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.

Why, then, is raw milk banned in Canada?

Water buffalo.

Health Canada’s Position

When milk from clean, healthy dairy livestock is extracted by clean, healthy humans, chilled promptly in clean storage tanks, and frequently tested, it is a healthy, safe, and delicious alternative to pasteurized, commercial milk. Yet Health Canada argues that raw milk is unsafe and, as proof, points to outbreak rates in jurisdictions where standards may be inadequate.

For example, Health Canada responded to a consumer by citing a 2014 letter from the CDC detailing outbreak rates in the U.S. There are two problems with this.

First, the regulation of raw milk in the U.S. is a patchwork of state laws, and most states have legal raw milk, but little or no regulation of product quality. As an example, only 18 states have set bacterial testing standards, and only six of these states require pathogen testing. Not all states have licensing or inspection programs. Many states permit farms that produce milk for pasteurization to also sell it raw to the public. CADA is not asking for legalization without standards.

Second, the outbreak data is obsolete. The contents of the CDC letter were published in an article later that year (Mungai et al. 2014), and this article concluded, based on 2007 to 2012 data, that legalization increases outbreak rates. A newer article (Whitehead and Lake (2018) examined the same data-set, but expanded it (2005 to 2016) and found that per-capita outbreak rates declined as legalization and consumption rates increased. This is the chart with 2017 data added (Note: The authors mention that CDC outbreak data for 2009 had quality issues).

Outbreaks per 1M persons in USA

Looking at total U.S. population, this chart is a very conservative estimate. If overall consumption of raw milk is factored in, there has been a 74% decline since 2005 in per-capita outbreak rates related to unpasteurized fluid milk.

Impact on Consumer Demand

But for all the safety concerns, banning raw milk consumption in Canada has not stopped the demand. In fact, demand is increasing as more people become aware of the health benefits and discover it is available in almost every other country. As with any banned product, prohibition increases risk when consumers can only purchase raw milk from black market suppliers who may or may not run a hygienic operation, and when inspections for food safety standards don’t occur. Yet even with government regulation, pre-pasteurized commercial milk and raw milk for human consumption, require different safety standards. As long as inspectors view all unpasteurized milk the same, outbreaks will occur and distrust of raw milk will continue.

Will Canadians who want the health benefits of raw milk ever be able to obtain it safely? The knowledge of how to do this exists and the proof that it works is available. When Canadian law makers are ready to legalize and regulate raw milk for human consumption, they can refer to excellent safety standards in use, such as the ones developed by the Raw Milk Institute to protect our health.

Safety Standards for Raw Milk

Effective safety regulations are in use in European countries such as Germany. In the United States, the non-profit Raw Milk Institute (RAWMI) has developed highly effective, voluntary safety standards (RAWMI Common Standards) and provides accreditation to farms that meet those standards. This gives consumers assurance that the milk produced by accredited farmers is produced safely, even in jurisdictions where government regulations are insufficient or do not exist at all. There are three important steps to ensuring safe raw milk, according to the Raw Milk Institute:

  1. Farmer training and mentoring.
  2. Farm-specific risk management plan.
  3. Rigorous bacterial testing standards.

Raw milk produced according to stringent RAWMI Common Standards meets safety standards set for milk which has been pasteurized:

Total Coliforms/ml.Standard Plate Count/ml.
RAWMI Common Standards, Raw Milka rolling 3‐month average of <10a rolling 3‐month average of <5,000
U.S. (Federal), Pasteurized Milk<10<20,000
British Columbia, Pasteurized MilkNot to exceed 1 more frequently than twice during the last 6 consecutive testsNot to exceed 10,000 more frequently than twice during the last 6 consecutive tests
California, Pasteurized Milk<10<15,000
New York, Pasteurized Milk <10 <20,000
New York, Pasteurized Frozen Desserts <20 <100,000
Note: Coliforms and Plate Count are indicators of the amount of microorganisms present in the milk.

Actual test results from RAWMI-Listed Farmers have been gathered by the Raw Milk Institute. This chart shows that raw milk can be produced as safely as pasteurized milk, when these standards are followed. (Test-Results-from-RAWMI-LISTED-Farms).

coliform-count
spc-count

Test results and food safety plans for Listed farms are published on the RAWMI website, so consumers can see for themselves that the farm from which they obtain their milk meets these stringent safety standards.

BC Fresh Milk Project

The BC Fresh Milk Project, sponsored by the BC Herdshare Association, has arranged for the testing of raw milk samples from grassfed microdairy farms across British Columbia. Farms send samples to an independent microbiological laboratory, MB Labs in Sidney BC. As of December 24, 2021, 220 samples have each been tested for the four pathogens (harmful bacteria) most frequently associated with dairy-related outbreaks:  Campylobacter, Salmonella, E.Coli STEC, and Listeria monocytogenes. All 880 pathogen tests have been negative—no pathogens found. Not all farms participating in the project are RAWMI-listed but, other than a few one-time participants, they are either fully RAWMI-trained or are “in-training,” being provided with mentoring and peer support to achieve these results.

RAWMI Standards Prevent Outbreaks

Providing further evidence of the effectiveness of these standards, data from Pennsylvania show that even a one-day RAWMI training workshop was able to prevent outbreaks:

Milk diseases outbreakes

More Information on Safety

Raw milk producers with high levels of hygiene and safety | Epidemiology & Infection | Cambridge Core