Low-Risk Raw Milk for Montana

The Raw Milk Institute and AERO have partnered for low-risk raw milk in Montana through farmer training and advocacy. 

Raw Milk Becomes Legal in Montana

After close to 50 years of raw milk prohibition, Montana passed the Local Food Choice Act (SB199) in 2021 as mostly a Food Freedom and Sovereignty act. Under SB199, small dairies in the state could legally produce and sell raw milk with practically no involvement from regulators. This was good news for farmers and consumers alike, who had repeatedly tried to change Montana’s raw milk laws to allow for legal access to this important nourishing food.  

A growing body of evidence shows that drinking raw milk is associated with decreased rates of asthma, allergies, eczema, ear infections, fever, and respiratory infections. Whereas, pasteurized milk is a top food allergen and difficult to digest, raw milk is actually a health-supporting food with rich therapeutic potential that is easily digested by most consumers, even many of those who are considered to be lactose intolerant.   

Raw Milk Institute Receives an Urgent Call from Montana

Unsanitary milking equipment at raw milk dairy in Montana

SB199 opened up new possibilities for raw milk farmers and consumers. However, SB199 essentially tied the hands of the state’s Department of Public Health and Human Services (DPHHS), who were not allowed to impose any standards for the production of raw milk. Soon after the passage of SB199, the Raw Milk Institute (RAWMI) received an urgent call from a dairy farmer in Montana whose raw milk was suspected to be the cause of an outbreak of campylobacter illness.   

In response, Mark McAfee, Chairman of RAWMI, traveled to Montana in Fall 2021 to assist the dairy and investigate the potential causes for the outbreak.  Mark quickly discovered that the farmer had substantial biofilm build up on milk machine systems and inadequate training in what it takes to produce low-risk raw milk.  While in Montana, Mark also met with AERO representatives to discuss SB199 and raw milk. AERO was working to ensure that Montana farmers had the resources they needed to successfully operate under the Local Food Choice Act. 

No Standards or Training = Potential Peril for Legality of Raw Milk in Montana

If poorly produced, foodborne illnesses are a real risk for raw milk, yet these risks can be mitigated through careful production practices. Ideally, the careful production practices are combined with periodic bacterial testing with the goal of achieving low coliform and Standard Plate Count bacteria test results (as published in the RAWMI Common Standards).   

Since Montana legalized raw milk but provided no standards or training for how to produce low-risk raw milk, the Fall 2021 campylobacter outbreak was unfortunately a predictable scenario. History has shown that repeated raw milk-related illness outbreaks will cause government agencies to ban raw milk outright or create difficult restrictions. In order to ensure both consumer safety and continued raw milk legalization, it was imperative that farmers in Montana gain access to training and resources for producing low-risk raw milk.  

With Freedom Comes Responsibility

With the freedom to produce raw milk comes the responsibility to make sure that raw milk is safe to drink.  Mark founded RAWMI in 2011, on a quest for safe raw milk that started after the raw milk from his own farm (Organic Pastures) was implicated in foodborne illnesses. As a former paramedic, Mark was committed to providing health-supporting foods for his customers, and those illness outbreaks were a huge wake-up call to learn more and do better. 

The Raw Milk Institute was founded in order to learn more and teach others the best ways to produce raw milk that would be both safe and nutritious. From 2011-2012, RAWMI worked to establish the Common Standards for safe raw milk by consulting with a diverse international group of medical doctors, epidemiologists, nutritional consultants, veterinarians, food safety scientists, raw milk farmers, and raw milk consumers.

Since that time, RAWMI’s Common Standards have influenced raw milk regulations in many states across the USA. The effectiveness of these standards has been demonstrated in two peer-reviewed research papers by researchers from Canada and Europe which have found that carefully produced raw milk is a low-risk food which is fundamentally different from pre-pasteurized milk. The implementation of the RAWMI Common Standards has led to a significant reduction in raw milk-related illnesses and outbreaks. RAWMI has trained hundreds of farmers in these methods, and the Common Standards have been voluntarily adopted by farmers in many states and countries around the world.  

Paving the Way for Low-Risk Raw Milk in Montana

In the wake of the campylobacter outbreak, AERO enthusiastically welcomed RAWMI to travel to Montana in order to train farmers in the production of low-risk raw milk. AERO even offered to cover the travel expenses for this work, through a grant from Western Extension Risk Management Education. 

The valuable partnership between RAWMI and AERO came to fruition in mid-September.  Mark McAfee and Sarah Smith (RAWMI Director and Board Secretary) traveled to Montana to teach two farmer training classes and meet with state regulators. Sam Blomquist from AERO did all of the on-site coordination by arranging the class locations and farm visits, taking registrations, and setting up meetings with regulators.  

Raw Milk Risk Management Training in Montana

On September 14th and 16th 2022, Mark and Sarah from RAWMI taught Raw Milk Risk Management training courses in Big Timber and Avon Montana to dozens of attendees. These training workshops focused on the benefits of raw milk, grass-to-glass identification of risks, development of a risk management plan, and lessons learned from other raw milk dairies. (For those who weren’t able to attend one of our Risk Management Classes in-person, there is an online version here.)

After a morning classroom portion, each training day ended with a visit to a nearby farm that produces raw milk. RAWMI extends a big thanks to Allison Cooley, from Hoof and Leaf Creamery in Big Timber, and Bobbi McIntosh, from McIntosh Ranch in Avon, for hosting the on-farm visits for the class attendees. Bobbi is the first Montana raw milk producer to have completed RAWMI’s (free) LISTING program. The on-farm visits gave the class attendees to opportunity to see risk management principles in action, including the use of on-farm labs for inexpensive bacterial testing of raw milk.

Feedback from the attendees of the training workshops included the following:

“It was excellent on EVERY topic. Thank you SO much.”

“I really learned a lot about the benefits of raw milk as well as a lot of great info on safe practices.”

