Personal choice and community impacts

Submission 224

Freedom of Choice:
The Case for Certified Raw Milk

Australian Raw Milk Movement Incorporated

Version 1
24 August 2015
 Personal choice and community impacts
Submission 224

This report is intended solely for informational and educational purposes and not as
personal medical advice. Please consult your health care professional if you have any
questions about your health.
The report has been prepared with care and attention to accuracy. Any errors in the
reporting or analysis of facts are unintended.

Australian Raw Milk Movement Incorporated

8 Harker Street
Alphington Vic 3078
https://www.facebook.com/AusRawMilk

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Submission 224

Contents

In short 4

Why is certified raw milk banned in Australia? 6

Why certified raw milk is safe 8

Raw milk around the world 10

The many health benefits of raw milk 14

Nurturing a certified raw milk industry in Victoria 18

Appendix 1: Pasteurisation and food safety, then and now 19

Appendix 2: Meet the pathogens 23

References 25

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk In short

In short

Every Australian state and territory prohibits the sale of raw milk for human consumption. The
grounds for this restriction are spurious. Prohibition is a denial of informed personal choice,
and at odds with scientific and consumer evidence from around the world. In this document the
Australian Raw Milk Movement makes the case for legalisation of certified raw milk.

 Certified raw milk is valued and legal almost everywhere in the world. Only Australia
and Canada forbid it.

o Raw milk has been legal in New Zealand for 60 years, and will be more widely
available from March 2016.
o Two hundred dairy farmers in England and Wales are registered to produce raw
milk and other dairy products.
o The British Royal Family has drunk raw milk for centuries.
o About ten million Americans drink raw milk. In many American states it is sold
in retail stores.
 Australia’s ban on raw milk is based on an incomplete risk assessment by Food
Standards Australia and New Zealand (FSANZ), which greatly exaggerated the risks to
public health of raw milk.

o FSANZ’s contention that raw milk is too dangerous to consume is not supported
by evidence—where are the grave public health disasters in the numerous
countries where raw milk is legal?

o FSANZ is out of step with international experts in this area.

 The New Zealand government was not persuaded by the advice of FSANZ and CSIRO
on raw milk, and is expanding raw milk sales in line with world best practice.
o New Zealand is moving ahead, assisted by the latest rapid on-farm milk testing
technology. Its raw milk is safer than other ready-to-eat foods, and at least as safe
as pasteurised milk.
 The States are not bound to follow the
Australian Food Code on raw milk.
The food choices of Australians are
being decided on bad advice based on
unverified risk estimates.

 Each State is free to amend its Dairy

Act, and if necessary its Food Act, to
permit the sale of raw milk. Four
states have already legalised raw
goat’s milk, using similar provisions.

 There is considerable confusion about

the risks posed by certified raw milk,
compared with milk from dairy
factories.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk In short

o They are separate products. Neither is a threat to public health.

o Milk produced to the highest standards of farming and hygiene is safe to drink
in the raw form.
o Certified raw milk reaches its consumers rapidly, often straight from the dairy.
Properly refrigerated, it keeps for well over a week. There is no need for longer
shelf life. Homogenisation is unwanted and unnecessary.
 Australia is blessed with conditions as good as any in the world for certified raw milk
production.
o Herds are free of the major diseases of concern for human health.
o Climate and soils allow grazing year round.
o Education and infrastructure support services are world class.

 Health conscious Australians have much to gain from consuming raw milk when it is
produced to the same demanding standards that apply in other countries.

 Few foods support our immune system as well as raw milk does. Raw milk from healthy
cows is a super-food, rich in nutrients and beneficial bacteria to keep our immune
systems healthy and strong.

 Raw milk is highly nutritious and has the potential to reduce illness and death from
serious diseases—there is sound evidence that it protects against asthma, allergies, and
respiratory infections, improves lactose tolerance, and is more easily digested by people
with trouble digesting dietary fat. It is richer in available nutrients than pasteurised
milk. Its vitamins have greater biological activity.

 People should be free to consume the foods they believe are most healthy, a principal
upheld by the Ontario Court of Justice.1

 A profitable, well supported addition to the dairy industry is ready to flourish, but is
blocked by current legislation.

 We invite State governments to support innovative dairy producers looking to diversify

with safe, high quality products, instead of driving a product like raw milk onto the
black market, where safety is less assured.

 Banning raw milk is unnecessary and unworkable, as consumers will continue to find
ways to get it. History tells us that prohibition does not work.

The Australian Raw Milk Movement calls for swift action by State governments to allow safe,
regulated trade in certified raw milk. We believe State legislation and regulations should
encourage research, while promoting consumer choice and freedom of exchange.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Why is certified raw milk banned in Australia?

Why is certified raw milk banned in Australia?

Raw milk is banned because health and regulatory agencies have deemed it more dangerous
than almost any other food. Of all the thousands of foods that cause illnesses, certified raw milk
has been singled out for exclusion from the diets of Australians, unless it comes from their own
cows.

Behind this extreme position is a risk assessment by Food Standards Australia and New
Zealand (FSANZ), which declares that raw milk cannot be made safe for human consumption,
no matter how carefully it is produced.2 The Australian Raw Milk Movement accepts that raw
milk, like any food, can become contaminated and cause illness. However, such events are
extremely rare. No food can be declared 100 per cent safe. And the dangers of certified raw milk
have been hugely exaggerated.

Our position is that FSANZ’s risk assessment is simply not believable. Where is the widespread
incidence of illness and death among raw milk drinkers in New Zealand, the UK, and the USA,
where consumption of certified raw milk is on the increase? Or right here in Victoria, during the
many years when significant numbers drank ‘bath milk’? Either there are thousands of
unreported illnesses and numerous unreported deaths around the globe, or the predictions by
FSANZ are flawed.

In the Weekend Australian Magazine of 10 December 2011, Mark Whittaker wrote as follows:

Modelling by Food Standards Australia New Zealand predicted that if raw milk were sold in retail
outlets, every 100,000 serves of 540 mL to a child would produce “97 cases of EHEC [an E. coli-
related illness], 153 cases of salmonellosis and up to 170 cases of listeriosis”. There are probably
more than three million such serves of bath milk being sold each year. If people are drinking it and
feeding it to their children, and they are, there should have been thousands of cases by now. I
contacted the various health authorities in each state to find the dead, or at least the sick.
The last known case of illness from raw milk was in 2003 at a school. There were eight outbreaks
between 1995 and 2003. Four of those involved school camps where raw milk was served
presumably to children who weren’t used to drinking it, two other outbreaks involved farm visits,
and only one claimed outbreak involved retail bath milk—the disputed Pet’s Milk outbreak of
2001. Out of all these outbreaks, four people were hospitalised. In 1976, 500 people in Whyalla,
South Australia, had salmonella poisoning, 95 per cent of whom said they’d drunk raw milk. There
were no deaths. By way of comparison, there are 11,500 cases of food poisoning every day in
Australia, killing about 120 people a year.

[In Whyalla, less than a third of the affected individuals tested positive for Salmonella,3
calling into question the conclusion that a single factor caused this outbreak. Other factors
were likely involved, which explains why the South Australian health authorities did not
ban raw milk sales at that time. Raw milk sales remained legal for a further 24 years, until
2000.

Moreover, the infective dose for this type of Salmonella is very high. Milk contaminated at
that level would be spoilt and unpleasant to drink.4 The regular testing mandated for
certified raw milk producers in other countries is intended to detect contamination of the
kind that is reported to have occurred in Whyalla.]

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Why is certified raw milk banned in Australia?

