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

Bird Flu and Raw Milk: Where is the Evidence?

We are pleased to share with you this balanced analysis of the risks of H5N1 bird flu from raw milk, from medical microbiologist Peg Coleman. Peg serves on the Advisory Board for Raw Milk Institute and she will be presenting a free webinar about Milkborne Risk Analysis (including a discussion of H5N1 avian influenza and raw milk) on Thursday May 9 at 11am Pacific / 2pm ET.

Recent risk communications from CDC , FDA, and USDA regarding transmission of influenza A sub-type H5N1 (highly pathogenic avian influenza virus or HPAI) to humans via raw milk include no supporting evidence of viral transmission from raw milk to humans in the peer-reviewed literature. CDC and USDA reported that the HPAI strains recently isolated in the US lack the genetic markers for viruses adapted to infect humans. An extensive body of scientific evidence from the peer-reviewed literature introduced herein does not support the assumption by these US government agencies that HPAI transmits to humans via milkborne or foodborne routes and causes disease. Nor does the scientific evidence support the recommendation that consumers should avoid raw milk and raw milk products.

One Detected Case: Worker Contact with BOTH Dead Birds and Affected Cows?

In March of 2024, dead wild birds on a TX dairy farm and unusual symptoms in older dairy cows (decreased lactation, low appetite, other clinical signs) triggered sampling of affected cows (oropharyngaeal swabs) and their milk. On March 25th, Texas Animal Health Commission confirmed samples were positive for HPAI. A dairy worker on this farm with eye inflammation was also confirmed positive for HPAI, though it is unclear if the worker had contact with both the dead birds and the affected cows. Similarly, it is unclear if dead cats on affected dairy farms were infected by contact with dead birds, milk, or other sources of viral contamination. 

On April 9th, the World Health Organization (WHO) stated the following about the TX case. “This is the first human infection with [HPAI (H5N1)] acquired from contact with infected cattle and the second confirmed human case of influenza A(H5N1) detected in the country. No additional associated cases of human infection with influenza A(H5N1) have been identified. Since the virus has not acquired mutations that facilitate transmission among humans and based on available information, WHO assesses the public health risk to the general population posed by this virus to be low and for occupationally exposed persons, the risk of infection is considered low-to-moderate.” In addition, the American Association of Bovine Practitioners (AABP) now recommends a new name, Bovine Influenza A Virus (BIAV) because the virus is not highly pathogenic in dairy cows.

The WHO lists the following factual information about avian influenza: i) “Direct contact with infected animals (through handling, culling, slaughtering or processing) or indirect contact (through environments contaminated with bodily fluids from infected animals) represent a risk for human infection.“; ii) “animal influenza viruses are distinct from human influenza viruses and do not easily transmit to and among humans;” and iii) sustained person-to-person transmission is not demonstrated.

Animal Contact is the Only Demonstrated Transmission Source

Of all the transmission sources reported in surveillance systems by CDC and other government agencies (animal contact, environmental, foodborne, person-to-person, and waterborne), the only demonstrated transmission source for HPAI transmission to humans is animal contact. In light of the body of evidence on HPAI transmission to humans by direct animal contact, not by foodborne transmission, risk communications to avoid consumption of raw milk and raw milk products do not appear to be based on scientific evidence, but on other factors.

An earlier risk assessment conducted by FDA and USDA (2010) determined that HPAI “is not considered to be a foodborne pathogen although virus had been isolated from poultry muscle and the interior of eggs”. This is consistent with current facts compiled by the WHO about avian influenza transmission to date: i) “Direct contact with infected animals (through handling, culling, slaughtering or processing) or indirect contact (through environments contaminated with bodily fluids from infected animals) represent a risk for human infection.“; ii) “animal influenza viruses are distinct from human influenza viruses and do not easily transmit to and among humans;” and iii) “sustained person-to-person transmission is not demonstrated”. Although HPAI was detected in milk from ill cows in TX, as in poultry muscle and eggs, no evidence supports foodborne transmission of HPAI to humans.

Antiviral Properties of Raw Milk

While no evidence supports milkborne or foodborne transmission of HPAI to humans, evidence does exist that demonstrates a multitude of well-characterized mechanistic factors that inactivate viruses and prevent foodborne illness. Key studies in the peer-reviewed literature are cited in brackets, with full references appended.

First, consider peer-reviewed studies demonstrating antiviral properties of a suite of bioactive components of raw mammalian milks, including bovine milk [4,5,7-9,12-14,16,17,19]. Multiple researchers note that some of the antiviral components of milk are likely function synergistically, meaning effects are greater in combination than independently, an observation particularly relevant in complex gut ecosystems of humans that include innate and adaptive immune systems. Many of these bioactive components of raw milk are also sensitive to heat and may be absent, inactive, or present in lower concentrations in pasteurized milks. Considering the extensive literature on antiviral activity in milk, clinical researchers [3] applied deep scientific knowledge to recommend that infants not be deprived of raw breastmilk due to the presence of viruses. The benefits of feeding raw breastmilk including its antiviral components to infants outweighs the very small risk of infection, from their perspective as clinical researchers, one associated with the Italian Association of Human Milk Banks.