“[We got] to talk about the whole process from 'grass to glass' and how important it all is.”

Bridging the Gap Between Regulators and Farmers

Given that SB199 does not allow the state health department to impose any standards for raw milk production, regulators are stuck between a rock and a hard place in wanting to ensure that raw milk will be safe for consumers in Montana.  

RAWMI and AERO met with state regulators at DPHHS to discuss ways to help Montana farmers have access to the information they need in order to produce low-risk raw milk.  Additionally, several local and state regulators attended the training classes in Montana in order to learn more with the mutual goal that raw milk will be safe and freely available for both farmers and consumers. 

Helping to Keep Raw Milk Legal and Safe in Montana

RAWMI has been pleased to partner with AERO for the good of raw milk farmers and consumers in Montana. Several farmers who attended the RAWMI training class have expressed interest RAWMI’s LISTING program and grants for farmers to build their own on-farm labs.  RAWMI extends a big thanks to AERO for sponsoring and coordinating this important step for safe, low-risk raw milk in Montana.

Join Us for Raw Milk Training in Montana

On September 14th and 16th 2022, the Raw Milk Institute (RAWMI) will be providing Raw Milk Risk Management training in Montana. This training is being coordinated and sponsored by the Alternative Energy Resources Organization (AERO) Montana.

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About the Training

Under the Montana Local Food Choice Act (SB199), raw milk production is now legal in Montana. RAWMI’s training workshops will focus on the 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 is our goal to assure that raw milk is safe and continues to be freely available for both farmers and consumers.

We'll be providing 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.

The trainings will be in Big Timber MT on September 14 and Avon MT on September 16. Each of these training workshops will include a 3-hour presentation followed by a on-site visit to a raw milk dairy.

There will be a lunch break between the morning presentations and the afternoon farm visits.

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FREE Registration

Thanks to AERO Montana, these RAWMI training days are FREE to attend and open to all. Whether you are from Montana or somewhere nearby such as Idaho or Wyoming, we welcome you to attend this training for low-risk raw milk!

Go here to register: https://aeromt.org/event/raw-milk-trainings/

Welcoming Milk House Farm and McIntosh Ranch to RAWMI

The Raw Milk Institute (RAWMI) sends a warm welcome to two more farmers who have joined 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 farms have recently completed the RAWMI Listing process, and we extend them a warm welcome into our growing community!

Milk House Farm – Herd Share in Corunna, Michigan

Maggie Kirkman is a city-girl-turned-farmer after hatching chicken eggs with her kids for a home school project. When Maggie found out that her HOA didn’t allow chickens, her family moved to the country.   The farm fresh eggs were so good that the Kirkman family decided to raise pigs, pastured poultry, beef, and finally a milk cow. Maggie saw the health of her family improve with every real food change they implemented.  So, when they moved to her husband's vacant family farm in Michigan, the animals went along, too.   

Milk House Farm is committed to providing safe, ethical, and nutrient dense foods for their family and community. Maggie milks 4 beautiful Jersey/Guernsey cows, who live their best life as they are rotationally grazed through pastures and enjoy farm-grown hay during the colder months. Maggie utilizes a RAWMI-sponsored on-farm lab to test her milk frequently and ensure that her milk is low-risk, safe, and delicious.

McIntosh Ranch – Farm Store and Delivery in Avon, Montana

Bobbi McIntosh was a nurse in the Air Force when she started studying nutrition and preventative medicine. Her love for nutrition and animals led her to start a micro dairy so she can share the health benefits of fresh raw milk with her family and community. Bobbi’s farm is the first dairy in Montana to become Listed by RAWMI.

Bobbi lives on the beautiful and historic 9000+ acre McIntosh Ranch. This ranch was established in 1892 on land that was originally granted as part of the Homestead Act of 1862. Nowadays, most of the ranch is used to raise beef cattle and Bobbi uses ~80 acres for her dairy cows.  Milk testing is a cornerstone of RAWMI’s risk management strategy for low-risk raw milk, and RAWMI sponsored an on-farm lab for Bobbi to allow her to test her milk frequently.

RAWMI Annual Report for 2021-2022

The Raw Milk Institute (RAWMI) is on a mission to improve the safety and quality of raw milk and raw milk products through farmer training, rigorous raw milk standards, raw milk research, and improving consumer education.

In 2021, RAWMI was awarded a 3rd grant for $50k from the Regenerative Agriculture Foundation (RAF) to further our work. RAWMI matches an economic benefit of stewardship of pastures and soils to high value raw dairy products for consumers. Safe raw milk from pastured cows can sustain the farm financially while the grazing improves the soils.

With the 3rd grant from RAF, RAWMI was able to accomplish much towards the overall goal of universal access to safe raw milk. With the unique continuing challenges of 2021, RAWMI was able to carry on with making progress through the latest methods and models for training and outreach.

Over the last year, RAWMI:

• Trained over 250 farmers, legislators, university professors, and consumers on raw milk benefits and risk management

• Prepared and presented a 1.5 hour training course for dairy farmers who are considering the switch to raw milk, for the Massachusetts Northeast Organic Farmers Association (NOFA-MASS)

• Developed 17-part Raw Milk Risk Management online video training series for raw milk farmers, which has been accessed by hundreds of additional farmers

• Worked with state and local regulators in Montana to develop a model for training raw milk farmers

• LISTED six new farms in Virginia, California, Michigan, British Columbia Canada, North Carolina, and Arkansas, who each went through the process of developing an individualized Risk Assessment and Management Plan (RAMP) for managing the health and hygiene of their unique farms

• Provided one-on-one mentoring in the production of low-risk raw milk to over 30 additional farms in California, Michigan, Virginia, Montana, Pennsylvania, Texas, Idaho, Vermont, Iowa, North Dakota, Washington, Oregon, New Zealand, Czech Republic, Ontario Canada, and British Columbia Canada