How did FSANZ get it wrong?

FSANZ took a theoretical approach which seriously disadvantaged raw milk. It started with
data from conventional milk intended for pasteurisation, and applied statistical methods to
estimate the risks from certified raw milk. If FSANZ had then compared its risk predictions
with public health records in countries that regulate production of certified raw milk it would
have discovered its mistake.

In short, FSANZ’s predictions are unverified, and demonstrably wrong. FSANZ should
abandon its flawed assessments, and gather real world data from certified raw milk consumers
in New Zealand, the United States, and the United Kingdom. Perhaps in tacit recognition of this
issue, late in 2014 FSANZ wrote:5

The Australia New Zealand Food Standards Code (the Code) requires that milk is pasteurised or
equivalently processed to eliminate pathogenic bacteria that may be present. There is an
exemption to this processing requirement that allows for state and territory legislation to regulate
and permit the sale of raw drinking milk. No States or Territories currently have legislated to allow
for raw cow milk to be sold. However, raw goat milk is permitted for sale in four States:
Queensland, New South Wales, South Australia and Western Australia. States and territories will
continue to have scope to allow for the sale of unpasteurised milk.

Thus Victoria is not bound by the pasteurisation provisions in the Australian Food Code. Each
state is free to permit the sale of unpasteurised milk. The legalisation of raw goat’s milk by four
Australian states highlights the point that each state and territory can depart from the Code if it
chooses. Making certified raw cow’s milk available in Victoria is not complicated. Simple
changes to the Victorian Dairy Act and, if necessary, the Food Act, will permit the production
and sale of safe, certified raw milk. Many Victorian dairy farmers are already well equipped to
produce certified raw milk.
Recent win for artisan cheese makers shows the way?
For years FSANZ forced the pasteurisation of cheese milk, arguing that cheese made from raw
milk poses a significant threat to public health. This was supported vigorously by big
processors, ingredient and equipment suppliers, and industry associations. Small/artisan
cheese makers were disadvantaged because:

 the capital cost of pasteurisation equipment is significant ($50k+) for high-temperature

short-time methods, and batch processing is slow, typically taking 4–8 hours
 cheese made from pasteurised milk is typically bland—acceptable to large producers but
commercially damaging for artisan producers.

In 2015 the Australian Food Code was amended to allow raw milk cheese production.6 We
congratulate those legislators and regulators who used soundly-evidenced reasoning to bring
about this change. And we look forward to similar evidence-based decisions for producers and
drinkers of certified raw milk.

Illnesses and death linked to raw milk?

In December 2014 Victoria’s Chief Health Officer made public statements linking raw milk
consumption to five cases of gastroenteritis in children over the six months from May to
October. One of the children died. A causal link between these illnesses and raw milk was
implied, and amplified by the media. The Australian Raw Milk Movement notes the lack of
evidence of any clusters of illness. The Coroner is yet to report.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Why certified raw milk is safe

Why certified raw milk is safe

Raw milk is the only food that combines built-in anti-pathogen mechanisms with numerous
components to create a healthy immune system. It contains components that assist in:7

 killing pathogens that have contaminated the milk: complex biological and chemical
systems (which begin to be destroyed by heat at 56°C) play an essential role in the
killing of pathogens by macrophages. The system is known to include lactoperoxidase,
lactoferrin, leukocytes, macrophages, neutrophils, antibodies, medium chain fatty acids,
lysozyme, vitamin B12 binding protein, bifidus factor, and beneficial bacteria
 preventing pathogen absorption across the intestinal wall: polysaccharides,
oligosaccharides, mucins, fibronectin, glycomacropeptides, bifidus factor, beneficial
bacteria
 strengthening the immune system: lymphocytes, immunoglobulins, antibodies,
hormones and growth factors.

Pasteurisation destroys many of these anti-microbial and immune-enhancing components

(Table 1). Ultra-pasteurisation completely destroys them.8 Numerous studies have shown that
pathogens grow more slowly or die more quickly when added to raw milk than when added to
heat-treated milk.9 For a history of pasteurisation please see Appendix 1 on page 19.
Table 1. Destruction/reduction of built-in safety systems by pasteurisation
Component Raw Milk Pasteurised Milk
B-lymphocytes Active Inactivated
Macrophages Active Inactivated
Neutrophils Active Inactivated
Lymphocytes Active Inactivated
IgA/IgG Antibodies Active Inactivated
B12 Binding Protein Active Inactivated
Bifidus Factor Active Inactivated
Medium-Chain Fatty Acids Active Reduced
Fibronectin Active Inactivated
Gamma-Interferon Active Inactivated
Lactoferrin Active Reduced
Lactoperoxidase Active Reduced
Lysozyme Active Reduced
Mucin A/Oligosaccharides Active Reduced
Hormones & Growth Factors Active Reduced

Australian microbiologist Dr Ron Hull has given expert evidence about the safety of raw
milk.10 Dr Hull describes raw milk as having “two systems of immunity to pathogens.” The
first he calls “innate immunity.” This comprises a number of factors, such as a set of enzymes,
white cells (as in human blood), antimicrobial fatty acids, as well as mineral apatite complexes,
with antimicrobial activity. Dr Hull says the existence and function of this innate immunity is
well established in the scientific literature.

“The other system of immunity to pathogens in raw milk is the existence and growth of lactic
acid bacteria. These are the sort of bacteria that cause milk to sour (‘clabber’) or, when certain
strains are added, turn into kefir, yogurt or cheese (all edible and safe), if left at room
temperature. Since both of these immune functions of milk are severely compromised by
pasteurisation, pasteurised milk left at room temperature will ‘rot’ (and become unsafe) due to
the action of other types of bacteria which are not killed by pasteurisation. Pasteurisation kills
the lactic acid bacteria, the white cells and half of the enzymes, leaving the terrain clear for the
remaining bacterial types to multiply unhindered by competition,” Dr Hull says.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Why certified raw milk is safe

“Raw milk will always ferment to an acidic product—soured/clabbered milk—on storage, and
is harmless to consume; whereas pasteurised milk putrefies and will make one sick if
consumed. Little Miss Muffet’s curds and whey was simply soured milk, a commonly
consumed, nutritious and safe food.”

Dr Hull says that “farm fresh unpasteurised milk produced by grass- or hay-fed animals and
handled appropriately can be just as safe as pasteurised milk.”
Why modern methods of dairy farming ensure raw milk’s safety
Dairy farmers today take advantage of many advances that contribute to a dramatically safer
product. The most important is the eradication of diseases transmissible to people, in particular
brucellosis and tuberculosis. Other important factors are animal nutrition, including managed
grazing on well maintained pastures, herd health testing, effective cleaning systems, and
refrigeration. Inexpensive, fast, on-farm bacterial testing techniques are now available. Dairy
farmers can now ‘test and hold’ their milk before giving it the all-clear for distribution.
However, the value of this procedure needs to be balanced against delayed distribution to
customers.

Appendix 2 contains information about the micro-organisms of concern that are sometimes
found in milk (page 23).

A crucial aspect that distinguishes certified raw milk dairy farmers from factory supply dairy
farmers is the milking procedure, in particular cleaning the udder, and use of comprehensive
testing schedules. The essential aspects of the milking routine are well documented and
include:11

 washing off all soil and manure on the udder

 hand milking, checking and discarding of first milk in the teat of each quarter, with milk
from cows whose milk is not of a satisfactory standard kept separate from that for
human consumption
 pre-dipping teats with an approved anti-bacterial solution (most farmers use iodine).
Pre-dipping with iodine reduces standard plate counts and coliform counts in raw milk
by 5–6 fold
 drying all teats with paper towels before applying the cups.

