– OPINION –

By Sara Bratager
Food Traceability and Food Safety Scientist at the Institute of Food Technologists 

According to a 2017 study in Emerging Infectious Diseases, unpasteurized dairy products cause 840 times more illnesses and 45 times more hospitalizations than pasteurized products, making raw milk a dangerous food. And yet legislation legalizing raw milk is emerging in numerous states. 

Bills to introduce or expand the sale of raw milk have cropped up in Iowa, Missouri, and Georgia in the last year alone. And they appear to be driven largely by consumer demand. The public comments on SSB 3126 — Iowa’s bill proposing to legalize on-farm sales of raw milk — are dominated by consumers’ desire to support local farmers, keep money in local economies, and reap the perceived health benefits. 

Some perceived raw milk health benefits — claims of superior nutrient content over pasteurized milk, for example — proved fictitious. Other benefits like probiotics, though potentially real, indicate food safety issues. Bifidobacterium are desirable probiotic organisms that do not occur naturally in milk. They are, however, commonly found in cows’ gastrointestinal tracts (i.e., fecal matter) and can be introduced into raw milk during the milking process. 

In fact, a 2018 study in Trends in Food Science & Technology found raw milk to be responsible for almost three times more hospitalizations than any other foodborne illness. With health implications in mind, it’s essential for consumers and policymakers, alike, to understand the need for pasteurization.  

Raw milk can also host a variety of human pathogens like Salmonella, E. Coli, Campylobacter, and Listeria. Sources of bacterial contamination include the environment, milking equipment and cows’ udders. Pasteurization is the only effective method of killing these harmful bacteria, but there are myths that lead consumers to believe that raw milk is safe such as: 

The Myth: Raw milk naturally contains antimicrobial compounds that make it safe. 

The Facts: While raw milk does in fact contain some antimicrobial compounds, they cannot be relied upon to ensure safe products. Lactoferrin occurs in concentrations too low to have a bactericidal or bacteriostatic effect. And Lactoperoxidase is only effective when activated by the addition of thiocyanate and hydrogen peroxide. An abundance of nisin, an antimicrobial peptide produced by Lactococcus organisms, is not only indicative of cold-chain issues (Lactococcus grow at warm temps) but it’s also ineffective against gram negative bacteria like salmonella, E. coli, and campylobacter.  

The Myth: Raw milk produced under a Hazard Analysis and Critical Control Point (HACCP) plan or other food safety plan is safe to drink.

The Facts: Raw milk produced under a food safety plan is likely safer than raw milk produced with no food safety protocols in place; however, it is not necessarily safe. Raw milk HACCP plans can adequately control for physical and chemical hazards at the farm level, but not biological hazards. Adequate control of biological hazards (pathogens) requires a kill step (pasteurization). “Test and Hold” programs help identify and prevent the spread of raw milk contaminated with pathogens. However, it’s not always possible to detect low levels of pathogens that could grow and multiply through the product’s shelf life. 

The Bottom Line: Raw milk carries real risk. 

Financial risk exists for every actor in the raw milk supply chain while consumers also risk illness — and severity can range from mild diarrhea and vomiting to miscarriage, hospitalization, and death. The very young, very old, pregnant, and otherwise immunocompromised have an increased chance of developing severe illness. 

Food safety advocates frequently reference two CDC studies that documented 127 outbreaks between 1993 and 2012. Both outbreaks and data collection have continued into the present, and data available on the CDC’s NORS database shows 47 outbreaks associated with raw milk from 2016 to 2020. As part of these 47 outbreaks, 435 illnesses, 69 hospitalizations and two deaths were reported with these outbreaks; however, the true number of impacted consumers was likely much higher due to under-reporting of mild cases. 

Though the consumption and sale of raw milk is inadvisable at best, raw milk legislation will continue if demand prevails. It is extremely important that proposed legislation include food safety measures to ensure that raw milk is produced as safely as possible. Development of full supply chain traceability programs is needed to mitigate potential spread of harmful product as even raw milk produced with the utmost caution is at high risk for pathogen contamination. Consumer safety depends on it. 

Author: Sara Bratager, Food Traceability & Food Safety Scientist at the Institute of Food Technologists

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