Defense Against Pathogens in the Human Digestive Tract

Next, consider the gauntlet of defenses against foodborne pathogens in the human digestive tract [1,6,18]. These defenses include physical (stomach acidity, peristalsis), chemical (digestive enzymes), and cellular (innate and adaptive immune system, microbiota) factors that, acting simultaneously or sequentially, inactivate pathogens, including viruses, and/or suppress infectivity and virulence of ingested pathogens. Researchers [11] note that HPAI is an enveloped virus, susceptible to disruption and degradation in stomach acids, unlike the 16 viruses known to be transmitted to human by the oral route [6]. Further, FDA and USDA determined in 2010 that HPAI “is not considered to be a foodborne pathogen” even though virus was isolated from poultry muscle and the interior of eggs.

Host chemical and cellular defenses include:  complement; defensins; enzymes; interferons; interleukins; pattern recognition receptors (Toll-like receptors 3, 4, and 7; NOD-like receptors; RIG-1 receptors); and an array of host cells (dendritic cells, B cells, intestinal epithelial cells, macrophages, monocytes, natural killer cells, T cells) and cells of the gut-associated microbes or microbiota. Also, the gut microbiota include not only commensal (non-pathogenic) bacteria, but also commensal viruses that can modulate infectivity and virulence of pathogens [10].

CDC Data on Transmission Sources

Now, consider that the microbial ecology of raw milks including antiviral activity as described briefly above aligns with recent CDC data for all transmission sources from 2005 to 2020 [15]. This CDC dataset included 3,807 milkborne illnesses (2,111 associated with pasteurized milk) linked to bacterial pathogens, but lacks any viral illness associated with milk, raw or pasteurized. The predominant virus in this CDC dataset was norovirus, associated with 8,199 illnesses from leafy greens reported over this 16-year period. No norovirus illnesses or any other viral illnesses were reported in milk.

What is known about HPAI transmission to humans is that it is rare, requiring prolonged direct contact with infected, sick, and dead animals, generally birds, now dairy cows, that can lead to mild flu-like symptoms or eye inflammation, some progressing to fatal infections, according to WHO. Again, HPAI in humans is linked to transmission via animal contact, not by foods.

It seems that occupational exposure resulted in infection of a farm worker handling ill cows, with developed of one symptom in the worker, eye redness (conjunctivitis), consistent with transmission by animal contact. HPAI has been detected in dairy cows in Texas, Kansas, New Mexico and Michigan as of April 2. The dairy animals and rare humans affected have recovered.

Cross-disciplinary evidence demonstrates that raw milk from healthy cows is not inherently dangerous, consistent with the CDC evidence of trends for 2005-2020 [15] and evidence of benefits and risks [2]. There is no scientific evidence that HPAI in raw milk causes human disease.

Please consider the references below and pose questions in the comments. You may be interested to learn more about these recent peer-reviewed publications.

• Trends in burdens of disease by transmission source (usa, 2005–2020) and hazard identification for foods: focus on milkborne disease.
  Journal of Epidemiology and Global Health.

• Suppression of pathogens in properly refrigerated raw milk.
  PLOS ONE

• Lessons identified from applications of the Risk Analysis Quality Test Release 1.0.
  Risk Analysis

This article was originally published on Peg Coleman’s website here: https://www.colemanscientific.org/blog/2024/4/7/where-is-the-evidence

References

1.           Buchanan RL, Havelaar AH, Smith MA, Whiting RC, Julien E. The key events dose-response framework: its potential for application to foodborne pathogenic microorganisms. Critical Reviews in Food Science and Nutrition. 2009 Sep 22;49(8):718-28.

2.           Dietert RR, Coleman ME, North DW, Stephenson MM. Nourishing the human holobiont to reduce the risk of non-communicable diseases: a cow’s milk evidence map example. Applied Microbiology. 2021 Dec 30;2(1):25-52.

3.           Francese R, Peila C, Donalisio M, Lamberti C, Cirrincione S, Colombi N, Tonetto P, Cavallarin L, Bertino E, Moro GE, Coscia A. Viruses and human milk: transmission or protection?. Advances in Nutrition. 2023 Aug 20.

4.           Gallo V, Giansanti F, Arienzo A, Antonini G. Antiviral properties of whey proteins and their activity against SARS-CoV-2 infection. Journal of Functional Foods. 2022 Feb 1;89:104932.

5.           Gallo V, Arienzo A, Tomassetti F, Antonini G. Milk bioactive compounds and gut microbiota modulation: the role of whey proteins and milk oligosaccharides. Foods. 2024 Mar 16;13(6):907.

6.           Lockhart A, Mucida D, Parsa R. Immunity to enteric viruses. Immunity. 2022 May 10;55(5):800-18.

7.           Kaplan M, Şahutoğlu AS, Sarıtaş S, Duman H, Arslan A, Pekdemir B, Karav S. Role of milk glycome in prevention, treatment, and recovery of COVID-19. Frontiers in Nutrition. 2022 Nov 8;9:1033779.

8.           Oda H, Kolawole AO, Mirabelli C, Wakabayashi H, Tanaka M, Yamauchi K, Abe F, Wobus CE. Antiviral effects of bovine lactoferrin on human norovirus. Biochemistry and Cell Biology. 2021;99(1):166-72.