When produced responsibly, certified raw milk is a low risk food. Food safety is the first
priority at any dairy producing certified raw milk. High quality pastures and healthy cows are
essential. Milking is done in a very clean environment. Once the milk is collected, it is
meticulously managed to minimise contamination. A reliable ‘cold chain’ of refrigeration is
essential.

The Australian Raw Milk Movement envisages that regulated raw milk producers in Victoria
will adopt and scrupulously follow formal risk management plans, as is done in countries
where raw milk is sold legally. Victorian dairy farmers with an interest in becoming certified
raw milk producers have formed an association, which will create and promote guidelines for
the production of safe, healthy, certified raw milk.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Raw milk around the world

Raw milk around the world

In many countries raw milk and products made from it have been part of the food culture for
centuries. Other countries are slowly developing carefully regulated raw milk industries. In the
United States about 10 million people legally buy and consume raw milk.12 There have been no
major illness outbreaks and no deaths from milk produced expressly for the certified raw milk
market.13

Certified raw milk in the United States: Organic Pastures Dairy Company
In California, 625 stores carry state-inspected, intensively tested, certified raw milk. It is a
thriving market. Individuals and families experience immune system recovery from all sorts of
gut-based and immune illnesses. Much can be learned about safe, regulated, profitable raw
milk production from the Organic Pastures Dairy Company (OPDC),14 and the Raw Milk
Institute.15 OPDC is an internationally recognised pioneer in raw milk food safety. The
following descriptions are taken from the OPDC website.

We are certified Grade A and inspected by California Department of Food and Agriculture. Grade
A is the highest standard for milk in California. We have to pass the bacteria and pathogen
standards that are meant for pasteurized milk, without pasteurizing. The coliform standard is 10,
standard plate count is 15,000 and pathogen standard is ‘Not Detected’ in all products all the
time. There are also rigorous quarterly inspections where our facilities and equipment are
inspected to ensure it is up to Grade A requirements and code. We have a great working
relationship with our California inspectors and they hold us to a high standard that we are proud
to achieve.
History of the OPDC Food Safety Program
Raw milk is naturally designed to be an extremely
safe, nutritious, complete food. It is up to the
dairyman (sic) and creamery team to maintain its
natural and inherent quality.
In 2007, OPDC collaborated with top researchers
worldwide including Dr Ron Hull of Australia, Dr
Caterina Berge UC Davis, and Dr Ted Beals MD of
Michigan to develop the beginnings of our current
Food Safety Program (RAMP, Risk Analysis and
Management Plan). Our RAMP is a ‘Grass to Glass’
comprehensive conditions- and risk-based
management system that assures consistent test
outcomes through audited daily checklist
verification of all non-critical, GMP, SSOP and CCP
raw milk safety elements. This management tool
allows for regular team meetings and discussions
to make any necessary changes to the plan as we
learn more about safety issues and assess data.
We extensively test our milk and our milk filters to
provide valuable information about our products
to assure they are pathogen free.
Our milk testing program
As part of our food safety plan, we use a local
state-approved lab to test our milk. We test daily

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Raw milk around the world

for the presence of coliforms and standard plate count. The coliform bacteria count is used as an
index of the level of sanitation employed in the handling and processing of milk products. The
standard plate count has long been the primary test for determining the bacterial density (quality)
of fresh raw or pasteurized grade A milk. We also test for pathogens weekly. In addition, local
state regulatory agencies test our milk for pathogens, standard plate count, and coliforms once a
month.

The company goes on to describe how it deals with animal health, by quarantining cows that
appear unwell, and applying a range of natural remedies.

Some of the 10 million drinkers of raw milk in the United States visit Organic Pastures Dairy
Company.

Across the USA:

 retail sales are legal in ten states
 on-farm sales are legal in fifteen states
 herdshares are legal in four states
 there is no law on herdshares in six states
 milk sales as ‘pet food’ are legal in four states (implying that human consumption is
feasible).
Thus, raw milk may be bought, or obtained through herdshares, in 39 out of 50 states.
Certified raw milk in the UK
In England and Wales, raw milk is sold direct by farmers from their farm shops and at farmers’
markets, but also by distributors if the sale is direct with the farmer, such as sales over the
internet (with overnight courier). There are no restrictions on raw cream, butter and other dairy.
Farms selling milk must be registered with the Food Standards Agency. In England some 200
producers are registered to sell certified raw milk.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Raw milk around the world

The British Royal family has consumed raw milk for hundreds of years. Prince Charles has been
quoted as saying that his grandmother lived to her 100th year thanks in part to her habit of
drinking raw milk.16

The Dairy Products Hygiene Regulations of 1995 state of raw milk:

an occupier of a registered production holding may sell such milk at or from the farm premises
where the animals from which the milk has been obtained are maintained, to: (a) the ultimate
consumer for consumption other than at those farm premises; (b) a temporary guest or visitor to
those farm premises as or as part of a meal or refreshment; or (c) a distributor.
A distributor may sell such milk: (a) in the containers in which he receives the milk with the
fastenings of the containers unbroken; (b) from a vehicle which is lawfully used as shop premises;
and (c) direct to the ultimate consumer.
Hook & Son—leading UK producer

Phil and Steve Hook produce certified raw milk and other dairy products in East Sussex. Phil
has been on the farm all his life, establishing the herd in 1959 and gaining tenancy in 1972. Phil’s
eldest son Steve joined the partnership in 1991. Phil and Steve sell milk on two local milk
rounds, at farmers markets in London, including Borough Market, in addition to offering a
pioneering nationwide delivery service. Here is how Hook & Son describe their quality control
and safety procedures on their website:17

To have a licence to sell raw milk we meet the standard three monthly laboratory tests that the
Food Standards Agency run on our raw milk. These tests are purely for the total viable bacteria
count (TVC) of the sampled milk and a 'coliform' test that detects how clean your milk is. In
addition to this we pay to have a sample of our raw milk, raw cream and raw butter tested every
week at a laboratory for TVCs, coliforms, presence of pathogens and other cleanliness checks. The
cost of these tests does mean that our milk overheads are higher but we feel that it is important
to have a weekly analysis of our produce to ensure that we are sending only the best quality
products to you.

Steve (left) and Phil Hook are among 200 licensed producers of certified raw milk in England.
Foil-capped ‘green top’ bottles are familiar to raw milk drinkers across the country.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk Raw milk around the world

We run our business in accordance with our HACCP (Hazard Analysis Critical Control Point) which
is a personalised, systematic preventative approach to food safety that has been drawn up with
feedback from our local Environmental Health officers. Our HACCP system is used at all stages of
the food chain, from milking the cows, preparation processes, cleaning and checks made along
the way, right up to packaging and distribution. All of our staff who either milk the cows, bottle
the milk, make cream or make butter are trained in food safety and hygiene to level 2 standard.
This is not a requirement but something that we have chosen to do and evidences how serious we
are about producing a good, clean product for our customers.
Our products are taste tested to understand how the flavours alter as the diet of the cows
changes through the seasons. Our cows are tested for tuberculosis annually and we have not
failed this test to date.
Certified raw milk in New Zealand
New Zealanders buy certified raw milk direct from dairy
farms, some of which operate vending/dispensing
machines. For example, dairy company Village Milk on
New Zealand’s South Island sells up to 300 litres of raw
milk a day from its on-farm vending machines, with a
rigorous focus on safety, including extensive testing
under a risk management plan. In four years of operation
there have been no health problems among customers.
Currently, New Zealanders are allowed to buy up to five
litres of raw milk a day at a cost of $NZ2.50 per litre.18

Wider distribution and a revised regulatory framework

were reviewed recently, with a focus on testing, quality
thresholds, monitoring processes, public education, and
secure and safe delivery of milk. As a result, new
arrangements for certified raw milk were announced by
the New Zealand government in June 2015, coming into
effect in March 2016. Importantly, home deliveries will be
allowed for the first time, in addition to the established
farm pickup system. New registration and milk testing
provisions will apply to raw milk producers. People who make cheese for their families will be
able to buy as much raw milk as they want, and sales limits on farmers will be lifted.