• Hosted quarterly meetings for LISTED farmers, which allow the farmers to stay up-to-date on the latest lessons learned for safe raw milk

• Performed an independent research study on pathogen growth in raw milk

• Amassed hundreds of raw milk test data from RAWMI LISTED farms 

• Attended and sponsored International Milk Genomics Consortium Conference

• Worked with researchers from Spectacular Labs who are developing on-farm technology for pathogen testing

• Worked towards legalization of interstate raw butter and increased legal access to raw milk in Iowa and Canada (with Canadian Artisan Dairy Alliance)

• Published 9 content pieces on the RAWMI website and developed new brochure on the Benefits of Raw Milk

• Developed on-farm lab training materials and provided on-farm lab sponsorships to 5 farms

Raw Milk Training

RAWMI taught about raw milk health benefits and safety throughout the United States via web-based training. Whenever RAWMI teaches about raw milk risk management, soil and conditions management are emphasized as key elements in creating healthy, sustainable farms.

Dairy animals grazing on pastures provide a critical link to the soil biome and restorative farm practices. Pasture-based dairy farms produce healthy soils that are rehabilitated and renewed through the cycle of returning organic carbon to the soil in the form of plants biomass and manure. The resulting food that is harvested by either the animals or the farmer is rich in nutritional elements needed for human health. 

Real-Time Training Courses

Via Zoom and podcast, raw milk and organic farming training was presented to over 250 farmers, legislators, university professors, university students, and consumers in association with the following:

• Massachusetts Northeast Organic Farmers Association (NOFA-Mass)

• Rutgers University

• Here’s to Your Health podcast with Josh Lane

On-Demand Training Course

RAWMI developed a 17-part video training series on Raw Milk Risk Management. This training series is now available for FREE on both the RAWMI website and Vimeo.  This video training has been accessed by hundreds of farmers.

Raw Milk Support in Montana

In Montana, raw milk was recently legalized with no regulatory oversight with the adoption of SB199.  This seeming victory for food freedom has the potential to go awry if raw dairy farmers are not properly trained in the production of low-risk raw milk. 

After an outbreak of Campylobacter was tied to one raw dairy farm in Montana, RAWMI was contacted and became heavily involved in helping the farmer learn best practices for raw milk production, install an on-farm lab for milk bacterial testing, and build better facilities for ongoing production of safe raw milk.

RAWMI is now collaborating with state and local regulators to develop a model for training Montana raw milk farmers in the production of low-risk raw milk. In partnership with Alternative Energy Resources Organization (AERO), RAWMI was awarded a small grant for $5k to cover travel costs for onsite training in Montana later in 2022. This training program will help in ensuring that the legalization of raw milk in Montana is a long-term success.  

Farmer Mentoring  

RAWMI worked with individual farmers across the United States, Canada, and internationally. RAWMI provided one-on-one mentoring and troubleshooting support for low-risk raw milk production, including helping farmers optimize their raw milk production, overcome problems in their milk systems and testing, and learn more about successful business practices.  This mentorship benefited farmers in:

• California

• Idaho

• Iowa

• Michigan

• Montana

• North Dakota

• Oregon

• Pennsylvania

• Texas

• Vermont

• Virginia

• Washington

• New Zealand

• Czech Republic

• British Columbia, Canada

• Ontario, Canada

RAWMI LISTED Farms

RAWMI LISTED farmers are dedicated to producing clean, safe raw milk. The RAWMI listing process involves the development of individualized Risk Assessment and Management Plans (RAMPs) for managing the health and hygiene of each unique farm. RAWMI LISTED farms submit test data monthly to show that they are in compliance with RAWMI Common Standards, which target a rolling three-month average of <5,000 standard plate count (SPC) and <10 coliforms per ml of raw milk.

In the last year, RAWMI LISTED six more farms, in Virginia, California, Michigan, British Columbia Canada, North Carolina, and Arkansas. To-date, RAWMI has LISTED 29 farms, and there are currently 22 active LISTED farms in the United States and Canada.

RAWMI provided continuing support to all LISTED farmers to enable sustained excellence in low-risk raw milk. This included quarterly meetings for LISTED farmers, which allow the farmers to stay up-to-date on the latest lessons learned for safe raw milk, exchange ideas for improvements, and collaborate with the RAWMI Board of directors.

Raw Milk Research and Science

RAWMI’s mission includes supporting raw milk research and science. Through this work, RAWMI helps raw milk become safer and more accepted by regulatory agencies.

Pathogen Growth Study

In order to generate a stronger scientific basis for assessments of risks of pathogen growth in raw milk, RAWMI commissioned a pilot study on pathogen growth performed by an independent 3rd party lab certified to perform pathogen testing, Food Safety Net Services (FSNS).  This pilot study was partially paid for through donations. 

In this pilot study, samples of well-produced raw milk were purposely inoculated at two levels with the four main pathogens of concern for raw milk: E coli 0157:H7, Salmonella spp., Campylobacter spp., and Listeria monocytogenes. The objective of this pilot study was to document growth characteristics of these pathogens in carefully produced raw milk over a period of 14 days when stored at the refrigeration temperature recommended by FDA and USDA.

The most relevant finding of the study was that at moderate Inoculum Level I, no pathogen growth was observed through at least 6 days of refrigerated storage. Over the study period of 14 days, the counts per mL of E coli 0157:H7, Salmonella spp., and Campylobacter spp. decreased over time. These results indicate that, when stored at the recommended refrigerator temperature, moderate to high counts of E coli 0157:H7, Salmonella spp., and Campylobacter spp. did not multiply over time in raw milk. Listeria monocytogenes exhibited some growth in this study after 9 days of refrigeration at both moderate- and high-level inoculum levels.