9.           Panon G, Tache S, Labie C. Antiviral substances in raw bovine milk active against bovine rotavirus and coronavirus. Journal of Food Protection. 1987 Oct 1;50(10):862-7.

10.         Pavia G, Marascio N, Matera G, Quirino A. Does the human gut virome contribute to host health or disease?. Viruses. 2023 Nov 17;15(11):2271.

11.         Sangsiriwut K, Uiprasertkul M, Payungporn S, Auewarakul P, Ungchusak K, Chantratita W, Puthavathana P. Complete Genomic Sequences of Highly Pathogenic H5N1 Avian Influenza Viruses Obtained Directly from Human Autopsy Specimens. Microbiol Resour Announc. 2018. 7(22):e01498-18. doi: 10.1128/MRA.01498-18. PMID: 30533850; PMCID: PMC6284082.

12.         Santos I, Silva M, Grácio M, Pedroso L, Lima A. Milk antiviral proteins and derived peptides against zoonoses. International Journal of Molecular Sciences. 2024. 25(3):1842.

13.         Schlusselhuber M, Godard J, Sebban M, Bernay B, Garon D, Seguin V, Oulyadi H, Desmasures N. Characterization of milkisin, a novel lipopeptide with antimicrobial properties produced by Pseudomonas sp. UCMA 17988 isolated from bovine raw milk. Frontiers in Microbiology. 2018. 9:355822.

14.         Singh P, Hernandez‐Rauda R, Peña‐Rodas O. Preventative and therapeutic potential of animal milk components against COVID‐19: A comprehensive review. Food Science & Nutrition. 2023. 11(6):2547-79.

15.         Stephenson MM, Coleman ME, Azzolina NA. Trends in burdens of disease by transmission source (USA, 2005–2020) and hazard identification for foods: focus on milkborne disease. Journal of Epidemiology and Global Health. 2024 Mar 28:1-30.

16.         Tache S, Benkaddour M, Corpet DE. Rotavirus inhibitor and recovery in raw bovine milk. Journal of Food Protection. 1995 Apr 1;58(4):434-8.

17.         Taha SH, Mehrez MA, Sitohy MZ, Abou Dawood AG, Abd-El Hamid MM, Kilany WH. Effectiveness of esterified whey proteins fractions against Egyptian Lethal Avian Influenza A (H5N1). Virology Journal. 2010 Dec;7:1-4.

18.         Wan T, Wang Y, He K, Zhu S. Microbial sensing in the intestine. Protein & Cell. 2023 Nov 1;14(11):824-60.

19.         Wang X, Yue L, Dang L, Yang J, Chen Z, Wang X, Shu J, Li Z. Role of sialylated glycans on bovine lactoferrin against influenza virus. Glycoconjugate Journal. 2021 Dec 1:1-8.

RAWMI Annual Report for 2023-24

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 2023, RAWMI was awarded a 5th grant for $45k 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 5th grant from RAF, RAWMI was able to accomplish much towards the overall goal of universal access to safe raw milk. Over the last year, RAWMI accomplished the following.

Farmer Training and Mentoring

• Trained over 150 farmers, legislators, university professors, and consumers on raw milk benefits and risk management

• Prepared and presented an intensive full day World Class, Low-Risk Raw Milk training course for farmers in conjunction with Northeast Texas Community College in Mount Pleasant, Texas

• Prepared and presented a 1.5-hour Thriving with Raw Milk webinar for farmers in conjunction with Iowa State University in support of Iowa’s recent legalization of raw milk

• Prepared and presented a 2-day intensive Raw Milk Risk Management training course in Oregon in conjunction with Cast Iron Farm and Godspeed Hollow

• Prepared and presented a 1-hour talk about The Quest for Raw Milk from Grass to Glass in conjunction with Dairy Day at Holcombe-Jimison Farmstead Museum in New Jersey

• Prepared and presented a 1-hour talk about The Return of a Nourishing Tradition at Ringoes Grange in New Jersey

• Prepared and presented a 1-hour Got Raw Milk? discussion at University of North Carolina School of Law in conjunction with the Conservation and Agricultural Law Foundation

• LISTED eleven new farms 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

  • Fiat Farm in Bethel, Minnesota

  • Hillside Springs Homestead in Poultney, Vermont

  • 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

  • Lomah Texas in Dallas-Fort Worth area

  • Anonymous Goat Dairy in British Columbia, Canada

  • Chapman Family Farms & Dairy in Morrill, Nebraska

• Served as the raw milk hotline for farmers in need across the USA and Canada

• Provided one-on-one mentoring in the production of low-risk raw milk to over 50 additional farms in California, Colorado, Kansas, Kentucky, Idaho, Illinois, Indiana, Iowa, Michigan, Missouri, Montana, Nebraska, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Dakota, Tennessee, Texas, Vermont, Virginia, Wisconsin, British Columbia Canada, New Brunswick Canada, Quebec Canada, and Portugal

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

 Raw Milk Research

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

• Attended the International Milk Genomics Consortium Conference

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

Education for Raw Milk Legalization

• Developed raw milk legalization policy brief as a resource for legislators, policy makers, and legalization advocates