Here is the viewpoint of the Raw Drinking Milk Producers Association of New Zealand:19

The test results our producers (and others around the world) are achieving are better than other
ready-to-eat food. Systems have evolved to such a point that producers in NZ and overseas are
achieving exceptional results, equal to or better than any processed milk. Emerging technology
will allow easier and more regular testing at affordable prices, giving producers and consumers
confidence that raw drinking milk is at least as safe as other food groups.
Raw milk is a food. As such it no longer needs exemption from the current laws in this country.
But it does not deserve to be singled out either, and we suggest it should get the same treatment
as all other fresh perishable food. We also ask that a clear distinction be recognised between raw
drinking milk, and raw milk produced for factory supply for further processing. This distinction
needs to flow right through from the regulatory process, all the way to the reporting processes, so
that in the future any raw milk illness reported recognises the difference. The Association is very
interested in being constructive in developing solutions to enable easy access to safe raw drinking
milk for all New Zealanders who want it.

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk The many health benefits of raw milk

The many health benefits of raw milk

Fresh, clean raw milk is nature’s perfect food—a single food that nourishes an infant mammal,
meeting all of its needs: energy, immune system development, and gut maturation—including
the development of a normal gut microflora. As an intelligent species, humans are fortunate to
be able to enjoy this living food from other mammals for its myriad of health benefits for people
of all ages.

Some of the oldest records of the human consumption of milk from other species date back
30,000 years to near the Red Sea, where people bred antelope for their milk.20 It is thought that
6000 years ago Neolithic farmers in Britain and Northern Europe were among the first to begin
milking cattle for human consumption.21 Galen, Hippocrates, Pliny, Varro, Marcellus,
Empiricus, Bacchis and Anthimus, leading physicians of their day, all used raw milk in the
treatment of disease.

At the dawn of nutritional science, respected researchers like Justus von Liebig (1803–73) held
the widely accepted opinion that food contained only proteins, carbohydrates and fats. It is not
surprising that diseases of nutritional deficiency such as rickets, pellagra, beriberi and scurvy
were common at this time. Nutritional science has come a long way in the past 150 years. We
now know that a healthy diet contains a wide variety of nutrients, including minerals, vitamins,
enzymes, pre-biotics and probiotic bacteria, which are essential for healthy digestion and body
functions. Consuming living foods such as raw milk, which complement and support the
microbes that live in our digestive systems, supplies our bodies with more than just proteins,
carbohydrates and fats. Current research into the human microbiome is perhaps the most
rapidly growing area of mainstream nutritional health and research. The normal gut flora form
the largest metabolic organ in the body and are essential for good health.

Benefits found in early human and animal studies

In early studies involving humans, raw milk was shown to be superior to pasteurised milk in
protecting against infection, diarrhea, rickets, tooth decay and tuberculosis; children receiving it
grew better than those receiving pasteurised milk.22

In early animal studies, animals fed raw milk had better growth, denser bones, greater integrity
of internal organs, less anaemia, fewer signs of anxiety and stress, and fewer signs of nutrient
deficiency than animals fed pasteurised milk.23
The ‘milk cure’
During the 1920s, Dr J.E. Crewe of the respected Mayo Foundation in the United States used a
diet of raw milk to treat allergies, skin problems, tuberculosis, oedema, heart failure, high blood
pressure, prostate disease, urinary tract infections, diabetes, kidney disease, chronic fatigue and
obesity, by giving his patients up to 8 litres of raw milk per day. Pasteurised milk was not
effective.24

With the growing use of antibiotics in the 1940s, nutritional research veered away from whole
food approaches, focussing instead on the development of pharmaceutical drugs. While no-one
can deny that modern drugs have saved many lives, the abandonment of therapies based on
whole foods with proven nutritional and health benefits is unfortunate and represents a loss to
modern medicine. Today, raw milk therapy is provided in many German hospitals.25

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Submission 224

Freedom of Choice: The Case for Certified Raw Milk The many health benefits of raw milk

Consumption of pasteurised milk has been linked to ear infections, gastro-intestinal problems,
diabetes, auto-immune disease, attention deficit disorder and constipation. Some people cannot
tolerate pasteurised (and ultra-pasteurised) milk.26 More research is needed on these
observations.

Protection from asthma, allergies and respiratory infections

European studies since 2001 point in the same direction: raw milk provides powerful protection
against asthma, allergies, and eczema.27 A study published in 2015 found that raw milk protects
against respiratory infections as well.28 Researchers followed almost 1000 infants from rural
areas of Austria, Finland, France, Germany and Switzerland for the first year of life. They
assessed consumption of different types of cow’s milk and the occurrence of rhinitis, respiratory
tract infections, ear infections and fever, from weekly health diaries.

The results were compelling. Early life consumption of raw cow’s milk reduced the risk of
respiratory infections and fever by about 30 per cent. The other milks were inferior—
industrially processed pasteurised milk, ultra-heat treated milk, and boiled ‘raw’ milk. The
researchers concluded that “the public health impact of minimally processed, pathogen-free
milk might be enormous, given the high prevalence of respiratory infections in the first year of
life and the associated direct and indirect costs.” Australian governments should explore the
potential for certified raw milk to reverse the escalating cost of diet-related degenerative
diseases.

Raw milk has the potential to protect millions of people from asthma and prevent hundreds of
asthma-related deaths, without increasing the total burden of food-borne illness. These
aspirations need to be evaluated with high-quality clinical research, which the Australian Raw
Milk Movement believes is more likely to proceed if the government re-evaluates its opposition
to raw milk.
Cow’s milk allergy in infants and children
Cow’s milk is the most common food allergen in infants and young children. It affects up to one
in twenty children under three years.29 Indeed, as milk is a common allergen, its presence must
be declared on food labels.30 Access to legal, regulated raw milk may help some of these
children thrive. The Australian Raw Milk Movement would like to see further research
comparing the allergenic properties of raw and pasteurised milk.

Lactose intolerance
In a survey of raw milk drinkers in the state of Michigan USA, over 80 per cent of those advised
by a healthcare professional that they were lactose intolerant were able to consume raw milk
without problems.31 On the other hand, a small pilot study by Gardner and others at Stanford
University reported no benefit of raw milk among the 16 adults in the trial, which ran for only
eight days.32 Further research is needed to account for the large numbers of people who report
that they cannot tolerate pasteurised milk but thrive on raw milk.33

Nutrients less available

Pasteurisation decreases the availability of iron, copper and manganese, and may diminish the
availability of calcium and phosphorus. Pasteurisation causes major losses of biological activity
for vitamin C and folate, substantial losses of vitamin B6, and may have similar effects on other

15
 Personal choice and community impacts
Submission 224

Freedom of Choice: The Case for Certified Raw Milk The many health benefits of raw milk

vitamins (Table 2). Effects on iodine are not conclusive.a Pasteurisation destroys beneficial
enzymes that digest the milk fat and milk caseins. Undigested milk products lead to allergy and
disruption of the microbiome in our digestive systems.

