Raw milk is milk that has not been pasteurized, that is, heated to 72°C and then rapidly cooled.
There are two kinds of raw milk:
- The first is milk that is intended for pasteurization. In its pre-pasteurized form, this milk may be unsafe for human consumption because it has not been produced to strict hygiene standards, such as avoiding fecal contamination that causes the majority of foodborne illnesses associated with raw milk. Standards for pre-pasteurized raw milk allow for higher levels of contaminants, such as campylobacter or E.coli, since heating the milk will kill these bacteria.
- The second type is raw milk for direct human consumption. Trained farmers follow stringent safety standards on the farm and in the milking parlour. This raw milk is always “single-estate”, never co-mingled with that of another dairy farm. It is rigorously tested to ensure it is free from harmful bacteria and comes from a healthy herd, free from tuberculosis and brucellosis. When CADA refers to raw milk, this is the type of milk we mean.
YES, in almost all countries around the world. In Canada, it is legal to consume raw milk in most regions, but it is illegal to sell, deliver or distribute it. Under federal Food and Drug Regulations, all milk for human consumption must be pasteurized. Every province also has its own laws and regulations forbidding its production and distribution. Changing these laws is the mission of CADA.
In countries where raw milk is legal, it can be purchased directly from farms and from some grocery stores. In some places where farmers may not sell it direct to consumers, raw milk may be obtained from a herdshare, a system that allows consumers to purchase part ownership of an animal in the dairy herd and to consume it under the “personal use” exemption in that jurisdiction.
Nevertheless, there are many Canadian consumers who develop a direct relationship with a farmer willing to sell them the milk, or to produce milk for them under a herdshare arrangement. Regulators consider this illegal and farmers have been charged and fined for non-compliance.
Canadians can also bring raw milk across the border from Washington and New York states.
There have been cases of serious foodborne illnesses associated with consuming unpasteurized dairy. If raw milk comes from unhealthy livestock, or is produced without following appropriate raw milk safety standards, it may be risky to consume. The actual safety will be dependent on the skills and hygiene practices of the farmer who produces it. This is why CADA advocates for legalization of raw milk on three conditions:
- Farmers are trained and mentored;
- Milk undergoes rigorous bacterial testing; and
- Farms have comprehensive risk management plans.
Originally, pasteurization was legislated in order to deal with herds infected with tuberculosis or brucellosis and farms with substandard hygiene practices. Lady Eve Balfour, founder of the Organic Movement and Soil Association in the UK, stated that ‘pasteurisation was a confession of failure. The aim should be to abandon the practice just as soon as the need for it – unhealthy cows and dirty methods – can be eliminated.’
On its website, Health Canada makes a misleading statement about pasteurization: “It does not affect the quality of nutrients present in milk, such as calcium, protein, riboflavin, niacin, folic acid, vitamin B6, pantothenic acid and vitamin A.” What this statement fails to address is that the complementary enzymes necessary for the body to absorb these nutrients have been killed through pasteurization.
While our pancreas is able to produce all kinds of enzymes to help us digest our food, it does put a strain on it. It is easier for the pancreas when the foods already contain the enzymes needed for digestion. Raw milk’s enzymes make minerals like calcium, magnesium and phosphorous more absorbable and help us digest butterfat. Unfortunately, pasteurization destroys the wide array of enzymes in raw milk.
Raw milk farmers who follow the safety standards which CADA advocates (namely, training, testing and risk management) care about the quality of the milk they produce and the health of their herds. They ensure the animals graze on fresh grass in the warm months and on dried forage in the winter. As a result, grass-fed livestock produce milk that has a higher level of the cancer-fighting omega-6 fatty acid CLA (conjugated linoleic acid).
The Canadian Artisan Dairy Alliance supports farmers who take great care in producing an artisanal food that not only tastes better, but is better for us.
Neither raw milk nor pasteurized milk is an outstanding source of Vitamin D. You would need ten 8-ounce glasses of fortified milk to reach 1000 IUs of Vitamin D (the recommended daily allowance.) It is best to obtain Vitamin D from healthy exposure to sunlight or by eating foods such as fish and organ meats. Pasteurized milk contains synthetic Vitamin D as a public health measure; however, for many people, this form of Vitamin D is difficult to absorb.
Sarah Smith, Raw Milk Institute, explains, “The overall amounts of Vitamin D3 in raw milk will generally be lower than that of fortified milk. However, it is important to note that there are various forms of Vitamin D and that raw milk will naturally contain multiple [natural] forms (including D2 and D3). The bioavailability of the naturally occurring forms of Vitamin D in raw milk would be higher than that of Vitamin D fortified milk.”
Sometimes people who think they are lactose-intolerant are only pasteurization intolerant.
If you are someone who suffers from lactose intolerance, you know the symptoms can range from embarrassing to debilitating: audible bowel sounds, flatulence, abdominal cramping, and diarrhea. It can be a hereditary condition or it may arise from damage to the digestive tract through poor nutrition or use of antibiotics. Raw milk contains the friendly bacterium lactobacillus that your body uses to create the enzyme lactase which is needed to digest the milk sugar lactose. Pasteurization destroys lactobacillus. This is why pasteurized milk left at room temperature for hours will putrefy, whereas raw milk will only sour, becoming a delicious fermented drink.
One objection to the claim that lactose-intolerant people can enjoy raw milk is an oft-referenced 2014 Stanford study. However, that study only included 16 subjects of the initial 383 volunteers and participation selection was questionable.