• Worked towards increased legal access to raw milk in Wisconsin, Delaware, Louisiana, Minnesota, South Africa, and Canada (with Canadian Artisan Dairy Alliance)

• Successfully advocated for legalization of raw milk in Iowa and Albuquerque, New Mexico

 Raw Milk Educational Materials

• Published 9 content pieces on the RAWMI website

  • Managing Pathogen Risks from Fresh Cows and Does

  • Iowa: The Path to Legalization of Raw Milk

  • Managing the Increased Risks of Calf-Sharing on Raw Milk Farms

  • Texas Raw Milk Training: for World-Class, Low-Risk Raw Milk

  • New Raw Milk Research from the 2023 IMGC Symposium

  • Albuquerque New Mexico: Another Victory for Raw Milk Legalization

  • New Raw Milk Research: Suppression of Pathogens in Properly Refrigerated Raw Milk

  • FDA Demonstrates Bias Against Raw Milk in Unfounded Raw Cheese Recall

  • Avian Flu and Raw Milk – A Common Sense Approach

• Published Farmers Can Thrive in the Emerging Raw Milk Market in The Natural Farmer Newspaper

• Continued work on an extensive book about raw milk risk management

• Wrote a 40+ page introductory training booklet for farmers titled Essential Principles for Low-Risk Raw Milk

 Supporting Testing for Low-Risk Raw Milk

• Provided on-farm lab sponsorships to 11 farms

  • Flat Creek Acres in Montana

  • 57 Farm Store in Wisconsin

  • Flowered Cow Dairy in Illinois

  • Shady Paddock Farm in Texas

  • Lomah Texas in in Texas

  • Lucky Star Farm in Iowa

  • ACM Grace Hill in Iowa

  • Chapman Family Farms in Nebraska

  • Towering Oaks Farm in North Carolina

  • Anonymous farm in British Columbia Canada

  • Raising Arrows in Nebraska 

Raw Milk Legalization Guidance

The Raw Milk Institute is frequently asked to weigh in on legalization of raw milk in various states and countries.  To that end, we have developed the following policy brief as a reference for legislators, policy makers, and legalization advocates.

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Raw Milk Legalization Policy Brief

Executive Summary

Consumers are demanding increased access to raw milk as a fundamental, health-supporting food. Raw milk can be produced as a low-risk food when farmers 1) are well-trained, 2) use specialized practices for mitigating risks on their unique farms, and 3) perform ongoing bacterial testing of their milk to ensure high standards. 

The Raw Milk Institute is in support of increased legalization. Raw milk is already legal in over half the states in the USA as well as many European countries including the United Kingdom, France, Italy, and Switzerland. Raw milk provides a pathway to economic viability for failing family farms when they focus on quality instead of quantity.

Raw Milk Risk Management Works

There is no such thing as a perfectly safe food. A CDC analysis of foodborne illnesses showed that a wide range of foods including meats and vegetables are known to have the potential for causing foodborne illnesses, with chicken, pork, and seeded vegetables topping the list. Pasteurized milk is not perfectly safe, either, and is implicated in foodborne illnesses and outbreaks every year.[1] 

Nonetheless, only raw milk is targeted by government regulators as a food to be completely avoided. Many foods, including raw milk, warrant concern for pathogens if not managed appropriately. Two studies have shown that raw milk can be carefully produced as a low-risk food.  

• Recent Trends in Unpasteurized Fluid Milk Outbreaks, Legalization, and Consumption in the United States (PLOS One 2018)

The authors concluded that, “Controlling for growth in population and consumption, the [raw milk] outbreak rate has effectively decreased by 74% since 2005.” The study suggested that the improving food safety record is the result of expanded safety training for raw milk dairy producers.[2]

• Raw Milk Producers with High Levels of Hygiene and Safety (Cambridge Journal of Epidemiology and Infection 2020)

Data show that raw milk being intentionally produced for human consumption is fundamentally different from pre-pasteurized milk that is taken from bulk tanks. It was concluded that "raw milk can be produced with a high level of hygiene and safety.” This paper provides further proof that, with farmer training, careful production practices, and ongoing testing, low-risk raw milk is achievable. [3]

Benefits of Raw Milk

• Immune System Support: Like breastmilk, raw milk supports strong immune systems. Large epidemiological studies have found that raw milk consumption is correlated with lower rates of asthma, eczema, allergies, ear infections, fevers, and respiratory infections.[4-6]

• Improved Digestion: Pasteurized milk is a top food allergen and difficult to digest. Raw milk is unlikely to induce allergies and it facilitates production of lactase enzyme in the intestinal tract. Thus, many people who are lactose intolerant have no issues digesting raw milk.

• Sustainable Pathway for Family Farms: Instead of continuing to struggle to make ends meet, raw milk farmers can thrive by selling directly to good-paying customers.

Legalization Guidelines

When raw milk is illegal, the demand will be supplied by neighboring states/countries as well as a black market where farmers are less likely to use recommended production practices. Regulatory agencies can improve the safety of raw milk in the following ways.

• Ensure there are legal pathways to raw milk access, such as retail sales, herd shares, delivery, and/or on-farm sales.

• Require raw milk farmers to attend training, such as the Raw Milk Institute’s 4-Hour Risk Management Training (which is freely available online).[7]

• Require that all dairy animals be free of Tuberculosis, Brucellosis, and Johne’s.