Changes to the bio-availability of micro-nutrients in pasteurised milk can be subtle and difficult
to measure with traditional chemical methods. For example, pasteurisation changes the bio-
availability of magnesium in milk, dramatically affecting the dynamics of virus–bacteria
interactions known to be important in cheese making.34,35

Table 2. How pasteurisation affects the nutrients in raw milk

Component Affect of pasteurisation

Vitamin C Raw milk but not pasteurised resolves scurvy. “Without doubt the explosive
increase in infantile scurvy during the latter part of the 19th century coincided with
the advent of use of heated milks.” Rajakumar, Pediatrics. 2001;108(4):E76
Calcium Longer and denser bones on raw milk. Studies from Randleigh Farms, chapter
14.
Folate Carrier protein inactivated during pasteurisation. Gregory. J. Nutr. 1982, 1329-
1338.
Vitamin B12 Binding protein inactivated by pasteurisation.
Vitamin B6 Animal studies indicate B6 poorly absorbed from pasteurised milk. Studies from
Randleigh Farms, chapter 14.
Vitamin A Beta-lactoglobulin, a heat-sensitive protein in milk, increases intestinal absorption
of vitamin A. Heat degrades vitamin A. Said and others. Am J Clin Nutr.
1989;49:690-694. Runge and Heger. J Agric Food Chem. 2000 Jan;48(1):47-55.
Vitamin D Present in milk bound to proteins (lactoglobulins); pasteurisation halves
assimilation. Hollis and others. J Nutr. 1981;111:1240-1248; FEBS Journal 2009
2251-2265.
Iron Lactoferrin, which contributes to iron assimilation, destroyed during
pasteurisation.

Minerals Bound to proteins inactivated by pasteurisation; Lactobacilli, destroyed by

pasteurisation, enhance mineral absorption. Br J Nutr 2000 84:S91-S98;
MacDonald and others 1985.

Finally, a word from the young…

Premature babies and infants fed raw breast milk gained weight more quickly than those on
pasteurised breast milk.36

Calves raised on pasteurised milk do poorly. Many die before maturity. Dairy farmers are
aware of this problem, which was investigated by Scottish researchers many years ago.37 This
observation challenges the contention that raw and pasteurised cow’s milk are nutritionally
equal.

a
Wheeler et al. 1983. J Dairy Sci.66(2):187–95.This report cited three studies showing 20 per cent loss of iodine in heated milk,
and another showing 40 per cent loss of iodine in spray-dried milk. Wheeler et al. did not confirm these findings, stating "this
discrepancy may reflect the difficulty of measuring iodine concentration of milk accurately."

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 Personal choice and community impacts
Submission 224

Freedom of Choice: The Case for Certified Raw Milk Nurturing a certified raw milk industry in Victoria

American raw milk consumers check out the mobile milking parlour at Organic Pastures Dairy
Company in California.

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 Personal choice and community impacts
Submission 224

Freedom of Choice: The Case for Certified Raw Milk Nurturing a certified raw milk industry in Victoria

Nurturing a certified raw milk industry in Victoria

Small dairy farmers stand to gain significantly from legalisation of certified raw milk. These
small farmers are struggling, as the supermarket price wars force them to accept prices near or
even below the fair cost of production. In 1980 Australia had 22,000 dairy farms; in 2010 there
were only 750038—a number that continues to fall annually.

Farmers producing certified raw milk can command far greater prices per litre than they would
get from milk processors. Even small-scale certified raw milk producers can be viable, as
overseas experience shows.b Australian dairy farmers are currently denied access to this
profitable niche market.

How might certified raw milk production unfold in Victoria? Small producers could be
profitable and rely solely on direct sales at the farm. Larger producers could sell at markets. Yet
others would gear up for retail distribution and home deliveries. Pathogen testing programs,
already well established in most cases, would match the risks attached to these varying scales of
production.

A certified raw milk industry would lift demand for support services such as artificial
insemination, dairy machinery sales and services, and refrigeration. Certified raw milk does not
need factory processing, with its intensive heating and cooling, and high water consumption
and chemicals for cleaning complex equipment—a net gain for the environment.

Certified raw milk producers can interact with families visiting their farm or buying direct from
them at farmers’ markets. Many people prefer to buy locally sourced foods directly from the
people who produce them. This worldwide trend is expanding. Direct sales invite trust in
quality, and allow customers to report back to the farmers. Both sides of the trade become better
informed, and enjoy the social interaction.

The Australian Raw Milk Movement estimates that weekly sales of ‘bath milk’ in Victoria stood
at about 17,000 litres per week in 2014. A small group of dairy farmers supplied that market,
carefully monitoring the quality of their milk. They and others are well placed to launch a fully
regulated certified raw milk industry.

Raw milk consumers are not food faddists. Typically they are well informed about nutrition.
They make informed choices to buy raw milk. In the absence of sound evidence that raw milk is
dangerous, how others judge these choices, how people interpret the nutritional science, are less
important than the right to choose freely. People want raw milk and will travel long distances
to get it, willingly paying far more than supermarket prices. These families know what they are
doing. The Australian Raw Milk Movement says they should be free to choose.

b For example, although selling raw milk is heavily penalised in Canada, Michael Schmidt in Ontario milks just 30 cows to

supply the herd’s owners in Toronto, under a ‘herdshare’ scheme, producing a gross income of CAN$350,000.

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Freedom of Choice: The Case for Certified Raw Milk Appendix 1: Pasteurisation and food safety, then and now

Appendix 1: Pasteurisation and food safety, then and now

Pasteurisation was one approach to a milk hygiene crisis that peaked as the industrial
revolution gathered pace.

The 1800s brought rapid industrialisation across Europe and the mass movement of
populations to cities. Overcrowding and poor nutrition, without understanding of the need for
sanitation, or infrastructure to prevent pathogen spread, were a public health disaster. These
were the days of slops buckets; open sewers; rodent infestations; open privies shared between
multiple families; and sealing the dead in walls. These factors increased susceptibility to disease
and allowed easier spread of pathogens. Engineering works separating sewage and drinking
water greatly reduced disease transmission from around 1900.

Food adulteration was a constant public health issue. The most common method of adulterating
retail milk was (and still is) the addition of water. Most of the infectious human pathogens
(Salmonella, E. coli Shigella, and Campylobacter) are water-borne. Pasteurisation resolved this
problem and allowed dairy factories to sell diluted product while minimising public health
dangers.

Inevitably, population movement also resulted in the loss of the ‘house cow,’ and the need for
transportation of milk—the beginnings of industrial dairying. Few farms had milking machines,
which were in any case technically crude. Often there was no running or clean water for
cleaning equipment, and milk vessels were cleaned (if at all) by hand. There was no
refrigeration.

These were dark times for dairying, which abandoned traditional methods of dairy cow and
milking hygiene that have been validated by science and form the basis of the farming
principles followed today by suppliers of certified raw milk in other countries—and by some
Australian producers.
Poor nutrition of cows
Many cows suffered from poor feeding practices, which were bad for their health and their
milk. In the early 19th century, the alcohol distillery business in the United States began to grow.
Large amounts of swill (spent grains) were produced as a by-product of whisky and other
alcohol production. Many distilleries opened dairies and began feeding their dairy cows with
the waste swill. The low nutritional content of the swill led to sickness in the cows and in the
humans who drank their milk.

