courtesy of the British Columbia Herdshare Association

Not All Raw Milk Is Dangerous!

It is clear that raw milk produced with the intention to be pasteurized is likely to contain dangerous pathogens. This type of raw milk is unsafe, and I would never feed it to my family. Unfortunately, this type of raw milk’s negative reputation has led many to believe that all raw milk is unsafe to consume.

It is important to note that there is no such thing as a perfectly safe food. An analysis of foodborne illnesses from 2009-2015 showed that the top food categories commonly linked to illnesses were chicken, pork, and seeded vegetables. Pasteurized milk is not perfectly safe, either, and is implicated in foodborne illnesses and outbreaks every year.  The CDC outbreak and illness data which is used to assert that raw milk is unsafe does not distinguish raw milk intended for pasteurization from raw milk that is carefully produced and intended for direct human consumption.

It is clear from the above-presented test data that intentionally-produced raw milk is a low-risk food. In my family, we purposely choose raw milk for its superior nutrition and significant health benefits over pasteurized milk.  Raw milk contains greater bioavailable nutrients than pasteurized milk, as well as a wide array of beneficial enzymes and probiotics which are known to have benefits on the immune system and gastrointestinal tract.   

FREE Raw Milk TRAINING: RAWMI Risk Management Training Video Series

The Raw Milk Institute (RAWMI) has trained hundreds of farmers through in-person workshops around the USA and Canada.  For those who cannot attend our training in-person, we have a free web version for you!

RAWMI’s Risk Management Training Workshop is now available to watch on Vimeo here. This 4.5 hour course is broken into 17 segments for easier viewing. There are direct links to each of the 17 segments towards the bottom of this post.

About the Training

This RAWMI training focuses on:

• benefits of raw milk,

• grass-to-glass identification of risks,

• development of a risk management plan, and

• lessons learned from other raw milk dairies.

It includes lots of practical tips for the production of safe raw milk. This training has been shown to reduce outbreaks and illnesses, increase safety, and lower insurance costs.

Links to Specific Segments

The overall training course is 4&1/2 hours long, but we have broken that down into 17 smaller segments so that you can easily find the sections you want to watch.  

WORKSHOP OVERVIEW: 

PART 1 – Introductions and About Raw Milk Institute  

PART 2 – Raw Milk History and Opposition 

PART 3 – Raw Milk Benefits 

PART 4 – Raw Milk Risks and RAWMI Method 

PART 5 – Introduction to Grass-to-Glass Risk Management   

PART 6 – Small-Scale and Large-Scale Raw Milk Production 

PART 7 – Risk Minimization: Grass, Pasture, and Water 

PART 8 – Risk Minimization: Animal Health and Biosecurity 

PART 9 – Risk Minimization: Milking and Udder Prep 

PART 10 – Risk Minimization: Management 

PART 11 – Q&A for Parts 1-10 

PART 12 – Risk Minimization: Management (cont.) 

PART 13 – Risk Minimization: Management (cont.) 

PART 14 – Risk Minimization: Glass, Bottling, and Inspections 

PART 15 – Raw Milk Testing 

PART16 – Why to Become RAWMI LISTED 

PART 17 – Conclusion and Final Q&A

What Attendees Have Said

Here is some of the feedback we received from attendees at this training: 

“Excellent presentation that every single person who dairies for themselves and their family should take and learn from. Thank you very much.”

“This has been excellent!  ONLINE was so helpful as it’s hard to travel and be away.”

“For me, the combination of technical information and anecdotes is very effective for explaining why the RAWMI methods are important and how they solve a raw milk producer challenges. I came away with practical solutions to increase the quality/value of our milk and farm. Thank you." 

“I left the Zoom meeting with a very clear understanding of what we are doing right and where we need to make changes. Beyond that, though, I left inspired to pursue excellence and cast a clear vision to everyone who is joining me in this endeavor.”  

“The information was also rich and informative. I learned a ton and the systematic way you presented it was easy to follow and comprehensive.” 

“I cannot wait to move forward with you in becoming RAWMI Listed. We will be making some changes as we form our RAMP plan. We have already adjusted our milk chilling and have seen an improvement in flavor and longevity.”  

“Thank you for all you do. I have no doubt history will look back at the RAWMI as having played a crucial role in reforming raw milk production, health, and nutrition.”

DONATE to HELP Farmers Test Their Raw Milk

You can help farmers and families thrive by donating for milk testing equipment!

Ongoing bacterial testing is one of the pillars of low-risk raw milk production. With testing, farmers can easily detect small issues before they turn into big problems. However, testing costs can be an ongoing financial burden which makes small-scale farmers hesitant to test their milk often. The solution is on-farm labs, where farmers can perform their own bacterial tests for just $1-$3 per test.

On-farm labs don’t take up much space or need a lot of sophisticated equipment. With a simple incubator, set-up costs for on-farm labs are in the range of $800-$1,000. Because even those costs can be too much for small-scale farmers, at the Raw Milk Institute we devote $5000 of our budget yearly to providing grants for on-farm labs. We give 10 farmers $500 each to help cover the costs of setting up their on-farm labs.