Raw Milk Bacterial Test Data

RAWMI LISTED farmers test their milk at least monthly for coliforms and Standard Plate Count (SPC). These tests provide a way to measure the amount of bacteria present in the milk, as well as providing a measure of the overall hygiene and cleanliness of the milk. Monthly testing serves as a useful confirmation step for ensuring that raw milk is being produced in a way that discourages pathogen growth and is therefore low-risk.

Test data from LISTED farms is submitted to RAWMI monthly. RAWMI amassed hundreds of test data from RAWMI LISTED farms over the last year.  This data can be used for raw milk research and demonstrates that low-risk raw milk is achievable on both small-scale and large-scale raw dairy farms.

International Milk Genomics Consortium

RAWMI was a sponsor of the 18th International Milk Genomics Consortium (IMGC) and attended the virtual IMGC conference. As part of that conference, RAWMI is now engaged with international research and relationships with PhD researchers across the world. The IMGC provides access to the most leading-edge studies on milk genomics.

An abstract about the pathogen growth pilot study is being prepared for presentation at the 19th IMGC conference later in 2022.

Development of On-Farm Pathogen Testing Technology

On-farm pathogen testing for raw milk has been considered too risky due to the potential for cross-contamination and inadvertent pathogen release.  However, researchers from Spectacular Labs are developing new technology for rapid on-farm pathogen testing. RAWMI collaborated with Spectacular Labs by providing a real-world farm environment where they could test their concept.

Raw Dairy Legalization and Support

RAWMI continued to collaborate with the Farm-to-Consumer Legal Defense Fund (FTCLDF) towards the legalization of raw butter. Raw butter is an exceptionally nutritious food. For instance, the enzyme alkaline phosphatase (ALP) is found in the butter fat membrane that covers fat globules. ALP decreases inflammation in the body; it is associated with good health and less chronic illness, such as cardiovascular disease and Type-2 diabetes. Raw milk has 4% butter fat, but raw butter contains 86% fat and thus it is very high in alkaline phosphatase.  ALP enzyme is destroyed by pasteurization. The case for legalization of raw butter is currently in Federal Appeals Court, and the next step is the US Supreme Court.

RAWMI worked towards legalization of raw milk in specific states and countries.  RAWMI provided support for lawmakers and farmers who were proposing a bill to legalize raw milk in Iowa.  Additionally, RAWMI collaborated with the Canadian Artisan Dairy Alliance, who is working towards legalization of raw milk in Canada.

RAWMI also created outreach materials for educating state agriculture departments about the benefits of raw milk for dairy farmers. RAWMI mailed letters to state agriculture departments all across the USA.

Raw Dairy Educational Outreach

RAWMI created educational materials and articles for raw milk consumers and the general public. Numerous articles were published to the RAWMI website and social media, with a wide array of topics including:

• Allergies and raw milk

• Profiles of 6 raw milk farmers across the USA and Canada

• “It’s Time to Go Raw” seminar for organic dairy farmers

• Pathogen growth in raw milk

• Importance of predictive microbiology for raw milk risk assessment

• Breastfeeding and peanut allergies

• Benefits of milk on osteoarthritis

• Raw milk and protection against eczema

• Nutritional benefits of raw milk

• How and why to make milk kefir

• Dairy foods and fall prevention in older adults

• Benefits of pasture-based farming

On-Farm Lab Training and Sponsorships

Frequent bacterial testing of raw milk is one of the pillars of producing low-risk raw milk. However, milk testing costs can be an ongoing financial burden which make small-scale farmers hesitant to test their milk often. On-farm testing is a great solution to this dilemma.

On-farm lab testing is a powerful tool for raw milk farmers.  It allows for frequent testing, so farmers can better identify issues before they turn into big problems, and it also helps immeasurably with troubleshooting when needed.  On-farm labs require an initial investment of $800-$1,000, but once the lab is in-place the cost per test is only $1-$3. With RAWMI’s sponsorship, five additional farms were able to build their own on-farm labs for testing coliforms and Standard Plate Count.

RAWMI also created educational materials about on-farm labs, including materials lists, how-to guides, and methods for using different brands of testing media.

Welcoming Kelsey Barefoot to the RAWMI Board of Directors

The Raw Milk Institute (RAWMI) sends a warm welcome to Kelsey Barefoot, who has now joined our Board of Directors!  

Kelsey is a former Critical Care Nurse who quit her nursing job to pursue her passion for a healthier life for herself, her family, and her community. Kelsey has been an Admin Assistant for RAWMI for a year, helping with raw milk data collection, answering inquiries from our website, and mentoring farmers who are working on becoming Listed by RAWMI.  Kelsey is a natural fit to join the RAWMI Board of Directors and she brings an additional farmer’s perspective to the table.

At Kelsey’s own micro-dairy herdshare, The Barefoot Cow, she tests her milk frequently in her on-farm lab. Kelsey’s farm became Listed by RAWMI last Fall, and her experience has been a great asset in assisting other farmers who are pursuing the production of low-risk raw milk. Kelsey’s farm is an extension of the generational family farm, as she was mentored by her parents at Jewel Hill Farms, another RAWMI Listed farm.

Congratulations to Kelsey in joining our Board of Directors!

On-Farm Lab Testing for Raw Milk Farmers

On-farm labs are a valuable and economical tool for raw dairy farmers

The three pillars of the Raw Milk Institute’s (RAWMI) Method for safe, low-risk raw milk are 1) farmer mentoring, 2) risk management plan for each farm, and 3) regular bacterial testing of raw milk.  This method works well and has been documented to lead to a significant reduction in raw milk-related illnesses and outbreaks. Researchers who have studied the safety of raw milk produced with the RAWMI Method have concluded that “raw milk can be produced with a high level of hygiene and safety.”

RAWMI’s farmer mentoring program and assistance in developing an individualized risk management plan are free for all farmers. However, milk testing costs can be an ongoing financial burden which make small-scale farmers hesitant to test their milk often. But there is a great solution to this: on-farm testing!

What is an On-Farm Lab?