A historian of milk at this time writes:

During the industrial revolution in the first half of the 19th century, the European population
doubled, and the proportion of city dwellers rose to 50 per cent. Industrialization and
urbanization jeopardized infant nutrition during the 19th century. Cow’s milk was produced in the
cities or transported long distances under suspect conditions. Milk was contaminated with
bacteria or adulterated with water, flour, chalk and other substances. When distilleries
proliferated in the metropoles, their waste slop was fed to cows which then produced thin and
contaminated swill milk. This was exacerbated by prohibition because ‘milk shakes’ became the
next legitimate business of the distilleries and they paid little attention to hygiene. These were
the first generation of ‘industrial’ dairy farmers.39

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Freedom of Choice: The Case for Certified Raw Milk Appendix 1: Pasteurisation and food safety, then and now

Grain diets cause acid toxicity in ruminants; grain feeding must be strictly controlled to produce
hygienic milk.

Confined to filthy, manure-filled pens, the unfortunate cows gave a pale, bluish milk so poor in
quality, it couldn’t even be used for making butter or cheese.40

The same poor quality milk has been observed in Victorian dairies feeding vegetable waste and
cotton seed waste, when traditional feeds are too expensive. Milk composition changed. The
poor quality milk couldn’t even be used for cheese.41

Sickness and disease

The consumption of poor quality milk led to sickness and disease. During 1800s, the death rate
was as high as 50 per cent among urban children drinking ‘swill milk,’ that is, milk produced in
inner city confinement dairies, from cows fed brewery swill and raised in unimaginable filth.
Water (usually from a well or dam) was often added to milk to make it go further; chalk was
sometimes added.42 Such milk spread diseases like typhoid and tuberculosis.43

Satisfactory sanitation could not be achieved in the milking procedures and equipment. Dairy
inspectors were most concerned about unsanitary milking machines. Bacterial contamination
was common, because water around the dairies was often contaminated by nearby outhouses.44
US physicians launch the milk certification movement
In 1893 Dr Henry Coit of Newark, New Jersey, enlisted several other physicians and together
they formed the Essex County Medical Milk Commission. Thus was born the first Medical Milk
Commission and the certified milk movement.

Coit's plan included three general requirements. First, physicians in the local medical society
selected members of a Medical Milk Commission and supported their efforts to bring to the city in
which they lived a supply of milk produced under conditions that would assure purity. Second,
"approved and trustworthy dairymen possessing honor" would be induced, by reason of promised
medical support and an increased price of their milk, to produce and handle their milk in accord
with the requirements imposed by legal contract with the Medical Milk Commission. Third, the
Commission would set standards of purity for the milk and ensure that physicians made periodic
inspections of the dairies, the animals and the employees. The Commission would conduct
periodic chemical analyses and bacterial counts of the milk, so that it could be certified entirely
free of pathogenic organisms. Coit coined the term ‘Certified Milk’ to distinguish milk produced
through the operation of his distinctive plan.45

Dr Coit and his colleagues understood the importance of having the best quality raw milk
available for the ill—infants, children and adults alike. Other cities throughout the United States
began forming Commissions, and in 1906 the Commissions were federated into the American
Association of Medical Milk Commissions.

Certified raw milk, endorsed by a significant percentage of the medical profession and enjoying
strong support from legislators and the public, was thus established as the standard to which all
other milk was compared. Though more and more milk was being pasteurized, many saw
pasteurization as a stopgap measure that would no longer be necessary once more careful
regulation of the production and distribution of milk was in place. Certified milk became the
model for the production of better milk everywhere. In writings about milk throughout the first
half of the 1900s, time and again one finds references to the essential role the certified milk
movement played in raising the standards of the entire dairy industry. This is reflected in the rules
and regulations governing dairy production that have been codified in every state's laws, for both
raw and pasteurized milk.46

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Freedom of Choice: The Case for Certified Raw Milk Appendix 1: Pasteurisation and food safety, then and now

Dr Ted Beals described how the county Medical Milk Commissions became controversial over
subsequent decades because pasteurisation was not part of their standards.

As the commercial dairy industry pushed the requirement for pasteurisation, the local milk
commission came under direct fire because they did not include pasteurisation. There were
conflicts between the commissions, which wanted their standards adopted by the states, and the
industry, which insisted that pasteurisation was necessary to ensure safe milk. The commissions
were essentially focused on farm hygiene and hygienic handling of the milk. In their view
pasteurisation was unnecessary.47

Note that the Medical Milk Commissions were satisfied that raw milk was safe if farm hygiene
was good. Dairy manufacturers, on the other hand, promoted pasteurisation for two important
commercial reasons: they could take bulk milk from all farms (hygienic and unhygienic),
pasteurise it to clean it up, and safely sell it; and pasteurisation machines were expensive—if
made compulsory, competition from direct sales by farmers and small players would be
eliminated.48
New standards emerge
American standards for clean milk production did not appear until the early 1900s. One
significant accomplishment was a system of sanitation from which dependably clean milk could
be produced on any farm. This included dairy farm inspections, laboratory milk tests, and
statistical monitoring.49 An official history of the dairy industry in the United States describes
how:

[t]he pipeline milking system and bulk tanks replaced the bucket milkers and milk cans on dairy
farms in the 1960s. In 1965 federal and state milk regulations established a maximum of somatic
cells, which are a marker (measure) of mastitis, for grade A milk.50

Pasteurisation arrives in Australia

After a slow start, pasteurisation became common in Australia during the mid-1950s, a period
when milk still carried a risk of infection with brucellosis (eradicated in 1989) and tuberculosis
(eradicated in 1997). The introduction of pasteurisation in Australia was widely hailed as a
major contribution to public health.51,52

Dr Ron Hull’s praise is more muted. He says pasteurisation resolved problems of poor hygiene,
and cows sickened by poor diets. It was a solution to the mixing (‘co-mingling) of good quality
milk with poor quality milk from below-standard farmers—about 10 per cent Dr Hull says.
Milk from ten or more farms is combined in road tankers. One farm with poor quality can
contaminate the entire tanker load. This necessitates pasteurisation to produce a safe product.
Commercial processors have responded to this problem by testing suppliers’ milk daily and
applying penalties, resulting in three or more levels of payments, varying by 35 per cent.
Moreover, large commercial processors collect some milk selectively from particular suppliers
when high quality is demanded, as it is for some cheeses and milk powders.

Nevertheless, for bulk milk produced for the dairy factories, and manufactured for the
extended shelf life required by the long supply chain, pasteurisation is essential. And it must be
done before the milk is homogenised, to inactivate the natural fat-degrading enzyme (lipase).
Otherwise the action of this enzyme leads to a rancid flavour. Homogenised milk spoils fast if it
has not been pasteurised, because heating destroys the built-in safety factors (described earlier
in this report).53

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Freedom of Choice: The Case for Certified Raw Milk Appendix 1: Pasteurisation and food safety, then and now

Pasteurisation was seen by the industry as a ‘silver bullet’ to solve the health regulators’
problems. But sometimes the bullet misses its mark, as Dr Hull explains:54

In the 1960s, deaths of infants and babies from Salmonella infections caused by contaminated
milk powders led Australia, as well as New Zealand and South Africa, to seize an international
marketing advantage by mandating pasteurisation of all milk (not just drinking milk), as this was
seen as a watertight solution to the Salmonella problem—which was assumed to come from the
cows. This required the Dairy Acts to assign legal ownership of milk, at the point when farmers
removed it from their cows, to government-delegated authorities (Milk Boards). The Milk Boards
assigned the milk to licensed dairy manufacturers (co-ops and companies) for processing. State
Departments of Agriculture enforced this requirement for pasteurisation on all milk powder
plants, though not on cheese producers until around 1985.
However, Salmonella was not eradicated from the milk powders, though subsequent
investigations absolved the farms of blame. Contamination was occurring at the factories, after
pasteurisation, from bird droppings and dirty plant. Nevertheless, faith in pasteurisation was
maintained.
In the 1980s pasteurisation received another dent to its reputation. In Chicago a large number of
people died or fell very sick from Salmonella-contaminated drinking milk. The milk was produced
in a new ‘state of the art’ liquid processing milk plant owned by a supermarket chain. Despite all
the experts’ attempts to resolve the problem, the plant never restarted. This incident and others
led to significant revision of pasteuriser operation.