As a 501c3 non-profit, we rely on donations and run on a low operating budget, but nonetheless we want to help as many farmers as possible have the capability to test their milk. However, with so much increased interest in raw milk, we have already given out all 10 of the lab grants we budgeted for in 2024! There are still many more farmers who want on-farm labs to help in producing low-risk raw milk, but we do not have the budget to continue giving out more lab grants this year.

This is where you come in. Your donations, no matter how small, can help more farmers build their on-farm labs so they can test their raw milk regularly. For every $500 we raise, we will be able to gift another farmer with a grant to make on-farm testing a reality.

Will you please donate today to help farmers purchase on-farm labs for testing their milk?

100% of your donation will go to helping farmers purchase testing equipment.

You can donate here: https://www.givesendgo.com/farmerlabs

USA-based donations are tax-deductible. With your support, we can continue to provide lab grants to raw milk farmers.

A Caution About Bleach and Chlorinated Sanitizers for Milking Equipment and Bottles

Sanitization can be an important part of an overall cleaning process for raw milk equipment, bulk tanks, and bottles. This is because bacteria growth can occur in milking equipment during the time between milkings.  These bacteria can contribute off flavors to the milk, shorten shelf-life, and in rare cases they can contribute to pathogenic illness when the raw milk is consumed.  The use of a sanitizer can help by reducing the bacteria load in milking equipment.  

Simple bucket milker systems and pipeline systems being used more than once per day may not need be sanitized prior to milking, and this can be confirmed with the use of bacterial tests. However, pipeline systems, and especially pipeline systems being used only once per day, may necessitate the use of a sanitizer rinse just prior to milking in order to lower the level of bacteria in these systems. Additionally, some states (such as Vermont) require that a sanitizer be used on milking equipment just before milking. 

Bleach and chlorine-based sanitizers are readily available and widely used for milking equipment.  However, when bleach or other chlorine-based sanitizers are used, special attention needs to be given to ensure that the amounts of sanitizer being used are carefully controlled.

Harmful By-Products from Chlorine Sanitizers

Although chlorine is quickly inactivated by contact with organic matter, chlorine is also known to create disinfection byproducts that can be toxic including trihalomethanes such as trichloromethane (i.e. chloroform). These toxic byproducts are formed when the acetoin, diacetyl, and other methyl ketones in milk react with chlorine [1].  

Trihalomethanes and chloroform have been shown to increase the risk of cancer, liver damage, fertility problems, and miscarriages [2]. Chloroform is categorized by the USA Environmental Protection Agency as a Probable Human Carcinogen.

Harmful Chlorine Byproducts in Milk

Studies, including those shown below, have shown that when chlorine-based sanitizers are used in greater-than recommended amounts, there can be unhealthy levels of sanitizer residues and toxic byproducts in the milk.  

• Volatile Organic Compounds in Foods: A Five Year Study [3] – In this study, the highest levels of chloroform in foods in the USA were found in dairy products.

• Chloroform in milk and dairy products B: Transfer of chloroform from cleaning and disinfection agents to dairy products via CIP [4] – This study found that the use of chlorine-based sanitizers in a Clean-In-Place (CIP) milking system can result in chloroform formation and contamination in the raw milk.  Chloroform was also found to concentrate in the milkfat, and therefore the levels of chloroform in cream, butter, and cheese were greater than the amounts in fluid milk.

• Evaluation of Trichloromethane formation in Cow’s milk from chlorine-based cleaning and disinfection agents [5] – This study found that “Increased chlorine concentration in the detergent and reduced rinse water volume resulted in increased TCM [trichloromethane] concentrations in milk, while the addition of chlorine to the rinse water also increased milk TCM.”

• Strategy for the reduction of Trichloromethane residue levels in farm bulk milk [6] – This study found that the ‘first milk’ that was collected in a milk pipeline system was likely to have higher concentrations of chloroform than milk which was collected subsequently.  Increasing the volume of rinse water in the pipeline resulted in a decrease in the amount of chloroform in the milk.  When chlorine-based sanitizers were used in recommended amounts, the total level of chloroform was found to be below the acceptable limit.

Acceptable Limit Standards

The USA Environmental Protection Agency sets an acceptable limit for chloroform and other trihalomethanes in drinking water at 0.06-0.08 mg/L [7]. The European Union (EU) sets the acceptable limit for chloroform and other trihalomethanes in drinking water at 0.1 mg ⁄kg [5]. Both of these standards are well below the concentration that would be considered carcinogenic.

The USA and EU have not published regulations on the acceptable limits for chloroform and other trihalomethanes in food.  However, in Germany 0.1 mg/kg has been set as the acceptable limit for chloroform and trihalomethanes in food, and target levels of <0.03mg/kg for butter and <0.002 mg ⁄kg for milk have been recommended [5].

Practical Advice for Raw Milk Farmers

We know that the use of no-rinse chlorine sanitizers in greater-than-recommended amounts can result in harmful levels of toxic byproducts (including chloroform) in the fluid milk.  