Pioneered by Edwin Shank from The Family Cow dairy in Pennsylvania, on-farm labs are a tremendous resource for dairy farmers. On-farm labs can be set-up on the countertop in a small, clean workspace. Once the lab area is ready, farmers can easily test their milk for coliforms and Standard Plate Count with the use of a small incubator. 

Set-up costs for on-farm labs are in the range of $800-$1,000.  RAWMI is currently offering grants of up to $500 to offset lab costs for farmers who are Listed or going through our Listing program. After the initial set-up costs, raw milk testing costs are only $1-$3 for each test performed in the on-farm lab.

Benefits of On-Farm Labs

On-farm labs have numerous benefits for raw milk farmers. As Mark McAfee says, “What gets measured gets done.”  Ignorance is not bliss when it comes to raw milk. Testing allows farmers to dependably produce low-risk raw milk with confidence.

With on-farm labs:

• Farmers can test their milk for coliforms and Standard Plate Count.

• Ongoing testing costs are only $1-$3 per test.

• Farmers can inexpensively test their milk as often as desired, so they can identify patterns in their bacterial counts which help in identifying trouble spots ahead of time.

• The effects of new equipment or procedures on bacterial levels can be evaluated.

• Farmers can test more often as needed for troubleshooting high bacteria counts.

• Annual water tests can also be performed.

The bacterial tests performed in an on-farm lab (coliform and Standard Plate Count) are used to provide a general indicator that the milk is being produced in a way that is unlikely to lead to pathogens and pathogen growth.  The RAWMI Common Standards aim for a rolling three-month average of <5,000 cfu/mL for SPC and <10 cfu/mL for coliforms.

NOTE: RAWMI does not recommend on-farm testing for specific pathogens (such as e coli 0157:H7, salmonella, listeria mono, etc), due to potential hazards from accidental release of pathogens on the farm.

Two Different Systems for On-Farm Testing

There are currently two different systems for performing on-farm testing, developed by 3M and Charm Sciences.  Both of these systems work well for on-farm raw milk testing, and the basic lab equipment (incubator, lightbox, magnifier, etc) are the same with either system.

3M’s testing system uses petri-films and provides results in 24 hours.  Unopened packages of 3M petrifilms are stored in the refrigerator or freezer for up to 18 months, with opened packages being stored at room temperature for up to one month.

Charm Sciences testing system uses peel-plates and provides results in 24-48 hours.  The peel plates can be stored at room temperature for up to 12 months. Testing costs are currently a bit lower with Charm Sciences peel-plates than with 3M petrifilms. 

How to Do On-Farm Bacterial Testing for Raw Milk

Here are several free resources for farmers who are interested in doing on-farm milk testing.

RAWMI VIDEO: How to Test Raw Milk with Charm Sciences Peel Plates

On-Farm Lab Testing: A Guide to Raw Milk Bacteria Testing from Six S Dairy

Comprehensive 20-page guide to on-farm testing with 3M Petri-Films, including materials list, procedures, results interpretation, and tips for success

Charm Sciences Peel Plate User Guide from The Barefoot Cow Dairy

5-page materials list and procedures for performing on-farm testing with Charm Sciences peel plates

Raw Milk Lab Materials List from The Family Cow Dairy

Short 1-page list of materials required for performing on-farm testing with 3M Petri-Films

Raw Milk Lab Procedures from The Family Cow Dairy

Short 2-page list of procedures for on-farm lab testing with 3M Petri-Films

Other Helpful Resources

• 3M coliform interpretation guide

• 3M SPC interpretation guide

• VIDEO: 3M PetriFilms

• VIDEO: Charm Sciences Peel Plates

• VIDEO: 3M Petrifilms vs Charm Sciences Peel Plate side-by-side demo

Why is Predictive Microbiology Crucial to Raw Milk Risk Assessment?

Earlier this month, readers of the feature article written by Sarah Smith, my colleague at the Raw Milk Institute (RAWMI), learned about pathogen growth in raw milk. RAWMI contracted with an independent laboratory to conduct a pilot study with an experimental design based on published studies on Predictive Microbiology, the science supporting models of the growth and survival of microbes under different experimental conditions. This article provides readers with more information about what Predictive Microbiology is and why it is important to dairy farmers and raw milk consumers in the 21st century.

Why is Predictive Microbiology important to dairy farmers and raw milk consumers?

Awareness of Predictive Microbiology is important because pathogen growth is modeled in the Exposure Assessment portion of Microbial Risk Assessments (MRAs; FDA/FSIS, 2003; FSANZ, 2009), and the models selected often intentionally overestimate pathogen growth by design, as ‘fail-safe’ models (Tamplin et al., 2002; Coleman et al., 2003a,b; Ross et al., 2003; Coleman, 2021). In other words, regulators rely on predictive microbiology models in estimating the level of risk, and the models that have been available thus far typically intentionally overestimate the risk of pathogen growth. 

The advantage for risk managers and regulators in selecting policies based on ‘fail-safe’ models that overestimate growth is the appearance of minimizing public health breaches or ‘failures’ (e.g., illnesses or outbreaks) if anything goes wrong along the food safety chain from production to consumption. The disadvantage for dairy farmers and raw milk consumers is that the growth models applied for raw milk MRAs are wrong, based on intentionally biased experiments that overestimate actual pathogen growth in raw foods and thus overestimate risk of illness to consumers.

For a quick overview of MRA, see the text box and figure in the forthcoming May 2022 article entitled Raw Milk Risks from a Microbiologist’s Perspective that I prepared for Weston A. Price Foundation’s Wise Traditions journal.

Science of Predictive Microbiology

Microbiologists including those at the USDA’s Agricultural Research Service in Wyndmoor, PA, began designing ‘factorial’ experiments for modeling pathogen growth in the 1990s, selecting rich nutrient culture broths amenable to testing a wide variety of levels of different ‘factors’ that influence microbial growth. The study designs were inexpensive and accurate, compared to more expensive and more complex analysis for different foods. The data from these experiments are generally well validated experimentally: that is, for growth in pure culture broths.