These problems do not discredit pasteurisation as a food processing technique. But they
demonstrate that it is not a guarantee of safety. No food can receive such a guarantee. Today
pasteurisation is a useful food safety tool in marketing bulk farm milk with a high probability of
including milk from diseased or stressed cows.

The Australian Raw Milk Movement believes that both certified raw milk and pasteurised milk
are safe foods, but should be considered as different products.55 We accept that under the
present system, regular factory milk must be pasteurised, despite the changes that causes.
Public safety is essential.

Laws compelling pasteurisation favour large, industrialised dairy operations and squeeze out
small farmers. However, when farmers have the right to sell safe unprocessed milk directly to
consumers, they can make a decent living, even with small herds.
Pasteurisation unnecessary for safety of certified raw milk
We have noticed much confusion about the risks posed by certified raw milk, compared with
retail pasteurised milk. Both products are safe, low-risk foods. Our point is that milk produced
to the highest standards of farming and hygiene is safe to drink in the raw form, as is obvious
from the successful certified raw milk industries in New Zealand, the United Kingdom, and the
United States.

Certified raw milk drinkers don’t seek extended shelf life. Homogenisation is unwanted and
unnecessary. Certified raw milk reaches its consumers rapidly, often straight from the dairy.
Properly refrigerated, it keeps for well over a week.

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Freedom of Choice: The Case for Certified Raw Milk Appendix 2: Meet the pathogens

Appendix 2: Meet the pathogens

The chance of finding any pathogens in carefully produced certified raw milk is remote. But it
can happen, even in pasteurised milk—no food can be made totally safe. So let’s now take a
brief look at the four pathogens responsible for most food-borne illness: Campylobacter jejuni,
Shiga Toxin producing E. coli (E. coli O157:H7), Listeria monocytogenes and Salmonella spp.c These
pathogens may be present in any food, including dairy.

Campylobacter, Salmonella, E. Coli and Shigella are water borne. Therefore water quality at the
dairy is vitally important, as well as the use of organic acid-based sanitisers, which are highly
toxic to these bacteria—they do not acquire resistance. Organic acids are traditionally used by
organic dairy farmers.56

Listeria is associated with putrefying vegetable and animal tissues, and is favoured by
refrigeration temperatures (long cold chain) where there is no competition from lactic acid
bacteria, which have a minimum growth/activity temperature of 7°C. It is for this reason that
fermented foods are safe above 7°C, but unpackaged, may become contaminated at
refrigeration temperatures used in supermarkets and their supply chains.57

Campylobacter jejuni
The most common pathogen currently associated with raw milk outbreaks is Campylobacter.
The virulent forms of Campylobacter can cause serious diarrhea. Campylobacter grows only
inside living animal cells. The most common source is the intestinal tract of poultry. Infected
chickens do not get sick, but they carry the organism in their faeces. Chicken meat can be
contaminated. The most common reservoir is water contaminated by poultry manure. People
with diarrhea caused by Campylobacter shed extremely high concentrations of the virulent
bacteria in their stools.

Unexpectedly, the potential risk, though extremely low, is increased with raw milk that is ‘too
fresh.’ Over time, the antimicrobial components of raw milk kill Campylobacter, so any
potential risk diminishes as the milk ages under refrigeration. Longer storage time and
exposure of the milk to air decrease the risk to raw milk drinkers. Keeping infected poultry and
people that carry Campylobacter away from milk-handling areas reduces the risk.

Campylobacter is the second most common cause of all human food-borne illness. The illness
usually goes away without treatment after a bout of unpleasant diarrhea, but there can be
severe complications in rare cases.

Data from the United States indicate that Campylobacter in raw milk is responsible for a minute
proportion of the cases of domestically acquired diarrhea caused by food contamination.58
Shiga toxin-producing E. coli (E. coli O157:H7)
This pathogen grows in the intestinal tract of mammals. The most common source is faecal
matter of infected humans. The most common reservoir is cows that are shedding virulent
subtypes. Factors that increase the risk to raw milk drinkers include dairy animals
contaminated with faeces from high-shedding animals, and milk handlers shedding during and
after infection. Factors that decrease the risk to humans include closed herds, managing dairy

c Most of this chapter is adapted from a presentation by Dr Ted Beals, a pathologist with decades of research experience in the

medical school of the University of Michigan http://www.realmilk.com/safety/those-pathogens-what-you-should-know/

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Freedom of Choice: The Case for Certified Raw Milk Appendix 2: Meet the pathogens

herds to minimise the spread of bacteria from colonised animals, and keeping people who are
shedding away from milk processing and herds.

In the United States, E. coli O157:H7 in raw milk is responsible for a minute proportion of the
cases of domestically acquired diarrhea caused by food contamination. The overall human
public health impact of E. coli O157:H7 is small, but highly publicised because of a rare illness
called haemolytic uremic syndrome.

The strains of E. coli implicated with haemolytic uremic syndrome are believed to have adapted
to the changed environment in the rumens of cattle fed diets with high levels of grain or other
by-products of food manufacture. If certified raw milk producers are required to feed their
animals a diet of predominantly pasture and/or hay, with only minimal grain and no by-
products, the risk of contamination with these strains can be eliminated.

Listeria monocytogenes
Listeria monocytogenes is the most serious and deadly of the contemporary food-borne
pathogens. Yet it is also widespread in our environment. Scientists understand a lot about the
factors that are necessary before certain subtypes of Listeria are able to cause disease.

Listeria can alternate between two growing modes: it grows in animal cells, or it can switch to
growing in decomposing plant materials. Listeriosis is a significant health problem in domestic
animals. The most common sources are poorly managed silage; amniotic fluid, placenta and
foetal tissues from abortions resulting from infection in cows; and meat processing plants and
their equipment.

The most common reservoir is the environment, particularly if cool, wet and undisturbed.
Listeria is present as well in our homes and on our bodies.

People regularly ingest Listeria without becoming ill. You must ingest huge numbers of a
virulent strain to cause gastroenteritis. Listeria in raw milk has never been a significant public
health risk. The most serious public health risk from Listeria comes from contaminated ready-
to-eat processed foods, particularly meats.

According to Dr Hull, there have been rare outbreaks associated with cheese, because of the
long processing times and storage conditions. This is a risk with cheese made from both raw
and pasteurised milk. In Australia, meat pâté is the major source of listeriosis, leading to revised
dietary recommendations for pregnant women—but meat pâté remains a legal food.
Salmonella spp
Salmonella grows inside animal cells as well as in food and feed with high protein content,
especially when stored in warm conditions. The most common source is infected humans and
animals, as well as contaminated animal feeds and re-warmed foods. The most common
reservoir is contaminated water. Inadequate refrigeration of raw milk increases the risk to
consumers; eliminating sources of Salmonella decreases the risk.

Salmonella is the most common cause of food-borne illness, but raw milk is implicated
extremely rarely.

