Safety
With proper training and strict risk management procedures, raw milk farmers can meet or exceed the most exacting safety standards set for pasteurized milk production.
So why is raw milk banned in Canada?
Two Types of Raw Milk
Published studies of milk produced by conventional dairies show frequent positive tests for pathogens. Laws are based on the assumption that it is therefore impossible to produce raw milk that is safe for human consumption. However, the recent development of production methods designed to ensure safety in raw milk for direct human consumption shows this assumption to be false. When we talk about raw milk, we MUST distinguish between raw milk intended for pasteurization and raw milk intended for direct human consumption.
Conventional Milk Produced for Pasteurization
At CADA, we do not advocate anyone drink unpasteurized milk from a conventional dairy farm. Unfortunately, it is true that this milk may be unsafe to consume. This milk might be produced where there’s lots of manure, inadequate udder preparation, or a less-than-spotless milking parlour. With even one of these factors, there’s a higher risk of contamination. For example, many conventional dairies don’t wash and dry udders or strip out fore-milk prior to milking, but only apply teat-dip. This not only leaves udders contaminated with manure, but also contaminates the teat dip. To be clear, CADA is not advocating that this type of raw milk be legalized.
Raw Milk for Direct Human Consumption
Canada is only one of five countries worldwide and the only G7 country to have a total ban on raw milk. This means that the vast majority of countries worldwide have found ways to produce raw milk to an acceptable level of risk. All foods have some risk.
In Europe, Germany has developed particularly effective safety regulations. In the United States, the non-profit Raw Milk Institute (RAWMI) was founded in 2011 to advance the cause of safe raw milk by bringing together a collegium of experts to determine the most important factors in ensuring raw milk is prepared so it is safe to consume by humans. This group of medical doctors, epidemiologists, nutritional consultants, veterinarians, food safety scientists, raw milk farmers and raw milk consumers developed the Raw Milk Institute Common Standards, first released in 2012.
Safety Standards for Raw Milk
There are three important steps to ensuring safe raw milk, according to the Raw Milk Institute (RAWMI):
Farmer training and mentoring
Farm-specific food safety plans
Rigorous bacterial testing standards
RAWMI provides free training in the form of workshops, webinars, on-farm mentoring and video training. RAWMI has also provided advice about raw milk safety to politicians and legislators in various US states, and around the world.
To become a RAWMI-listed farm, farmers must go through the training and submit test data monthly to show compliance with RAWMI Common Standards. They must also submit an Annual Checklist to demonstrate continued low-risk optimization of their production of raw milk.
When milk is produced to RAWMI Common Standards, it meets or exceeds government safety standards set for pasteurized milk, as seen in the table to the right.
NOTE: RAWMI uses a ratio based on the equivalencies from the Canadian National Dairy Code to convert individual bacteria count (IBC) to standard plate count (SPC), a conversion factor of 0.41. For instance, 12,000 IBC = 5,000 SPC.
Evidence of Safety
Tests of raw milk samples and population-level outbreak statistics are evidence that raw milk can be safe to consume provided appropriate production methods are followed.
California has just over 39 million inhabitants; almost the same as the entire population of Canada. There, raw milk is sold in grocery stores, at farm markets, and from farms directly. California has not had a raw milk outbreak since 2016. And the last “outbreak” of illness from raw milk in 2012. This was the year the RAWMI standards were released.
Data from the United States CDCs National Outbreak Reporting System (NORS) shows that per-capita raw milk-related outbreaks have been steadily declining.
Since 2011, when raw milk training began to be available, up to 2021, there’s been a 68% decrease in outbreak rates.
Test results from RAWMI-trained farmers show that with proper training and strict risk-management procedures, raw milk farmers can meet or exceed the most stringent safety standards set for pasteurized milk. In other words, raw milk can be as safe to consume as any other food.
BC Raw Milk Project
The BC Herdshare Association’s “The BC Fresh Milk Project” has independently tested milk samples from grass-fed micro-dairy herdshare farms in BC. All 265 milk samples and 1060 pathogen tests came back negative.