These issues would be lessened somewhat with the use of simple bucket milker systems as opposed to milk pipeline systems (wherein the milk flows over greater lengths of sanitized surfaces and cleaners can concentrate in low points in the pipeline system).

factors that make it more likely that sanitizers will be needed:

• More complex milking systems, such as pipeline systems,

• Milking only once a day instead of twice a day, and/or

• Hot or humid climates which can contribute to bacterial growth and prevent dairy equipment from drying properly between uses.

guidelines for using bleach or chlorinated dairy sanitizer as a no-rinse sanitizer:

• By federal regulations, bleach needs to be used at a concentration of no greater than 200 ppm, which could generally be achieved by using no more than 1 Tablespoon of bleach per gallon of water (assuming the bleach has a content of 5.25% sodium hypochlorite).

• Alternatively, chlorine test strips can be used to verify that the chlorine concentration is correct. 

• Be aware that some bleaches (such as Clorox Disinfecting Bleach) have a higher concentration of sodium hypochlorite and therefore need to be used in smaller amounts.

• When using chlorinated dairy sanitizer, make sure to carefully measure the amounts of sanitizer and water to ensure that the concentration of sanitizer is no greater than recommended.

alternatives to using chlorine-based sanitizers include the following:

• A pure water rinse can be performed after the use of chlorine-based sanitizers, just prior to milking or bottling.

• Hydrogen peroxide-based sanitizers can be used instead of chlorine-based sanitizers.  Hydrogen peroxide-based sanitizers do not create toxic byproducts.

• Acid-based sanitizers can be used instead of chlorine-based sanitizers. Beware that some acid sanitizers may not have a long enough time of action to be sufficient for milking systems that are only used once per day.

• Sanitizers may not be needed, depending on the complexity of the system, frequency of milking, and climate.  For instance, some farms using bucket milkers have had success in achieving low bacteria counts with the implementation of alkaline and acid cleaners without using a sanitizer. Testing for coliforms and Standard Plate Count can be used as a confirmation step to verify that the use of a sanitizer is not needed. Ideally, this testing should be performed throughout the year to ensure that a sanitizer is not needed regardless of weather factors (such as humidity and heat).

NOTE: Care must be taken with both chlorine-based and hydrogen peroxide-based sanitizers to ensure that they are never mixed with acid cleaners or vinegar.

References

1.       Coura, Fernanda & FERREIRA, F. & Barbieri, Jonata & PACIULLI, S.. (2020). QUEIJO MINAS ARTESANAL PRODUZIDO NA REGIÃO DE CANASTRA: CARACTERÍSTICAS DOS PARÂMETROS DE PRODUÇÃO, QUALIDADE DA ÁGUA E DOS QUEIJOS. Ars Veterinaria. 36. 78. 10.15361/2175-0106.2020v36n2p78-87. https://www.researchgate.net/publication/342483080_QUEIJO_MINAS_ARTESANAL_PRODUZIDO_NA_REGIAO_DE_CANASTRA_CARACTERISTICAS_DOS_PARAMETROS_DE_PRODUCAO_QUALIDADE_DA_AGUA_E_DOS_QUEIJOS/citation/download

2.       Environmental Protection Agency (2000). Chloroform.  https://www.epa.gov/sites/default/files/2016-09/documents/chloroform.pdf

3.       Fleming-Jones, Mary & Smith, Robert. (2004). Volatile Organic Compounds in Foods: A Five Year Study. Journal of agricultural and food chemistry. 51. 8120-7. 10.1021/jf0303159. https://www.researchgate.net/publication/8947382_Volatile_Organic_Compounds_in_Foods_A_Five_Year_Study/citation/download

4.       Resch, P. & Guthy, K.. (2000). Chloroform in milk and dairy products B: Transfer of chloroform from cleaning and disinfection agents to dairy products via CIP. Deutsche Lebensmittel-Rundschau. 96. 9-16. https://www.researchgate.net/publication/287869065_Chloroform_in_milk_and_dairy_products_B_Transfer_of_chloroform_from_cleaning_and_disinfection_agents_to_dairy_products_via_CIP

5.       Ryan, Siobhan & Gleeson, David & Jordan, Kieran & Furey, Ambrose & Brien, A. (2012). Evaluation of Trichloromethane formation in Cow’s milk from chlorine-based cleaning and disinfection agents. International Journal of Dairy Technology. 65. 498-502. https://onlinelibrary.wiley.com/doi/10.1111/j.1471-0307.2012.00858.x

6.       Ryan, Siobhan & Gleeson, David & Jordan, Kieran & Furey, Ambrose & O'Sullivan, Kathleen & O'Brien, Rebecca. (2013). Strategy for the reduction of Trichloromethane residue levels in farm bulk milk. The Journal of dairy research. 80. 1-6. 10.1017/S0022029913000113. https://www.researchgate.net/publication/235894115_Strategy_for_the_reduction_of_Trichloromethane_residue_levels_in_farm_bulk_milk/citation/download

7.       National Primary Drinking Water Regulations. Environmental Protection Agency. https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations

How to Clean Your Milking Equipment for Low-Risk Raw Milk

Whether you are a farmer using a simple bucket milker or a more complex pipeline milking system, cleanliness of equipment is a top priority for low-risk raw milk. Improper cleaning of milking equipment can lead to increased bacteria counts in the milk, off flavors, shortened shelf life, and increased likelihood that there will be pathogens present in the milk. Milking equipment needs to be cleaned after every milking.