Such data formed the basis of free online tools for predicting growth, including the USDA’s Pathogen Modeling Program (PMP). The experiments were designed to include multiple levels of different factors including pH and salt or water activity that are similar to levels that can be measured in foods. The advantages of such tools based on broth culture experiments for government and academic risk assessors are that they might extrapolate the broth culture growth models to foods with similar levels of factors measured, and assume the models are still accurate. This could be beneficial because conducting pathogen growth studies in foods under diverse conditions of temperature and storage is expensive and time consuming.

Screenshot from USDA PMP

Now, with access to PMP, the risk assessor can select the inputs from those tested in multiple factor broth culture experiments from the sliders illustrated in the screen shot from PMP on the left. I illustrated a growth scenario with an appropriate refrigeration temperature (5°C or 41°F, from a range of 5-42°C or 41-107.6°F) and a pH (6.5, from a range of 4.5-8.5) relevant to raw milk.

The first problem for dairy farmers and raw milk consumers is that models based on optimal growth of pathogens in pure cultures described by rich broth culture models overestimate actual pathogen growth in raw milk. As early as 1997, university researchers published experimental results reporting that the rate of growth of the pathogen E. coli O157:H7 was significantly slower in raw milk than pasteurized (Wang et al., 1997). The authors noted that the difference in growth rates was likely due to the natural microbes in raw milk that outcompete pathogens and limit their growth in raw, not pasteurized, milk.

Another problem for farmers and consumers is that the broth culture study designs are typically biased by inclusion of only high initial pathogen levels (> 3 log10 colony forming units (CFU) per mL or >1,000 CFU/mL, from a range of 3 to 5.9 log10 CFU/mL).  Even in rich culture broth, growth rates are lower at low inoculum levels (~1 CFU/mL; Coleman et al., 2003). Biased growth models (based on rich nutrient broth, high initial inoculum, and/or absence of natural milk microbiota) result in biased MRAs that overestimate raw milk risks.

You may not be surprised to learn that some microbial risk assessment teams, including the Food Standards Australia New Zealand team (FSANZ, 2009), selected rich culture broth studies (Salter et al., 1998; Ross et al., 2003) that measured growth of harmless or commensal E. coli strains that are part of our healthy gut microbiota, not even pathogenic strains like O157:H7 that can cause illness and grow at slower rates. FSANZ excluded an available study on growth of the pathogen E. coli O157:H7 itself in raw and pasteurized milk reported by Wang and esteemed food scientist Mike Doyle at the University of Georgia (Wang et al., 1997).

Why do you think the FSANZ team decided not to cite Mike Doyle’s study, a study they should have known about? Likely because it measured lower pathogen growth rates in raw milk than in pasteurized milk (and broth). Thus, it seems that FSANZ likely excluded the study because the results did not support their notion that raw milk is inherently dangerous, and more dangerous than pasteurized milk. A short plain language summary prepared by the Australian Raw Milk Movement (ARMM) and the full 73-page technical report that I prepared for them (Coleman, 2021) are both available on the ARMM website. See the technical report for the more detailed section on pathogen growth and microbial ecology (pp. 30-40 of the 73-page report).

Why is Inoculum Level Important to Predict Growth in Raw Milk?

Well-produced raw milk has relatively low levels of coliform and aerobic bacteria. Farmers who follow RAWMI’s Common Standards for raw milk aim for coliform counts of <10 CFU/mL and Standard Plate Counts of <5,000 CFU/mL. However, don’t let these low coliform counts or low Standard Plate Counts in raw milk fool you.

Raw mammalian milks are complex ecosystems with dense and diverse microbes that benefit health. The natural microbes in raw milks have different requirements for culturing them, so studies that rely on specific culture media for assessing what microbes are present in raw milk are biased. The development of genomic methods that estimate presence of microbial genes or gene products in raw milks without culturing are more reliable for describing the raw milk microbes or microbiota (Oikonomou et al, 2020). Such studies are transforming our understanding of the microbiota of many natural systems in the recent decade, including raw mammalian milks.

The dense and diverse microbiota predominant in raw milk from healthy mammals is illustrated in the figure below by Oikonomou and colleagues (2020; authors’ Figure 2, pg. 4 of 15). The bacteria listed in red text were identified in the milk microbiota from all five types of mammals, bacteria in yellow from 3 or more mammals, and bacteria in blue in less than three mammals. None of these bacteria were identified as pathogens, but rather are natural microbes that appear to benefit human and animal offspring (and adult humans) by ‘seeding and feeding’ the gut. In other words, raw milk ‘seeds’ the gut with beneficial microbes and ‘feeds’ gut and microbial cells with nutrients. The raw milk microbiota also stimulates proper maturation and function of immune, neural, and respiratory systems (Coleman et al., 2021a,b; Dietert et al., 2022).

Oikonomou, et al., “Milk microbiota: what are we exactly talking about?” Frontiers in Microbiology

Predominant beneficial microbes including Pseudomonas, Staphylococcus, and certain lactic acid bacteria or LABs (including not just the familiar Lactobacillus, but also 11 other microbes: Lactococcus, Enterococcus, Streptococcus, Carnobacterium, Vagococcus, Leuconostoc, Oenococcus, Pediococcus, Tetragonococcus, Aerococcus and Weissella) are known to outcompete specific pathogens at refrigeration temperatures (Coleman et al., 2003a; Reuben et al., 2020).

A recent study in the Journal of Dairy Science (Reuben et al., 2020) illustrates the importance of incorporating data on the microbiota and microbial ecology of raw milks into Predictive Microbiology models and MRAs.  The authors demonstrated not merely suppression of growth of all pathogens tested (E. coli O157:H7, L. monocytogenes, and Salmonella) by LAB strains isolated from raw cow milk, but also ‘competitive exclusion’ of these pathogens inoculated at both 103 and 106 log10 CFU/mL. Clearly, the natural milk microbiota influences growth of pathogens.