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Freedom of Choice: The Case for Certified Raw Milk References

References

1
http://www.canlii.org/en/on/oncj/doc/2010/2010oncj9/2010oncj9.html See sections X180–X181 of the judgement.
2
Microbiological Risk Assessment of Raw Cow Milk. Food Standards Australia and New Zealand (2014)
3
Seglenieks & Dixon (1977) Morbidity and mortality weekly report 26(15) p127.
4
Dr Ron Hull, personal communication 2015.
5
Primary Production & Processing Requirements for Raw Milk Products, p4. Food Standards Australia and New Zealand
(2014).
6
http://www.foodstandards.gov.au/code/primaryproduction/dairy/pages/default.aspx
7
Scientific American, December 1995; Br J Nutr, 2000:84(Suppl. 1):S3-S10, S75-S80, S81-S89.
8
Ibid.
9
Doyle MP and Roman JD. Prevalence and survival of Campylobacter jejuni in unpasteurised milk. Appl Environ Microbiol.
1982;44(5):1154-8. Xiong J. Survival of Animal-derived Campylobacter Strains in Raw and Pasteurized Milk, and the Roles of
Capsule in Campylobacter Survival in vitro, and in Chick Colonization. MS thesis. Raleigh, NC: North Carolina State University.
2009. 65 Simms L, Mac Rae IC. Survival of Campylobacter jejuni in raw, pasteurized and ultra-heat treated goat's milk stored at
different temperatures. Lett Appl Microbiol. 1989;8(5):177-80. 66 Wang G, Zhao T, Doyle MP. Survival and Growth of
Escherichia coli O157:H7 in Unpasteurized and Pasteurized Milk. J Food Protect. 1997;60(6):610-3.
10
Adapted from https://thebovine.wordpress.com/2009/02/09/dr-ron-hull-phd-on-raw-milk-safety/.
11
Personal communication Mr Ray Ridings, Chair, Raw Drinking Milk Producers Association of New Zealand 2015.
12
http://www.westonaprice.org/press/government-data-proves-raw-milk-safe/
13
http://www.ruralvermont.org/wordpress/wp-content/uploads/2014/04/Dr-Beals-Summary-Testimony-Vermont-S70-2014.pdf
14
http://www.organicpastures.com/
15
www.rawmilkinstitute.org
16
http://www.realmilk.com/international-updates/
17
http://hookandson.co.uk/index.html
18
http://www.abc.net.au/news/2015-02-09/raw-milk-vending-machine/6080148
19
Personal communication Mr Ray Ridings, Chair, Raw Drinking Milk Producers Association of New Zealand 2015.
20
Schmid R. The Rise and Fall of Raw Milk. http://greenlivingjournal.com/page.php?p=1025 accessed 14 May 2015.
21
Historical Timeline, History of Cow’s Milk from the Ancient World to the Present.
http://milk.procon.org/view.timeline.php?timelineID=000018 accessed 14 May 2015
22
Powerpoint slides 54–56, 58 http://www.realmilk.com/safety/real-milk-powerpoint/
23
Real Milk PowerPoint slides 57, 59–64 http://www.realmilk.com/safety/real-milk-powerpoint/
24
A Campaign for Real Milk. The Weston A. Price Foundation. 2006. Washington, DC. http://www.realmilk.com/brochures/real-
milk-brochure/
25
http://www.realmilk.com/wp-content/uploads/2012/11/RealMilkTrifold.pdf
26
Don’t Drink Your Milk, Frank Oski, MD, 1983
27
Lancet. 2001 Oct 6;358(9288):1129-33; J Allergy Clin Immunol. 2006 Jun;117(6):1374-8; Clinical & Experimental Allergy.
2007 May; 37(5) 627-630; Clin Exp Allergy 2011; 41(1) 29-35; Current Opinion in Allergy & Clinical Immunology 2012; 12(2)
158–163.
28
J Allergy Clin Immunol 2015; 135 (1) 56-62.
29
http://www.cowsmilkallergy.co.uk/home/
30
http://www.foodauthority.nsw.gov.au/consumers/problems-with-food/allergy-and-intolerance/#.VX_cK1Ipffg
31
http://www.realmilk.com/health/lactose-intolerance-survey/
32
Ann Fam Med March/April 2014 vol. 12 no. 2 134–141.
33
http://thecompletepatient.com/article/2014/march/25/and-now-rest-story-stanford-raw-milk-lactose-intolerance-study

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34
Hull, RR & Brooke, AR (1982), Aust J Dairy Technol 37, 143.
35
Eddy, DW et al. (1986), Aust J Dairy Technol 43, 19.
36
J Pediatr Gastroenterol Nutr. 1986 Mar–Apr;5(2):248–53
37
JM Mercer. An Experiment in Milk Pasteurization. Nature's Path, March 1941. In Bryant CP. The Truth About Pasteurization,
National Nutrition League, Seattle, Washington, 1943.
38
The Australian Dairy Industry From family farm to international markets, (Price Waterhouse Coopers, 2011). Retrieved from
http://www.pwc.com.au/industry/agribusiness/assets/Australian-Dairy-Industry-Nov11.pdf
39
Obladen M. From Swill Milk to Certified Milk: Progress in Cow’s Milk Quality in the 19th Century. Ann Nutr Metab 2014; 64:80-
87.
40
Historical Timeline, History of Cow’s Milk from the Ancient World to the Present.
http://milk.procon.org/view.timeline.php?timelineID=000018 accessed 14 May 2015 .
41
Dr Ron Hull, personal communication 2015.
42
Schmid R. The Untold Story of Milk. 2009; NewTrends Publishing: Washington, DC.
43
Historical Timeline, History of Cow’s Milk from the Ancient World to the Present.
http://milk.procon.org/view.timeline.php?timelineID=000018 accessed 14 May 2015
44
Brown M and Ely LO. Dairy Industry. New Georgia Encyclopaedia; 9 September 2014. Accessed 18 May 2015
http://www.georgiaencyclopedia.org/articles/business-economy/dairy-industry
45
Schmid R. The Untold Story of Milk. 2009; NewTrends Publishing: Washington, DC.
46
Ibid.
47
Dr Ted Beals, personal communication 2015.
48
Dr Ron Hull, personal communication 2015.
49
United States Department of Agriculture National Agriculture Library. Research in the Private Sector. Accessed 15 May 2015
http://www.nal.usda.gov/exhibits/speccoll/exhibits/show/the-american-dairy-industry/research-in-the-private-sector
50
Brown M and Ely LO. Dairy Industry. New Georgia Encyclopaedia; 9 September 2014. Accessed 18 May 2015
http://www.georgiaencyclopedia.org/articles/business-economy/dairy-industry
51
Technology in Australia 1788–1988 p100; http://www.austehc.unimelb.edu.au/tia/100.html
52
Technology in Australia 1788–1988 p127; http://www.austehc.unimelb.edu.au/tia/100.html
53
Dr Ron Hull, personal communication 2015.
54
Ibid.
55
The Bovine. Ron Hull Ph.D. and Dr Ted Beals – Michael Schmidt’s expert witnesses. 26 December 2008. Accessed 14 May
2015 https://thebovine.wordpress.com/2008/12/26/ron-hull-phd-and-dr-ted-beals-michael-schmidts-expert-witnesses/
56
Dr Ron Hull, personal communication 2015.
57
Ibid.
58
Scallan E, Hoekstra RM, Angulo FJ, Tauxe RV, Widdowson M-A, Roy SL, et al. Foodborne illness acquired in the United
States—major pathogens. Emerg Infect Dis. 2011 Jan. Table 2 www.cdc.gov/EID/content/17/1/pdfs/09-1101p1.pdf

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