Clean milking equipment is part of an overall goal for ensuring that there will be very little bacteria growth in the milk.  When bacteria counts are low and the milk is kept properly chilled, raw milk will stay fresh for at least 2-3 weeks, with the delicious flavor that keeps your customers coming back over and over again.  

Example of an Effective Cleaning Process for Milking Equipment and Bulk Tanks

Cleaning Process	Purpose	Notes
1. Flush with lukewarm water	Rinse away milk and organic debris	It is very important that the first rinse is done with lukewarm water. Otherwise, the milk may coagulate and stick to the equipment surfaces.
2. Hot alkaline wash	Remove bacteria, protein, fat, and biofilms from the equipment surfaces	Dairy detergent and most soaps are alkaline cleaners. Bucket milkers and tank valves should be disassembled and scrubbed clean with hot soapy water. Pipeline systems rely on turbulent flow of hot soapy solution through the clean-in-place system. The temperature of the soapy water needs to be at least 120 F at the outlet of the system to prevent milk solids from re-adhering to surfaces.
3. Warm acid rinse	Lower the pH of the equipment surfaces to create an environment that is unfavorable for bacterial growth	Most bacteria grow best in neutral pH environments. Using an acid rinse as the last cleaning step makes bacterial growth less likely to occur in-between usage of the equipment. Ideally, the acid rinse should have a pH of 3-4.
4. Dry	Remove moisture to make it hard for bacteria to grow	Invert equipment such as inflations and milk buckets to allow them to drip dry between uses. Completely dry milk tanks and valve parts between uses. Avoid having low spots where moisture can accumulate in pipeline systems.
5. Sanitize just prior to milking (optional)	Inactivate any bacteria that have grown in the system in between milkings	Pipeline systems, and especially pipeline systems being used only once per day, may necessitate the use of a sanitizer rinse just prior to milking. Simple bucket milker systems and pipeline systems being used more than once per day may not need to use a sanitizer prior to milking. This can be confirmed through coliform and Standard Plate Count testing. Some states require a sanitizer be used on milking equipment just before milking. Care needs to be taken to ensure that no more than the proper amount of sanitizer is used, to ensure that no undesirable residues end up in the milk.

Biofilms Provide a Place for Bacteria to Grow

Biofilms are symbiotic colonies of bacteria that can adhere to the inside of the milk lines, valves, crevices, etc. Through a process called quorum sensing, bacteria within biofilms are protected with multi-species cooperation. This makes the bacteria in biofilms hard to remove and destroy.

Biofilms can provide a safe haven for the growth of pathogens such as E. coli 0157:H7, Campylobacter spp., Listeria monocytogenes, and Salmonella spp. As biofilms grow larger, pieces of biofilm can break off when milk flows through the system, leading to contaminated milk. 

Cleaning to Prevent Biofilms

Preventing biofilms in bucket milker systems is fairly simple since the components can be disassembled and scrubbed clean after every milking.  However, milk pipeline systems require extra care to ensure that biofilms do not grow in the system. Since it is not possible to manually scrub the internal surfaces of the pipeline system, the cleaning process relies on turbulent flow of hot liquid cleaning solutions to wash away any bacteria in the lines. 

Valves, gaskets, low points, and bends in the system create opportunities for biofilm growth. Pipeline systems need to be designed to minimize bends and ensure there are no low points where moisture can accumulate in the system.  Valves and gaskets need to be completely disassembled and cleaned often to prevent biofilm growth.  This includes the valve on the bulk tank, which should be completely disassembled and cleaned every time the milk tank is emptied.

Periodically Change Cleaners to Prevent Biofilm Growth

The use of both alkaline and acid cleaners will help prevent biofilm growth. Nonetheless, over time biofilms can become resistant to specific cleaners, especially in pipeline systems.  Therefore, it is recommended to periodically “shock” the system by using different alkaline and acid cleaners about once a month. Simple bucket milker systems may not need to periodically alter their cleaners since they are completely disassembled and manually scrubbed after each use.  

NOTE: Quaternary ammonias are not recommended for cleaning milking equipment because they are difficult to fully remove and can linger on the equipment. 

Aim for “Kitchen Clean”

The main goal when cleaning milking equipment is to achieve “kitchen clean.”  There is no need to go overboard by using high concentrations of harsh cleaners. If you overdo it, your cleaning processes can lead to early degradation of your milking equipment as well as unhealthy residual components in the milk. 

Aim instead to find a good balance where you are cleaning your milking equipment enough to be clean and dry like the dishes in your kitchen.

Lukewarm Water First, Then Hot Cleaner

Make sure that the first rinse of the milking equipment is performed with lukewarm water.  This will allow the residual milk to wash away without coagulating on the internal surfaces of your milking equipment.  Using water that is too hot or too cold can result in the milk adhering to the internal surfaces of the milking equipment.

Once the initial rinse is completed, it is important to use hot alkaline cleaning solutions to ensure that fats and bacteria are washed out of the system. Bucket milkers and tank valves should be disassembled and scrubbed clean with hot soapy water. A pump can also be used to circulate the hot cleaning solution through bucket milker systems.

For clean-in-place systems, the temperature of the cleaning solution needs to be measured to ensure it is still at least 120 F at the outlet of the system.