• Ensure that raw milk from multiple farms cannot be commingled.

• Recommend that raw milk be chilled to <40°F within an hour after milking and maintained at <40°F in storage and transport.

• Require farmers to test their milk at least once per month, at either an on-farm lab or an offsite lab, with the goal of achieving a 3-month rolling average of:

  • <15,000 cfu/mL for Standard Plate Count

  • <10 cfu/mL for coliforms

References

1. CDC MMWR (2018). Surveillance for Foodborne Disease Outbreaks — United States, 2009–2015.   https://www.cdc.gov/mmwr/volumes/67/ss/ss6710a1.htm

2. Whitehead, J., & Lake, B. (2018). “Recent Trends in Unpasteurized Fluid Milk Outbreaks, Legalization, and Consumption in the United States.” PLoS currents, 10, https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6140832/

3. Berge, A C, and T Baars. “Raw milk producers with high levels of hygiene and safety.” Epidemiology and infection vol. 148 e14.  31 Jan. 2020, https://pubmed.ncbi.nlm.nih.gov/32000877/

4. Loss, Georg et al. “The protective effect of farm milk consumption on childhood asthma and atopy: the GABRIELA study.” The Journal of allergy and clinical immunology vol. 128,4 (2011): 766-773.e4. https://pubmed.ncbi.nlm.nih.gov/21875744/

5. Brick, Tabea et al. “The Beneficial Effect of Farm Milk Consumption on Asthma, Allergies, and Infections: From Meta-Analysis of Evidence to Clinical Trial.” The journal of allergy and clinical immunology. In practice vol. 8,3 (2020): 878-889.e3. https://pubmed.ncbi.nlm.nih.gov/31770653/

6. Loss, Georg et al. “Consumption of unprocessed cow's milk protects infants from common respiratory infections.” The Journal of allergy and clinical immunology vol. 135,1 (2015): 56-62. https://pubmed.ncbi.nlm.nih.gov/25441645/

7. Raw Milk Institute (2021). Raw Milk Risk Management Training Videos. https://vimeo.com/showcase/8619574

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.

Allergies and Raw Milk

Modern Lifestyles and Allergies

Although allergies were rare prior to the 1800’s [1], they are a common affliction in our modern lifestyles.  As people have moved further from their agricultural roots, allergies have become more prevalent.  Several studies have found that exposure to diverse bacteria and potential allergens in the environment makes a big difference in preventing the development of allergies.

For instance, in a study looking at allergies and asthma in northern Europe, allergy prevalence was much higher in Finnish people as compared to Russians, even though they lived in geoclimatically similar areas [2]. 27% of Finnish school children demonstrated allergic sensitization to pollen, as compared to only 2% of their Russian counterparts. In unraveling the causes for this disparity, the study found a striking result: “the epidemic of allergy and asthma results from reduced exposure to natural environments with rich microbiota, changed diet and sedentary lifestyle.” Basically, exposure to environments with high bacterial and microbial diversity is associated with lower rates of asthma and allergies.   

North Karelia in Finland and Pitkäranta region in the Republic of Karelia in Russia. The dashed lines are Finnish borders before 1944. Haahtela, et al, 2015.

Several other studies have found similar results, and have concluded that living in a farm environment provides protection from asthma and allergies. Contact with farm animals was found to be associated with lower rates of allergies [3], as was “exposure to stables and farm milk” [4]. Although several studies identified that consumption of raw milk (aka “farm milk”) was an integral part of the farm environment, it was argued that allergy protection was from the farm environment and not from raw milk consumption.  However, further research has revealed that raw milk is indeed a key factor in protecting against allergies and asthma.

Children Who Drink Raw Milk Have Less Allergies

Several large epidemiological studies of European children have found correlations between raw milk consumption and decreased rates of allergies.

PARSIFAL Study

The PARSIFAL study was designed to look at allergy risk factors in children. This large study of over 14,800 European children (from Austria, Germany, the Netherlands, Sweden, and Switzerland) investigated allergic diseases in relation to children’s exposure to different environments (farms, rural, suburban) and farm-fresh foods (such as raw dairy products, eggs, and vegetables). The PARSIFAL data relating to allergies and raw milk were published in December 2006 in the Journal of Clinical and Experimental Allergy [5].

The PARSIFAL study concluded that there is a “significant inverse association between farm [raw] milk consumption and childhood asthma, rhinoconjunctivitis, sensitization to pollen, a mix of food allergens, and horse dander." The study found that, regardless of which environment the children lived in, those children who drank raw milk had significantly lower rates of allergies and asthma than children who did not drink raw milk. These effects were “most pronounced in children drinking farm milk since their first year of life.”

GABRIELA Study

The GABRIELA study was designed to investigate the genetic and environmental causes of asthma and allergies.  This study included over 8,000 European children (from Germany, Austria, and Switzerland), and was published in the Journal of Allergy and Clinical Immunology in August 2011 [6]. In this study, raw milk consumption was compared to consumption of boiled/pasteurized milk, and the level of exposure to raw milk in utero through school age was also accounted for. The study also looked into the children’s exposure to farm environments as a possible variable related to rates of asthma and allergies.