In summary, the raw milk ecosystem differs greatly from sterile nutrient broth. If an MRA relies on pathogen growth models based on broth cultures, be skeptical of its value for predicting pathogen growth in raw milk. Pathogen growth rates in raw milk are likely lower due to suppression or exclusion of pathogens by the natural raw milk microbiota and compounds produced by these beneficial microbes.

How do Microbes in Raw Milk Outcompete and Exclude Pathogens?

The peer-reviewed literature is expanding as researchers document the mechanisms or pathways by which the raw milk microbes benefit health. Microbes in raw milk produce vitamins and enzymes that enhance gut health. Microbes also produce antimicrobial compounds including proteins (bacteriocins) and organic acids like lactic acid that reduce pH and indirectly suppress pathogen growth, modulate the immune system, and reduce inflammation. 

The natural raw milk microbiota also enhances gut mucosal barrier function, and competes with pathogens in the gut nutritionally and spatially (colonizing potential bacterial binding sites, enhancing ‘colonization resistance’ to pathogens, and reducing pathogen infection rates). Consider recent evidence for benefits and risks for the breastmilk microbiota (Coleman et al., 2021a,b) and the cow milk microbiota (Dietert et al., 2022). A large body of evidence also exists that documents mechanisms of interference of LABs with pathogens, including pathogen virulence expression.

Want More Perspectives from a Microbiologist and Risk Assessor?

Feel free to contact me for more information at peg@colemanscientific.org.

Key References Cited

1. Coleman, M. E., Sandberg, S., & Anderson, S. A. (2003a). Impact of microbial ecology of meat and poultry products on predictions from exposure assessment scenarios for refrigerated storage. Risk Analysis: An International Journal, 23(1), 215-228.

2. Coleman, M. E., Tamplin, M. L., Phillips, J. G., & Marmer, B. S. (2003b). Influence of agitation, inoculum density, pH, and strain on the growth parameters of Escherichia coli O157: H7—relevance to risk assessment. International Journal of Food Microbiology, 83(2), 147-160.

3. Dietert, R. R., Coleman, M. E., North, D. W., & Stephenson, M. M. (2022). Nourishing the Human Holobiont to Reduce the Risk of Non-Communicable Diseases: A Cow’s Milk Evidence Map Example. Applied Microbiology, 2(1), 25-52.

4. Food Standards Australia New Zealand (FSANZ). (2009). Microbiological Risk Assessment of Raw Cow Milk. Available at: https://www.foodstandards.gov.au/code/proposals/documents/-p1007%20ppps%20for%20raw%20milk%201ar%20sd1%20cow%20milk%20risk%20assessment.pdf.

5. Oikonomou, G., Addis, M. F., Chassard, C., Nader-Macias, M. E. F., Grant, I., Delbès, C., ... & Even, S. (2020). Milk microbiota: what are we exactly talking about? Frontiers in Microbiology, 11, 60.

6. Ross, T., Ratkowsky, D. A., Mellefont, L. A., & McMeekin, T. A. (2003). Modelling the effects of temperature, water activity, pH and lactic acid concentration on the growth rate of Escherichia coli. International Journal of Food Microbiology, 82(1), 33-43.

7. Reuben, R. C., Roy, P. C., Sarkar, S. L., Alam, A. R. U., & Jahid, I. K. (2020). Characterization and evaluation of lactic acid bacteria from indigenous raw milk for potential probiotic properties. Journal of Dairy Science, 103(2), 1223-1237.

8. Salter, M. A., Ross, T., & McMeekin, T. A. (1998). Applicability of a model for non-pathogenic Escherichia coli for predicting the growth of pathogenic Escherichia coli. Journal of Applied Microbiology, 85(2), 357-364.

9. Tamplin, M. L. (2002). Growth of Escherichia coli O157: H7 in raw ground beef stored at 10 C and the influence of competitive bacterial flora, strain variation, and fat level. Journal of Food Protection, 65(10), 1535-1540.

10. Wang, G., Zhao, T., & Doyle, M. P. (1997). Survival and growth of Escherichia coli O157: H7 in unpasteurized and pasteurized milk. Journal of Food Protection, 60(6), 610-613.

How Well Do Pathogens Grow In Raw Milk?

Low Risk of Pathogens in Intentionally-Produced Raw Milk

Despite raw milk’s association with decreased rates of asthma, allergies, eczema, ear infections, fever, and respiratory infections, government agencies in countries such as the USA, Canada, and Australia are still biased against raw milk. These Government agencies warn against raw milk consumption and, in some places, they even impose an outright ban on raw milk with potential heavy penalties and imprisonment for raw milk farmers.

The rationale that these Government agencies cite against raw milk is their belief that raw milk consumption leads to high rates of foodborne outbreaks, illnesses and deaths.  However, this belief is outdated and conflicts with the most up-to-date peer-reviewed research which has 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. carefully-produced 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 from bulk tanks or milk silos that the risk profile of pre-pasteurized milk is categorically different from raw milk intended for direct human consumption.

Data courtesy British Columbia Herdshare Association

Pathogen Loads and Illness

Carefully-produced raw milk has a low-risk of containing pathogens, but there is no such thing as a perfectly safe food. A CDC 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. 

In the very rare case that a pathogen could be present in carefully-produced raw milk, in order for a pathogen to cause illness four variables must align:

• A pathogen must be present

• The pathogen must be virulent and capable of producing harmful effects

• The pathogen load must be high enough to produce illness

• The person must be susceptible to the pathogen

If it is present in a small enough quantity, even the most virulent pathogen will not produce illness.  The presence of a single virulent bacterium is not sufficient to cause illness, and different pathogens have varying thresholds at which they must be present to induce human illness. 