Acid Rinse

Using a warm acid rinse as the last step in the cleaning process is important for minimizing bacteria growth in the system in-between milkings.  Most bacteria grow best in neutral pH environments, so ending with an acid rinse creates an environment in which bacteria are less likely to proliferate. Ideally, the acid rinse should have a pH of 3-4 for the greatest effectiveness.

Drying

Allowing milking equipment, buckets, and tanks to fully dry in-between uses is another important step in limiting bacteria growth in-between milkings. Milk buckets, hoses, and inflations should be inverted to allow them to drip dry.

Complex pipeline systems may not be able to be dried completely between uses. These systems will need to rely on acids and sanitizers to ensure that bacteria counts remain low. Additionally, these systems should be designed to avoid low points where moisture can accumulate.

Sanitize Prior to Milking (Optional)

Some systems, such as pipeline systems being used only once per day, will need to use a sanitizer rinse just prior to milking in order to keep bacteria counts low.  Summer humidity and heat, which can contribute to bacterial growth and prevent dairy equipment from drying properly between uses, may also necessitate the use of a sanitizer rinse just prior to milking. Additionally, some states (such as Vermont) require that a sanitizer be used on milking equipment just prior to milking.

Studies have shown that when sanitizers are used in greater-than recommended amounts, there can be unhealthy levels of sanitizer residues and by-products in the milk.  Therefore, care needs to be taken to ensure that no more than the proper amount of sanitizer is used.

If bleach is used as a no-rinse sanitizer, by federal regulations it needs to be used at a ratio of no more than 1 Tablespoon of bleach per gallon of water (assuming the bleach has a content of 5.25% sodium hypochlorite). Alternatively, chlorine test strips can be used to verify that the chlorine concentration is correct.  Be aware that some bleaches (such as Clorox Disinfecting Bleach) have a higher concentration of sodium hypochlorite and therefore need to be used in smaller amounts.

Test to Verify That Cleaning Process is Working Well

Every farm is unique, so there is no one cleaning process that will work in all cases.  For instance, complex milk pipeline systems require different cleaning processes than simple bucket milker systems. Coliform Count and Standard Plate Count (SPC) tests can be used as verification tools to determine whether the cleaning process is working properly.

Ideally, these tests should be performed at least once a month, or more frequently such as weekly or daily.  These tests can be performed inexpensively and conveniently with the use of an on-farm lab. (The Raw Milk Institute is still offering grants to offset the costs for on-farm lab materials to farmers who are completing our free Listing program.)

Testing more often allows farmers to identify trends and trouble spots. Whenever the cleaning processes or equipment are being changed, coliform and SPC testing can be performed to ensure that the new processes and equipment have been optimized for low-risk raw milk.

Daily Cleaning Habits for Success

Once you’ve optimized your cleaning processes and verified that they work well through bacterial testing, you can settle in to creating the daily cleaning habits that will keep your milk production running smoothly.  You may also find that the shelf-life of your milk has increased and that the flavor is even better.  

If you need help optimizing your cleaning processes for low-risk raw milk, contact us for free mentoring.

NOW Available: Farmer Training Booklet

Raw Milk Institute is pleased to announce that we have released an introductory farmer training booklet! We developed this booklet to meet the needs of farmers who prefer written materials or cannot access our online training resources.

Our introductory booklet about production practices for low-risk raw milk includes information about:

• Managing the Conditions for Low-Risk Raw Milk

• Udder Preparation for Low-Risk Raw Milk

• Rapid Chilling of Raw Milk To Reduce Risk of Pathogens and Improve Shelf-Life

• Managing the Risks of “Fresh” Cows and Does

• Managing the Risks of Calf-Sharing

• How to Clean Your Milking Machine

This booklet is offered in two formats:

• A spiral-bound, 43-page booklet, printed in full color

• A 41-page, full-color PDF digital download

You can get the RAWMI Booklet here: https://www.rawmilkinstitute.org/shop

Avian Flu and Raw Milk: A Common Sense Approach

Breaking News!  There is a concern among dairymen and biosecurity experts about a multistate outbreak of avian flu that is affecting cattle in Texas, Kansas, Michigan, New Mexico, and Idaho. Various Federal and state government agencies are using this cow illness outbreak as a stage to warn consumers against drinking raw milk. 

According to the US Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS), in cattle this illness causes decreased lactation and low appetite, but the cattle generally recover without dying. Cows who have contracted this illness have recovered “with little to no associated mortality,” according to the USDA.

The press and media information released by the USDA and others warns against drinking raw milk from affected cows. They further state that pasteurization protects consumers from the illness.  

Raw Milk and Breastmilk are Very Similar

As a premed-trained dairy farmer who is a 12-year member of the UC Davis International Milk Genomics Consortium (IMGC), I have studied viral infections in cows and the immunologic and biomechanics of antibody creation.  Based on what is known about antibodies and raw milk, there are deep flaws in the warnings about consuming raw milk related to avian flu.  

Dr David Dallas PhD is an IMGC researcher who studies milk genomics. At the 2023 IMGC Symposium, Dr Dallas reported that raw milk from cows and goats is “qualitatively similar” to human breast milk.  However, “quantitatively” bovine raw milk and human breast milk have “different levels” of various milk components.  

This is why raw milk from cows and goats is so well-digested and compatible by human consumers. We can thus compare human mammals with bovine mammals in how mothers protect their babies. 