The GABRIELA study found that raw milk consumption is associated with significantly lower rates of allergies and asthma, and that this beneficial effect is independent of other farm exposures. It was found that early exposure to raw milk (at <1 year of age) and daily consumption of raw milk increased the beneficial effect in children who drank a mixture of raw milk and pasteurized milk. The consumption of only pasteurized milk “was not associated with any health outcome.”

It’s Not the “Farm Effect,” It’s the Raw Milk!

The above-referenced studies specifically analyzed the effects of living environments, and found that the beneficial effects of raw milk on allergies and asthma were indeed present even in children who did not live on farms. Furthermore, a recent meta-analysis of eight health studies related to raw milk was published in the November 2019 issue of the Journal of Allergy and Clinical Immunology [7]. A meta-analysis is a quantitative statistical analysis which combines the results of multiple scientific studies, thereby allowing the researchers to derive overall conclusions about that body of research.

The recent meta-analysis, written by a team of researchers from the Netherlands and Germany, concluded that when taken as a whole, the body of data from the previous studies shows that raw milk consumption in childhood has a protective effect on allergies and asthma “independent of other farm exposures and that children not living on a farm can theoretically profit from this effect.” 

Why Does Raw Milk Protect Against Allergies and Asthma?

Although it was originally postulated that raw milk’s bacterial content was responsible for its allergy-protective effects, research has not found this to be the case.  For instance, the GABRIELA study found that, “Contrary to our expectations, we did not observe an association between total viable bacterial counts in milk and investigated health outcomes” [6].

More recent research has investigated whether the whey proteins in raw milk could be responsible for the beneficial effect on allergies. A study published in the June 2020 Food and Function Journal “aimed at achieving a better understanding of the underlying mechanism between heat damage to whey proteins and allergy development” [8]. In this study, “raw cow’s milk was heated for 30 min at 50, 60, 65, 70, 75, or 80 °C [122, 140, 149, 158, 167, or 176 °F]… The allergy-protective effect of differently heated milk samples were tested in a murine OVA-induced food allergy model.” 

Heat treatment at 65 °C or higher destroyed allergy-protective capacity of raw milk in murine OVA-induced food allergy model. Abbring, Xiong, et al, 2020.

This study found that allergy protection ceases when raw milk is heated to 149 °F, which is the same temperature at which the whey proteins are denatured.  It was concluded that the whey protein in raw milk provides protection from allergies, asthma, and inflammation.  When heated above 149 °F, these properties are dramatically reduced or eliminated. This finding is an important confirmation of the unique beneficial properties of whole, unprocessed raw milk. 

Low-Risk Raw Milk as a Therapeutic Tool Against Allergies

The research is clear that raw milk consumption is correlated with protection from allergies and asthma. Although a living environment that is rich in bacterial diversity is helpful, it has been demonstrated that the allergy-protective benefits of raw milk are present in both rural and urban environments.  The immunologically active whey proteins are likely the cause of this protective effect.  There is a growing body of evidence that raw milk is a low-risk food when it is produced carefully and intentionally [9, 10]. Thus, low-risk raw milk can be a powerful therapeutic tool for allergy and asthma protection.

References

[1] Hay Fever and Paroxysmal Sneezing: Their Etiology and Treatment. 1887. Mackenzie M. https://archive.org/details/b20406757/page/n7/mode/2up

[2] Hunt for the origin of allergy – comparing the Finnish and Russian Karelia. Clinical and Experimental Allergy. 2015; (45) 891– 901. Haahtela T, Laatikainen T, Alenius H, Auvinen P, Fyhrquist N, Hanski I, von Hertzen L, Jousilahti P, Kosunen T U, Markelova O, Mäkelä M J, Pantelejev V, Uhanov M, Zilber E, Vartiainen E. https://onlinelibrary.wiley.com/doi/full/10.1111/cea.12527

[3] Farming exposure in childhood, exposure to markers of infections and the development of atopy in rural subjects. Clinical and Experimental Allergy : Journal of the British Society for Allergy and Clinical Immunology vol. 34,8 (2004): 1178-83. Radon K, Windstetter D, Eckart J, Dressel H, Leitritz L, Reichert J, Schmid M, Praml G, Schosser M, von Mutius E, Nowak D. https://pubmed.ncbi.nlm.nih.gov/15298556/

[4] Exposure to farming in early life and development of asthma and allergy: a cross-sectional survey. Lancet. 2001;358(9288):1129-1133. Riedler J, Braun-Fahrländer C, Eder W, Schreuer M, Waser M, Maisch S, Carr D, Schierl R, Nowak D, von Mutius E; ALEX Study Team. https://pubmed.ncbi.nlm.nih.gov/11597666/

[5] Inverse association of farm milk consumption with asthma and allergy in rural and suburban populations across Europe. Clinical and Experimental Allergy. 2007; 37(5):661-70. Waser M, Michels KB, Bieli C, Flöistrup H, Pershagen G, von Mutius E, Ege M, Riedler J, Schram-Bijkerk D, Brunekreef B, van Hage M, Lauener R, Braun-Fahrländer C; PARSIFAL study team. https://www.ncbi.nlm.nih.gov/pubmed/17456213

