Two Types of Raw Milk

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

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

“Raw milk is dangerous!”

“Doesn’t raw milk make people sick?”

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

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

Raw Milk Intended for Pasteurization

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

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

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

Raw Milk Intended for Direct Human Consumption

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

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

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

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

Where Do Pathogens in Milk Originate?

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

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

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

Comparison of Bacterial Test Standards for Two Types of Raw Milk

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

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

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

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

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

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

Research on Raw Milk Safety

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

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

Data courtesy of the British Columbia Herdshare Association

Not All Raw Milk Is Dangerous!

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

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

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

FREE Raw Milk TRAINING: RAWMI Risk Management Training Video Series

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

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

About the Training

This RAWMI training focuses on:

• benefits of raw milk,

• grass-to-glass identification of risks,

• development of a risk management plan, and

• lessons learned from other raw milk dairies.

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

Links to Specific Segments

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

WORKSHOP OVERVIEW: 

PART 1 – Introductions and About Raw Milk Institute  

PART 2 – Raw Milk History and Opposition 

PART 3 – Raw Milk Benefits 

PART 4 – Raw Milk Risks and RAWMI Method 

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

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

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

PART 8 – Risk Minimization: Animal Health and Biosecurity 

PART 9 – Risk Minimization: Milking and Udder Prep 

PART 10 – Risk Minimization: Management 

PART 11 – Q&A for Parts 1-10 

PART 12 – Risk Minimization: Management (cont.) 

PART 13 – Risk Minimization: Management (cont.) 

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

PART 15 – Raw Milk Testing 

PART16 – Why to Become RAWMI LISTED 

PART 17 – Conclusion and Final Q&A

What Attendees Have Said

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

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

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

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

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

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

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

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

DONATE to HELP Farmers Test Their Raw Milk

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

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

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

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

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

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

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

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

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

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

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

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

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

Harmful By-Products from Chlorine Sanitizers

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

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

Harmful Chlorine Byproducts in Milk

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

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

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

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

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

Acceptable Limit Standards

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

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

Practical Advice for Raw Milk Farmers

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

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

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

• More complex milking systems, such as pipeline systems,

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

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

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

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

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

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

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

alternatives to using chlorine-based sanitizers include the following:

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

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

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

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

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

References

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

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

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

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

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

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

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

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

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

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

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

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

Biofilms Provide a Place for Bacteria to Grow

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

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

Cleaning to Prevent Biofilms

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

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

Periodically Change Cleaners to Prevent Biofilm Growth

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

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

Aim for “Kitchen Clean”

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

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

Lukewarm Water First, Then Hot Cleaner

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

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

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

Acid Rinse

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

Drying

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

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

Sanitize Prior to Milking (Optional)

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

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

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

Test to Verify That Cleaning Process is Working Well

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

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

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

Daily Cleaning Habits for Success

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

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

NOW Available: Farmer Training Booklet

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

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

• Managing the Conditions for Low-Risk Raw Milk

• Udder Preparation for Low-Risk Raw Milk

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

• Managing the Risks of “Fresh” Cows and Does

• Managing the Risks of Calf-Sharing

• How to Clean Your Milking Machine

This booklet is offered in two formats:

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

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

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

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.