Mammals Protect Their Young Through Antibodies in Raw Milk

In 2004, the state of California Veterinarian visited our dairy to perform tuberculosis testing of our cows. He told me something I will never forget: “Mammals protect their young.”  

What he meant was that, in general, when a mother becomes infected by a virus or bacterial infection, she will produce antibodies in her raw milk that will provide her young with protection from the illness.  This is part of why breastfed babies are known to have stronger immune systems than babies raised on formula.  Antibodies in raw milk are one way that Nature assures the strength and survival of the next generation.  

The CDC readily acknowledges that mothers should continue to breastfeed their infants because “flu is not spread to infants through breast milk.” They know that breastmilk contains “antibodies and other immunological factors that can help protect her infant from flu.” Similarly, studies performed at the UC Davis dairy lab during COVID found that exposing a cow to coronavirus resulted in antibodies to coronavirus in her raw milk.  

These studies were a further confirmation of what doctors and the owners of Alta Dena dairy knew way back in the 1960’s: cows that have been exposed to illnesses create antibodies to the illnesses which are then passed through their raw milk.  Decades ago, Alta Dena dairy would purposely make immune milk for certain consumers and doctors by intentionally exposing cows to specific illnesses. This raw milk was used to help heal sick people.  Now the FDA does not allow this practice and threatens anyone who uses it with criminal charges. They consider it to be equivalent to creating a new drug without oversight, which is a crime in the USA under the Food Drug and Cosmetic Act.  

Further back in history, it was observed that the milk maidens of the 1700-1800s did not catch smallpox because of their exposure to cowpox by being around dairy animals and drinking raw milk.

Common Sense Approach to Avian Flu in Cattle

The warnings against raw milk related to avian flu are clearly fearmongering.  The FDA acknowledges that “there is limited information available about the transmission of bird flu in raw, unpasteurized milk.” Then they go on to use the same fearmongering tactics they’ve been using for decades against raw milk, despite the fact that there is now ample evidence that raw milk can be carefully produced as a low-risk food.  

Conscientious raw milk producers already monitor their herds for illness and ensure that raw milk from unhealthy animals is not used for direct human consumption. Additionally, biosecurity measures such as maintaining a closed herd and quarantining any new animals are implemented.   

These are common sense measures that are already recommended by the Raw Milk Institute and used by diligent raw milk farmers. We have no reason to suspect that any further measures are necessary in the current Avian flu outbreak in cattle.  Mammalian milk is uniquely designed to protect and strengthen the immune system, and those systems will continue on as new threats arise.

FDA Demonstrates Bias Against Raw Milk in Unfounded Raw Cheese Recall

Government agencies in many countries have been biased against raw milk and raw dairy products for over a century.  This is true in the United States as well, even though Dr Henry Coit and the American Association of Medical Milk Commissions demonstrated that raw milk could be produced carefully and hygienically as a low-risk food all the way back in the late 1800’s.

Anti-raw milk smear campaigns and propaganda have been used continually to make people fearful of raw milk and raw milk products. In reality, raw milk can be produced as a low-risk food when farmers are trained and use careful production practices.

Of course, there is no such thing as a perfectly safe food, as evidenced by the ongoing illness outbreaks linked to foods such as cantaloupes, leafy greens, and chicken. Pasteurized milk is not perfectly safe, either, and is implicated in foodborne illnesses and outbreaks every year. For instance, in 2007, there was an outbreak of Listeriosis in Massachusetts which was associated with pasteurized milk.  Overall, there were five cases identified and three deaths occurred.

Nonetheless, only raw milk and raw milk products are targeted by government agencies as being unsafe.

My Family’s Farm is Being Targeted

In the latest example of anti raw milk bias, the Food and Drug Administration (FDA) has recently targeted raw cheese from my family’s farm (RAW Farm). On February 15th 2024, the Centers for Disease Control (CDC) and the FDA urgently demanded to speak with us. We had 30 minutes notice for a call that was attended by about a dozen people from the CDC and FDA.

Our raw cheeses are sold nationally at over 1,300 grocery stores.  We were told that the CDC’s PULSENET database had associated 10 illnesses to our raw cheese products over the last 5 months. The CDC and FDA admitted that, out of these 10 illnesses, half of those who became ill denied ever having consumed our cheese.

Nonetheless, the FDA gave us two alternatives: either 1) voluntarily recall all of our cheese sold in the USA, or 2) they would force a mandatory recall of all our cheeses.

Our own internal tests performed on every batch of raw cheese were all negative for pathogens.  The state of California’s tests on our cheeses were also all negative for pathogens.  Nonetheless, we chose to fully comply with a voluntary recall of all raw cheeses within a specified date range. Although we needed a lot more information and answers to questions, out of an abundance of caution we recalled all of our cheeses on February 16th 2024. 

Searching for Answers to Many Questions

Over a 10-day period during our voluntary recall, we dug into the data to see what we could learn.  We were patient and did not comment, but instead we just collected information and considered every piece of data in our investigation.

We asked the FDA to provide the Whole Genome Sequencing (WGS) test data gathered by PULSENET. We conferred with experts from a testing lab who concluded that the WGS data was inconsistent from person to person and did not match as having a single cause. The CDC appears to have picked and selected data to match a narrative and ignored other data and date ranges. 