For instance, even though Listeria monocytogenes is a known foodborne pathogen, the European Union allows Listeria up to 100 bacteria/gram in foods that do not permit growth because it is known that Listeria in lesser amounts is not sufficient to cause illness.

Some of the data cited by Government agencies against raw milk includes pathogen growth studies where it was found that pathogens multiply greatly over time.  However, these studies are not actually applicable to carefully-produced raw milk because they were performed in nutrient-rich broth instead of milk, they used tremendously high amounts of pathogens (such as 10 log 7, which corresponds to ten million pathogenic colony-forming units (CFU) of bacteria per mL), or they did not account for cold temperature storage.

Need for a NEW Pilot Study on Pathogen Growth for Raw Milk

In order to generate a stronger scientific basis for assessments of risks of pathogen growth in raw milk, the Raw Milk Institute (RAWMI) recently commissioned a pilot study on pathogen growth performed by an independent 3rd party lab certified to perform pathogen testing, Food Safety Net Services (FSNS).  RAWMI Advisory Board member Peg Coleman provided technical input on the study design based on predictive microbiology (Coleman et al., 2003a) and risk assessment (Coleman et al., 2003b) studies that she had conducted at the University of Maryland Eastern Shore and published through the USDA Agricultural Research Service. The new pilot study was partially paid for through donations.   

In this new pilot study, samples of well-produced raw milk were purposely inoculated with the four main pathogens of concern for raw milk: E coli 0157:H7, Salmonella spp., Campylobacter spp., and Listeria monocytogenes. Raw milk was inoculated at two levels (high and moderate counts per mL). The objective of this new pilot study was to document growth characteristics of these pathogens in carefully produced raw milk over a period of 14 days when stored at the refrigeration temperature recommended by FDA and USDA: 40°F (4.4 °C). The number of pathogenic bacteria present in the raw milk were counted on days 0, 3, 6, 9, 12, and 14.

Highlights of NEW Pilot Study Design

• The temperature for this study was chosen because 40°F (4.4°C) is the recommended maximum temperature for a home refrigerator.

• Inoculum Level I: target <10 CFU/mL. Although the study design called for inoculation with <10 CFU/mL, the actual amounts used in the study were measured in the range of 22-162 CFU/mL, thus a moderate level inoculum.

• Inoculum Level II: target 1,000 CFU/mL. Although the study design called for inoculation with 1,000 CFU/mL, the actual amounts used in the study were measured in the range of 600-8,300 CFU/mL.

Results of the NEW Pilot Study

The tables below show the results of the study at Inoculum Levels I and II.

Table of Results from Inoculum Level I, from FSNS Report, Determination of Growth Rate of Salmonella enterica spp., E. coli O157:H7, Campylobacter spp., and Listeria monocytogenes in Raw Milk

Table of Results from Inoculum Level II, from FSNS Report, Determination of Growth Rate of Salmonella enterica spp., E. coli O157:H7, Campylobacter spp., and Listeria monocytogenes in Raw Milk

The most relevant finding of the study is that at moderate Inoculum Level I, no pathogen growth is observed through at least 6 days of refrigerated storage. The very high Inoculum Level II results are less important to risk assessors since these levels of pathogens are not observed in naturally contaminated raw milk.

Over the study period of 14 days, the counts per mL of E coli 0157:H7, Salmonella spp., and Campylobacter spp. decreased over time. These results indicate that, when stored at the recommended refrigerator temperature, moderate to high counts of E coli 0157:H7, Salmonella spp., and Campylobacter spp. did not multiply over time in raw milk. Listeria monocytogenes exhibited some growth in this study after 9 days of refrigeration at both moderate and high level inoculum levels.

Click the button below to download the full report from FSNS, Determination of Growth Rate of Salmonella enterica spp., E. coli O157:H7, Campylobacter spp., and Listeria monocytogenes in Raw Milk.

Further Research

This study was designed as a small pilot study, and further research is needed to draw more-robust conclusions. Analysis of the NEW pilot study data are in preparation for submittal to a peer reviewed journal. Peg Coleman will also be providing a more detailed analysis of the study.

The new pilot study and the publication are intended to support a grant proposal to fund a full study that includes multiple producers of raw, lightly pasteurized, and typical pasteurized milks, with daily sampling after low and high inoculum levels. Nonetheless, the results of this NEW pilot study serve to provide an initial basis for challenging incorrect assumptions of the past that overestimated the growth of pathogens in clean, cold raw milk produced for direct human consumption by careful, trained producers.

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It's Time to Go Raw! Online Seminar for Organic Dairy Farmers

Farmers have been denied fair markets for their dairy products for more than a century. Recently, dozens of farmers have recently lost their organic milk contracts and are looking for a sustainable alternative. Raw milk presents a unique opportunity for farmers to move into an expanding market.

On Saturday January 15th 2022 at 4pm Eastern/1pm Pacific, the Raw Milk Institute (RAWMI) will be presenting a 1.5-hour It’s Time to Go Raw seminar. This presentation will be livestreamed online, so that means you could attend from your own location. The presentation will be part of the 2022 Northeast Organic Farming Association Massachusetts (NOFA Mass) Winter Conference.

Raw milk presents a unique farmstead product that brings all the added value back to the farmer with an incentive to work on quality. By selling directly to consumers, raw milk farmers are able to obtain greater financial rewards for their work, while consumers benefit from the improved flavor and nutrition. It’s a win for both farmers and consumers!

About the Training

This RAWMI presentation will focus on:

• Why raw milk farms are thriving

• Health benefits of raw milk

• Legality of raw milk

• Benefits of selling raw milk

• Safety and risks of raw milk

• Raw milk risk management

• Building a successful raw milk market

We'll be providing lots of practical tips for farmers who are interested in switching to raw milk as a sustainable business model.

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