Other digestion difficulties are related to allergies to the protein casein, found in cow’s milk. Some people with this issue can digest dairy products from sheep, goats, buffalo and camels. Not that you’ll see too many milking camel herds in Canada.
A better comparison would be to human breast milk which, of course, is always consumed raw.
Human breast milk contains at least 700 different kinds of bacterial strains and 2500 different proteins, including powerful anti-inflammatory enzymes. It even has pathogens found in it when routinely tested. Breast milk contains functional and protective proteins that provide very specific functions to the growing baby. Specialized sugars and carbohydrates plus fibre feed the good bacteria and starve the bad. Raw milk from humans, cows, buffalo, goats, sheep and camels is a whole food that nourishes, protects, and even gives genomic direction to the nursing young through mRNA data found in raw milk.
CADA would like to know the answer to this too. There have been outbreaks and food recalls for strawberries, romaine lettuce, corn, and deli meats, to mention just a few, yet these foods have not been banned. We urge Health Canada to review the most recent raw milk safety data and update the Canadian laws. As of January 1, 2022, the BC Fresh Milk Project, for example, tested 220 samples for the four pathogens most frequently associated with dairy-related outbreaks. All 880 pathogen tests have been negative—no pathogens found.
The safety of raw milk is the main issue holding back legalization. Arguments that milk is unsafe were successfully made in Canadian court cases which ruled against legalization, examples being R. v Schmidt 2011 (paragraphs 76, 85, and 87 to 90), R. v Schmidt 2014 (paragraph 20), and Affleck v The Attorney General of Ontario 2021 (lots).
In 2016, a petition asking Health Canada to legalize raw milk was rejected because of arguments concerning safety. In responses to consumers who write to ask for raw milk legalization, food safety is the main issue raised by Health Canada.
In order to see legalization happen, we need to address the issue of food safety.
In 2014, the BC Herdshare Association met with BC’s Minister of Agriculture Norman Letnick. He told them that he supported legalization, but they had to address the Ministry of Health’s food safety concerns. He also said, “You have to go through it [legalization], not around it. No more loopholes.” Selling pet milk for human consumption would be considered a loophole. Frozen raw goat milk is already available in pet stores, and there is no momentum among pet owners to get distribution expanded beyond this. Health Canada will not believe CADA if we say that our goal is to further expand the sales of pet milk for pets to drink.
There is a difference between raw milk produced by methods intended for pasteurization and raw milk produced by methods appropriate for direct human consumption. Dr. Ted Beals described the “two types of raw milk” in a January 2022 article on the Real Milk website [provide link] and data from the BC Fresh Milk Project also confirms this difference. So far, 232 raw milk samples from grass-fed microdairy herdshares have been tested for pathogens. Most participant farmers are either fully RAWMI-trained or are partially-trained (“in-training”). Two are RAWMI-Listed. A total of 928 pathogen tests have been performed and 100% of them were negative.
The U.S. Centers for Disease Control and Prevention (CDC)’s National Outbreak Reporting System (NORS) database lists two deaths and many illnesses related to raw milk. Details on the deaths are as follows:
- Listeriosis outbreak associated with one death in Florida. Cancer was a pre-existing condition (more information at https://www.cdc.gov/listeria/outbreaks/raw-milk-03-16/index.html and https://www.journalofdairyscience.org/article/S0022-0302(19)30990-7/fulltext ).
- Campylobacter outbreak in Utah associated with 99 illnesses, 10 hospitalizations, and one death. The individual who died also had a pre-existing health condition (more information at https://www.cdc.gov/mmwr/volumes/65/wr/mm6512a1.htm and (https://archive.sltrib.com/article.php?id=58524746&itype=CMSID).
In addition, CDC data from 2005 to 2017 shows that unpasteurized fluid milk was also responsible for 31 cases of hemolytic uremic syndrome (HUS), a serious illness which can involve kidney failure or lead to disability. Medical intervention may have prevented a larger number of deaths in these cases.
Between 2005 and 2016, unpasteurized fluid milk was responsible for 66% of all dairy-related outbreaks, despite a much lower consumption rate than other dairy products such as pasteurized milk and cheese (source: Whitehead and Lake 2018, Table 1)
The flaw in the CDC’s data is that it does not distinguish between milk produced by methods intended for pasteurization and milk produced by methods appropriate for direct human consumption. Dr. Ted Beals described the “two types of raw milk” in a January 2022 article on the Real Milk website and data from the BC Fresh Milk Project confirms this difference. So far, 232 raw milk samples from grass-fed microdairy herdshares have been tested for pathogens. Most participant farmers are either fully RAWMI-trained or are partially-trained (“in-training”). Two are RAWMI-Listed. A total of 928 pathogen tests have been performed so far and 100% of them were negative.
The simple fact is that not all raw milk is safe to consume. We recommend to consumers that, whenever possible, they choose milk from “dedicated raw milk dairies” rather than “dual-purpose dairies” which produce milk for pasteurization plus sell it raw to the public.
Farmers need to be appropriately trained order to produce raw milk direct for human consumption. Producing milk for pasteurization, with an emphasis on milking animals as fast as possible and maximizing volume produced, does not work for producing safe raw milk. Paying careful attention to meticulous udder preparation and equipment cleaning and sanitation are vital, and these methods take time.