By February 25th, we had considered all the data from the FDA as well as mountains of internal test data and state test data. There was never any evidence that our cheese contained pathogens.

Clear Bias from the FDA and CDC

In handling this situation, the FDA broke their own rules in numerous ways.  They did not comply with their own Food Safety Modernization Act requirements or procedures. 

The timing of this whole situation was conspicuous considering that it was in the middle of a nationwide recall of pasteurized cheeses due to Listeria.  That outbreak is affecting 11-states and is associated with dozens of illnesses and two deaths. 

Additionally, on February 17th despite lack of evidence, FDA Director Dr Stic Harris posted on his personal LinkedIn page a photo of our cheese along with a warning that “While my personal opinion is you should never drink raw milk or eat raw milk products, you certainly don’t want to eat raw milk cheese linked to an ongoing outbreak.” Raw milk was never even involved in this recall, only raw cheese.  The bias against raw milk and raw milk products is clear.

The Accusations Were Baseless

It is clear from investigating all of the data that the FDA’s accusations against RAW Farm’s cheese were baseless. We stand with our consumers and our test data. The FDA can provide no evidence what so ever of any pathogens in any of our products.

As of February 26, we have now lifted our Voluntary Recall on our cheeses. You can read our full press release here:

Suffice it to say that as pioneers in the raw milk movement, we wage many battles.  Some are scientific, some are political, and some are educational. In this case, the FDA refuses to acknowledge science and is protecting themselves and big industry. They are demonstrating extreme political bias and continue to refuse to become educated about how raw milk can be produced as a low-risk food.

Welcoming Two Goat Milk Farms in Texas and British Columbia to RAWMI Community

The Raw Milk Institute (RAWMI) sends a warm welcome to two more farmers who have completed our Listing program!

RAWMI offers free mentoring to all dairy farmers. Whether they are milking one cow, a handful of goats, or a large herd, the principles of safe raw milk production form a foundational toolset that benefits all dairy farmers and their customers. 

Some of the farmers we mentor choose to keep it casual, and are satisfied to just ask us a few questions before continuing their raw milk journeys. There is another set of farmers, though, that is not content to just dip their toes in the water; they want to dive right in and take their entire milk process to the next level. 

For these farmers, we offer our (free) RAWMI Listing program, wherein we assist farmers in developing their own unique on-farm Risk Analysis and Management Plan, documenting their processes with written Standard Sanitary Operating Procedures, and identifying the Critical Control Points that are essential to their production of safe raw milk. RAWMI Listed farmers test their milk at least monthly for ongoing assurance that their processes are working well to produce low-risk raw milk. RAWMI Listing is the gold standard for raw milk producers.

Two goat milk farms have recently completed the RAWMI Listing process, and we extend them a warm welcome into our growing community!

Lomah Texas: Dallas-Fort Worth Area

Lomah Texas is operated by Jennifer Daniels and her family. It all started over a decade ago with a goat for Jennifer’s daughter.  Their herd quickly grew such that their farmstead was supplying goat cheese, yogurt, and bath-and-body products by 2010.  Finally, in 2021 the Texas state law was changed to allow raw milk sales off the farm. This created a realistic opportunity to sell and deliver raw goat milk and yogurt, and with that, “Lomah Texas” came to be what it is today.  

Jennifer’s farm produces delicious low-risk raw milk for her community with the use of intentional risk management practices and on-farm lab testing.  

You can check out Lomah Texas' Risk Management Plan and test results here: https://www.rawmilkinstitute.org/listed-farmers/#lomah

British Columbia Dairy: Canada

This is a functioning farm on a small patch of land. Several La Mancha goats live on the property along with a handful of chickens and ducks. Raw milk is illegal in Canada, so even though this farmer is achieving low-risk raw milk, she cannot publicly list her farm name or location.

This farm follows permaculture and regenerative agriculture practices, thereby allowing an abundance of blackberry bushes, grapevines, fruit trees, and vegetables. For this farmer, raw milk safety is more than peace of mind; it’s an innate desire to produce the best product for organic goat milk soap and delicious, nutritious milk and milk products.

This dairy is the second hand-milking farm that has been able to achieve RAWMI Listing. Hand-milking poses some extra risks because it is an open system, but this farmer has shown diligence and persistence in optimizing her processes to reduce the risks, as evidenced by her stellar milk testing results.  

You can check out this farm's Risk Management Plan and test results here:

https://www.rawmilkinstitute.org/listed-farmers/#BC3

Welcoming 6 Farms to RAWMI Community in Illinois, Iowa, Tennessee, Texas, and New York

The Raw Milk Institute (RAWMI) sends a warm welcome to six more farmers who have completed our Listing program! RAWMI offers free mentoring to all dairy farmers. Whether they are milking one cow, a handful of goats, or a large herd, the principles of safe raw milk production form a foundational toolset that benefits all dairy farmers and their customers. 

Some of the farmers we mentor choose to keep it casual, and are satisfied to just ask us a few questions before continuing their raw milk journeys. There is another set of farmers, though, that is not content to just dip their toes in the water; they want to dive right in and take their entire milk process to the next level. 