[6] The protective effect of farm milk consumption on childhood asthma and atopy: The GABRIELA study. Journal of Allergy and Clinical Immunology. 2011; 128 (4): 766-73. Loss G, Apprich S, Waser M, Kneifel W, Genuneit J, Büchele G, Weber J, Sozanska B, Danielewicz H, Horak E, Joost van Neerven RJ, Heederik D, Lorenzen PC, von Mutius E, Braun-Fahrländer C; GABRIELA study group. https://www.jacionline.org/article/S0091-6749(11)01234-6/fulltext

[7] The Beneficial Effect of Farm Milk Consumption on Asthma, Allergies, and Infections: From Meta-Analysis of Evidence to Clinical Trial. Journal of Allergy and Clinical Immunology: In Practcice, 2019. 8 (3): 878-889. Brick T, Hettinga K, Kirchner B, Pfaffl MW, Ege MJ. https://www.ncbi.nlm.nih.gov/pubmed/31770653

[8] Loss of allergy-protective capacity of raw cow's milk after heat treatment coincides with loss of immunologically active whey proteins. Food and Function. 2020 Jun 24;11(6):4982-4993. Abbring S, Xiong L, Diks MAP, Baars T, Garssen J, Hettinga K, van Esch BCAM. https://pubmed.ncbi.nlm.nih.gov/32515464/

[9] Recent Trends in Unpasteurized Fluid Milk Outbreaks, Legalization, and Consumption in the United States. PLOS Currents. 2018; 10. Whitehead J, Lake B. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6140832/#ref27

[10] Raw milk producers with high levels of hygiene and safety. Epidemiology and Infection, 2020; 148, e14, 1-7. Berge AC, Baars T. https://www.ncbi.nlm.nih.gov/pubmed/32000877 

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.

Raw Milk and Lactose Intolerance

People choose to drink raw milk for many different reasons. Some are seeking to support local farms and connect with the places from which their food originates.  Others want to make sure that animal welfare is a high priority in the production of their food. Some people choose raw milk for its delicious, rich flavor.  And still others seek out raw milk in order to address specific health conditions, such as asthma, allergies, and eczema.

Lactose intolerance and maldigestion of pasteurized milk are significant factors for many people who choose raw milk. Nonetheless, when researching the peer-reviewed literature, many would conclude that raw milk cannot help with lactose intolerance. Raw milk detractors often cite a study by Stanford University in their assertion that raw milk does not help with lactose intolerance. However, many people who have been diagnosed as “lactose intolerant” have reported that they can actually drink raw milk with no digestive problems. Let’s dig deep into all of this to better understand the disconnect.

The Stanford Study

The Stanford study, titled “Effect of Raw Milk on Lactose Intolerance: A Randomized Controlled Pilot Study,” assessed the effects of raw milk, pasteurized milk, and soy milk in 16 adults. The people participating in this study were confirmed to have “true lactose malabsorption” through the use of a Hydrogen Breath Test (HBT). Over a course of several weeks, the participants in the study consumed successively greater amounts of raw milk, pasteurized milk, and soy milk in an 8-day milk phase for each type of milk as shown in the figure below.  This study found that there was no improvement in lactose intolerance symptoms with the consumption of raw milk compared to pasteurized milk.

Milk dosage protocol and outcome measures for each 8-day milk phase: full amount of milk was consumed in 1 sitting on each day. Mummah, et al 2014.

Although the Stanford study has often been cited as proving that raw milk does not help with lactose intolerance, there are some significant problems with this study. The sample size of 16 participants is quite small, and this makes is very difficult to make any sweeping conclusions based on the results of the study.  The sample size becomes even more problematic when it is considered that 383 people initially signed up to participate in the study.

The 383 people who volunteered for this study considered themselves to be lactose intolerant. This means that they had experienced digestive symptoms such as diarrhea, abdominal cramping, audible bowel sounds, and/or flatulence as a result of consuming milk products. However, only 27 people were qualified to participate through the use of the Hydrogen Breath Test. Of these 27 people, 16 people chose to participate in the study. Out of the initial group of 383 volunteer participants, only 4% actually participated in the study. This means that 96% of the original volunteers were excluded from this study!

This calls into question the use of the Hydrogen Breath Test as an appropriate measure of lactose intolerance.  Although the HBT is used to characterize the clinical definition of lactose malabsorption, it is clearly not a sufficient test for identifying people who experience digestive symptoms as a result of consuming milk products. The study even mentioned that, “Many people with lactose malabsorption [as diagnosed through results of the HBT] do not report clinical lactose intolerance. Conversely, many individuals with perceived lactose intolerance do not experience malabsorption [as confirmed with HBT].” The Hydrogen Breath Test is clearly not a sufficient test for identifying people who experience digestive symptoms from the consumption of milk products.

Another significant problem with the Stanford study is that the length of the 8-day milk phases may have been too short.  Specifically, the study authors found that “the reduced H2 production observed for raw milk on day 8 vs day 1 suggests a degree of adaptation to raw milk… In contrast to raw milk, no adaptation was observed for pasteurized milk.” The participants had decreased levels of hydrogen in the HBT by the end of the 8-day raw milk phase, and this finding warrants further study to determine whether this trend would have continued over a longer period of time and resulted in a reduction of lactose intolerance symptoms.