RAWMI Common Standards
The mission of the Raw Milk Institute (RAWMI) is to improve the safety and quality of raw milk and raw milk products through: training and mentoring farmers; educating consumers; establishing international raw milk guidelines; improving consumer access and producer transparency; and investment in raw milk research.
There are three fundamental components to the Raw Milk Institute farmer mentoring program:
Common Standards that all LISTED farmers follow
Risk Analysis and Management Plan (RAMP), food safety program specific and appropriate to farm size, breed, and type of production
Training and Education
Additional RAWMI Information
Common Standards for RAWMI-LISTED Raw Milk Farmers
The following Common Standards are guidelines for the production of raw milk. All farmers LISTED with Raw Milk Institute make every possible effort to achieve these Common Standards with transparency and integrity.
Have a Risk Analysis and Management Plan (RAMP) for raw milk production.
Test for coliform bacteria at least monthly. Testing frequency will depend on each farmer’s individual RAMP. Target: a rolling three-month average of less than 10 coliforms per ml raw milk.
Test for Standard Plate Count (SPC)* at least monthly. Testing frequency will depend on each farmer’s individual RAMP. Target: a rolling three-month average of less than 5,000 per ml raw milk.
Raw Milk shall not contain pathogens including the following 4 main pathogens for raw milk: Salmonella spp., E. coli O157:H7, Campylobacter spp., and Listeria monocytogenes.
Pathogen testing and testing frequency will depend on each farmer’s individual RAMP.
Small farms and farms who do not have access to pathogen testing labs may rely on coliform and SPC testing as a general indicator of milk hygiene and safety.
Sell raw milk for direct human consumption that is only from their own farm. Commingling of raw milk from other dairies is not permitted.
Provide documentation and assurance that herds are tuberculosis (TB) free and tested once per year OR meet local TB requirements.
Provide documentation or assurance that herds are brucellosis free.
The Common Standards are basic guidelines for effective risk reduction practices. Farmers are encouraged to expand on the basic guidelines and include other risks that may be found in their specific set of conditions. RAWMI is available to assist farmers if they choose to expand their programs to address additional risks and risk reduction practices.
RAMP Food Safety Plan (Risk Analysis and Management Plan)
All LISTED farmers have a basic food safety plan – RAMP – that assists them in optimizing their production of raw milk. With technical assistance provided by RAWMI, each LISTED farmer develops their own specific RAMP with size-appropriate frequency of monitoring, sampling and testing. This comprehensive plan identifies potential risks that are present at the farm. Management practices are set up to reduce, manage, or mitigate those potential risks.
Individual RAMPs
Includes risk assessment and mitigation measures for the following risks:
Animal introduction onto farm (transportation and trade risks) — New animal risk introduction and risk mitigation; Health screening animals for potential health issues, bacterial hazards, etc.
Herd health — Mastitis prevention and management; Preventative veterinary program
Milk handling and management — Training of milking team and milking protocols; Protection and security of raw milk after milking is complete; Ensuring that milk is rapidly chilled and kept cold; Cleaning protocols and documentation
Environmental management — Water sources; Pasture management; Manure management; Bedding management; Wild animals/rodents; Land and soil issues; Weather; Other livestock such as chickens, pigs, etc.
Feed sources — Pasture; Purchased feed; Hay and silage; Water feeder management
Human factors — Health of milking team; Risk introduction by people
Nutritional management of the dairy cow, goat, sheep, or other lactating mammals
Management of freshened animals and new offspring
Management of bulls/bucks/rams
Individual RAMPs include procedures, protocols and documentation:
Testing procedures for indicator bacteria including coliforms and SPC.
Testing procedures (if utilized in specific RAMP) for potential bacteria including Salmonella, Listeria monocytogenes, Campylobacter and E. coli O157:H7.
Checklists that document annual, monthly, weekly and daily management practices.
Protocols for action steps in the event of substandard results.
Additional RAWMI Training & Resources
Farm bio-security – how to protect your herd
Know your enemy- basic microbiology, bacteria, the good and the bad
Preventive herd health medicine
Quarterly LISTED farmer meetings to exchange knowledge and aid with troubleshooting
Consumer education and outreach
Media management and communication skills
Recall and critical incident management
More Information is available at: https://www.rawmilkinstitute.org/