For these farmers, we offer our (free) RAWMI Listing program, wherein we assist farmers in developing their own unique on-farm Risk Analysis and Management Plan, documenting their processes with written Standard Sanitary Operating Procedures, and identifying the Critical Control Points that are essential to their production of safe raw milk. RAWMI Listed farmers test their milk at least monthly for ongoing assurance that their processes are working well to produce low-risk raw milk. RAWMI Listing is the gold standard for raw milk producers.

Six farms have recently completed the RAWMI Listing process, and we extend them a warm welcome into our growing community!

• ACM Grace Hill in Washington, Iowa

• Flowered Cow Dairy in Penfield, Illinois

• LanaRosa Dairy in Leicester, New York

• Shady Paddock Farm in Paige, Texas

• The Lucky Star in Iowa City, Iowa

• Whispering Willows Farm and Dairy in Thompson’s Station, Tennessee

ACM Grace Hill – Washington, Iowa

ACM Grace Hill is operated by Andy and Christy Meader in the historic Grace Hill community. Their home is the original Grace Hill store, mentioned in the book Iowa Outpost written by Katherine Buxbaum who grew up in the home.

Since 2006, the Meaders have used raw milk for their own family and found it helpful for many of their health concerns. They started out with a small hand-milked herd of goats, but have now moved into machine milking with cows. They believe in the importance of quality local nutrition and produce A2 raw milk from registered Guernsey cattle. They are proud to follow the RAWMI framework for producing the best quality raw milk products.

You can learn more about ACM Grace Hill here: https://www.rawmilkinstitute.org/listed-farmers/#acm

Flowered Cow Dairy – Penfield, Illinois

Flowered Cow Dairy is operated by Elizabeth Hesterberg on her family’s farm in Illinois. Elizabeth grew up on her family’s farm and originally started producing milk for her own family before growing her herd to provide milk for her community.  Elizabeth is very passionate about providing healthy, clean, low-risk raw milk for her community and bridging the gap between farm and consumer. Coliform and Standard Plate Count tests are run twice per week in the on-farm lab to ensure milk quality and safety.

Each of the Jersey cows in the milking herd at Flowered Cow Dairy is given a floral name to reflect the beauty, femininity, and individual personality of the cow. The small herd is rotationally grazed on pasture throughout the growing season and supplemented with a small ration of non-GMO grain at milking time.

You can learn more about Flowered Cow Dairy here: https://www.rawmilkinstitute.org/listed-farmers/#flowered

LanaRosa Dairy – Leicester, New York

LanaRosa Dairy is operated by Lana and Wayne Scofield on their 100-acre farm in New York. Wayne and Lana have a scrap metal recycling facility and Lana has transitioned to working full time on the farm. Lana originally sought raw milk to help with healing her health problems, and they decided to get a Jersey cow since there were no local sources for raw milk. Once their community saw the cow out in the pasture, people were clamoring for raw milk so their herd grew from there.

Lana and Wayne decided to take the step of becoming permitted by the New York Department of Ag and Markets in 2022 and just celebrated their first year in August 2023.  They are happy to share delicious Jersey milk with their community. They are a boutique dairy which only allows them to serve a limited number of consumers. 

You can learn more about LanaRosa Dairy here: https://www.rawmilkinstitute.org/listed-farmers/#lana

Shady Paddock Farm – Paige, Texas

Shady Paddock Farm is operated by Tammy and Dennis Gallagher on 13 beautiful acres in Central Texas. Tammy is a former Registered Nurse and Dennis is a retired Marine. After originally producing raw milk and cheese for their own family, Tammy and Dennis fell in love with Nigerian Dwarf goats and the farming way of life.

The Gallaghers believe that the very best food products come from healthy, happy, and stress-free animals. With this in mind, their animals are raised with a compassionate care philosophy. They are excited to share delicious and creamy goat milk provided with their community. 

You can learn more about Shady Paddock Farm here: https://www.rawmilkinstitute.org/listed-farmers/#shady

The Lucky Star Farm – Iowa City, Iowa

The Lucky Star Farm is operated by Susan Young on a 20-acre diverse homestead in Iowa. Susan is an educator and her family started their farm back in 2011.  Susan milks Nigerian dwarf goats and her customers appreciate the delicious sweet milk, high in protein and butterfat.

The goats are machine milked once-a-day and milk is tested weekly in the on-farm lab to ensure all milk is up to RAWMI standards. Susan is committed to producing the highest quality raw milk possible for her community and dedicated to sharing local food, education and farm experiences with others.

You can learn more about The Lucky Star Farm here: https://www.rawmilkinstitute.org/listed-farmers/#lucky

Whispering Willows Farm and Dairy – Thompson’s Station, Tennessee

Whispering Willows Farm and Dairy is operated by Jennifer and Brad Wilson in middle Tennessee. Brad was a management consultant and Jennifer was a PhD biophysics researcher prior to homeschooling and starting the farm.

Whispering Willows originally started out as a rabbit farm, but that soon grew to include chickens, goats, and cows. The Wilsons are passionate about providing nutritious foods for their community. They produce both cow and goat milk, as well as raw yogurt and a variety of hard and soft cheeses.

You can learn more about Whispering Willows Farm and Dairy here: https://www.rawmilkinstitute.org/listed-farmers/#willows