Mummah, et al 2014

Overall, the Stanford study fell far short of actually answering the question of whether raw milk can be well-tolerated by people who describe themselves as “lactose-intolerant.” 96% of the volunteers who considered themselves to be lactose intolerant were excluded from this study. Furthermore, the study did not continue long enough to determine if the positive trend in hydrogen production from drinking raw milk would have continued and resulted in reduction of lactose intolerance symptoms.

First-Hand Accounts About Raw Milk and Lactose Intolerance

There have been numerous first-hand reports of improvements in lactose intolerance from the consumption of raw milk. For instance, lactose intolerance runs in my husband's family, coming through his father.  My husband and his siblings all developed digestive problems from consuming milk and other dairy products at around 18-20 years old. Prior to trying raw milk, my husband could only tolerate pasteurized milk products if he took lactase enzyme pills whenever he consumed dairy. However, my husband has been able to drink raw milk in moderate amounts (such as 1-2 glasses per day) with no problems, and raw milk consumption also corresponded with an increased ability to tolerate pasteurized dairy in cheese and ice cream.  My father-in-law was also able to consume raw milk without digestive problems and reported that it also increased his ability to consume pasteurized cheese and ice cream.  

Here are a few more first-hand accounts about raw milk consumption and lactose intolerance.

“I am lactose intolerant. I was diagnosed around the age of 12. I missed so much school due to upset stomach & went off of dairy fully for over 10 years. I can drink raw milk with no issues - I can have cups of it with no bad side effects. In fact - I can even have pasteurized dairy now with little to no problems. It has helped my gut health so much - I notice when I don’t consume it because my digestion gets weird.

“When I first started drinking it I was terrified but after the first cup my body craved it for the first month. It was all I wanted. I could have easily drank half a gallon a day if I didn’t limit myself. That’s tapered off now though.”       ~Bethanie N.

“I had IBS and had to take everything out of my diet and slowly add things back in to see what was bothering me. It was processed dairy. Found raw dairy and now that's all I consume most days. Raw milk, cheese, yogurt, butter. IBS gone, hemorrhoids gone, arthritis gone, inflammation gone, sinus problems gone. Feel like a new woman.” ~Patricia W.

“My kids were all lactose intolerant, but when I switched to raw A2, they all saw a huge difference in response. No more issues. One of my kiddos was at the point of needing her tonsils removed, but they shrunk down to normal size, and her sleep apnea went away.” ~mother of four children

Surveys About Raw Milk and Lactose Intolerance

There have been several raw milk surveys which collected data about lactose intolerance. In a 2007 survey of Michigan raw milk drinkers, 155 people participating in the survey had been diagnosed with lactose intolerance by a healthcare professional. Out of these 155 people, 118 reported that they did not have lactose intolerance symptoms from consuming raw milk.  Thus, 76% of the survey respondents who had been diagnosed with lactose intolerance were able to consume raw milk with no digestive issues.

In a 2011 survey of 56 Michigan raw milk drinkers, “eleven individuals claimed that they experienced symptoms of lactose intolerance when drinking processed milks but had no ill side effects from drinking raw milk.”

In a 2014 survey of 153 Maryland raw milk drinkers, “Fifty-nine respondents claimed no discomfort after drinking raw milk but discomfort from drinking pasteurized milk.

Raw Milk and Lactase

Pasteurization inactivates enzymes and also denatures proteins, and consequently pasteurized milk induces digestive discomfort in many people. Lactase is the enzyme responsible for breaking down lactose into digestible form. Raw milk facilitates the production of lactase enzyme in the intestinal tract, and thus it makes sense that so many people have reported improvements in lactose intolerance from drinking raw milk.

Ancient populations who relied on dairy products adapted over time by developing lactase persistence genes. These genes allow people to digest lactose into adulthood, and they have been found in various indigenous populations in Africa, Europe, Asia, and the Middle East. Overall, around 35% of adults worldwide have lactase persistence genes.

Although it has been widely argued that only people who have lactase persistence genes can consume milk, there are currently many populations around the globe who subsist largely on dairy yet who do not have lactase persistence genes.  For instance, despite the fact that an estimated 95% of Mongolians do not have the lactase persistence gene, their diet relies very heavily on raw milk, cheese, and other milk products.

Furthermore, archaeological evidence shows that humans were consuming raw milk for thousands of years before the widespread appearance of the lactase-persistence gene. Raw milk allowed humans to thrive in conditions where survival would have been difficult. Scientists now believe that lactase-persistence genes were spread through natural selection. This means that the reproductive capacity and/or survivability of ancient raw milk drinkers was substantially increased compared to non-milk-drinking populations.

Large Body of Evidence for Raw Milk and Lactose Intolerance Benefits

First-hand accounts and surveys show that there are many people whose lactose intolerance symptoms are improved by drinking raw milk. Additionally, many worldwide raw milk-drinking populations do not have lactase persistence genes. Furthermore, the archaeological record shows that humans were consuming raw milk for thousands of years before the appearance of lactase persistence genes. This large body of evidence cannot be negated by one small study. The Stanford study should clearly not be seen as the final word on raw milk and lactose intolerance.

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