The future of raw drinking milk hangs in the balance

Watching the Board of the Food Standards Agency (FSA) discuss the Microbiological Safety of Raw Drinking Milk (as agenda item 4.2 was titled) and the proposed review of controls at its meeting last month was really rather depressing and the outcome entirely predictable.

The tone of the meeting was set when Tim Smith, Chief Executive of the FSA, declared an interest as  CEO of Arla Foods UK plc prior to his appointment at the FSA stating: “(M)y views on the sale and consumption of raw milk are a matter of public record.” He did not say what those views were, I googled them but couldn’t find them, but I can’t help but think it is probably safe to conclude that he is no supporter of the availability of raw milk to say the least. The interest declared, he did not feel it prudent to leave the meeting, as would have happened in most public bodies, which afforded him the opportunity of a light hearted exchange with Jeff Rooker, Chair of the Board, at the end of the discussion.

Alison Gleadle, Director of Food Safety, presented her report and quite fairly  made it clear at the start that there had been “no reported illnesses associated with raw drinking milk or cream in the UK for around 10 years.”

The present system of controls and background to the review were covered by Artisan Food Law in the run-up to the FSA Board meeting. There are two issues in particular that appear to have prompted the review – a raw milk vending machine in Selfridges department store and online internet sales of raw milk. Both are under the control of the farmer producer providing the milk so it is difficult to see what practical issues arise. Certainly no more than those with the milkman who can provide, and for many years in some areas has done so, overnight doorstep deliveries of raw milk.

Raw milk vending machine at Selfridges department store

Steve Hook beside his raw milk vending machine

Against this background, I have rarely observed so many members of a public body come to a conclusion before public consultation has even been launched. A few comments during the discussion:

“(I) made my mind up before reading it (the Director of Food Safety’s report to the meeting) that I was going to go with the idea that pasteurisation was by far the best.”

“I would look for a ban on the sale of raw milk.”

“I totally agree that pasteurisation has to be the way forward.”

Does this sound to you like a group of people intent on meaningful public consultation with an open mind? One member of the Board had even made up his mind before reading the Director’s report, never mind the public consultation! In fairness, the odd comment was made that tried to put things into some sort of more rational perspective:

“I’m not sure we should be overly worried and be bothering because I can’t see there’s a problem.”

One member did also rather tentatively raise an alternative view, pointing out there was nothing about sustainability in the report, which I took to mean diversity in food supply, and another, although somewhat patronisingly, referred to drinking raw milk as a cultural issue for “the farmers on the small farms who have done it for centuries.”

What were frequently referred to as the “inherent risks” of raw milk were never balanced by a single word about the possible benefits. Almost every conceivable activity on the planet carries inherent risks, the responsible way forward is to put in place prudent measures to manage those risks, which is what we have already. Crossing the road carries a risk but we have yet, for very good reason, to ban crossing the road.

The FSA must recognise its responsibility to protect consumer interests outside of the very narrow and blinkered approach it appears to be taking. It must take heed of issues of sustainability, diversity and community in place of the pursuit of sterile purity. If it continues down this road it will end up giving the regulation of food quality the same poor public image that the Health and Safety Executive managed to achieve, resulting in press reports of cutting down conker trees because the conkers may fall on your head and other daft stories. These may, for the most part, have proved to be myths but they reflected a widely held public view. If this happened to the FSA it will only serve to undermine the credibility of an otherwise important and essential body.

Finally, if raw drinking milk is lost, next in the frame will be cheese made from raw milk. Take note of Jeff Rooker, Chair of the FSA, in his closing remarks in the discussion:

“We know to our certain knowledge last year some farmers criminally switched ear tags from TB infected cattle so those cattle continued to put milk into the food chain and they sent other cattle to slaughter. Now I accept that milk in the normal course of events would have been pasteurised, but what if that milk had been had been supplied to cheese makers making cheese from unpasteurised milk?”

The FSA drew attention to this problem in March last year but raw milk production is subject to a much stricter control regime, this connection is misguided, but maybe it’s a case of raw drinking milk in the frame today, raw milk cheese tomorrow?

Some proposed changes may make sense. No one could sensibly argue that raw milk from different species should be treated differently. There ought to be appropriate safeguards in place for all raw milk, and if this is all about goats and sheep then it will prove to be the proverbial storm in a tea cup. The FSA should not, however, use this as an excuse for more far reaching change.

The members who questioned whether this review is a priority should have been heeded, focus on what really matters and makes a difference, harassing a 100 or so farmers trying to preserve a tradition that does no harm does the FSA no credit. How about making a real difference – put energy into addressing something worthwhile like, for example, cutting fat and salt in processed food to save an estimated 40,000 lives. Get the priorities right and use public money wisely.

Regrettably for now, the FSA gives no semblance of a group of people embarking on a public consultation with an open mind, raising fears the consultation will be a sham. It is almost impossible not to reach the conclusion that the FSA is simply trying to cover its back.

Oh yes, the light hearted exchange I mentioned at the outset. Jeff Rooker, Chair, quizzed those present if they knew why the statutory warning for raw milk did not refer to it not being ‘pasteurised’, nobody knew except Tim Smith who chuckled, kept it to himself, but indicated he would tell the Chair later, he had an interest after all, leaving us all to guess again.

It would have been hard to watch a more one-sided discussion, but don’t take it from me, you can watch the discussion for yourself. Meanwhile, drinkers and advocates of raw milk, and those who believe in the consumer’s right to choose should be very concerned.

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  1. Reblogged this on Artisan Food Law and commented:

    The raw milk debate continues …

  2. My grandparents were born between 1910 and 1920 in Italy: they loved traditional food and they have never failed to boil milk – even pasteurized milk – before providing (lots of) it to us children.

    Why did they do that? Because the safety of us children came first, no matter what. Has the situation changed in recent years in regard to raw milk? No, it has not. Quite consistently, in any jurisdiction where sales of raw milk have been somewhat liberalized and hence increased, there has been an increase in illnesses. In serious illnesses, particularly in children. A glaring example is Italy. Since the liberalization of 2007, raw milk vending machines have become popular; infecting children with devastating HUS has also become popular with E.coli O157. This is unsurprising as parents have been led to believe that raw milk provides extra benefits to their children (being trendy, more expensive and marketed as super-healthy), and so they feed it to their children. In my opinion, this is unacceptable even if raw milk had any proven benefit beyond taste, particularly when there is a safe, nutritious alternative, pasteurized milk. And I also wonder if adults consuming milk are really making an informed choice.

    Is possible to produce raw milk which is as safe as pasteurized milk? It seems very unlikely. Are adults entitled to risky behaviors? Yes, when properly informed, though I have doubts about the ethics of selling risky products to people, even if the consumer is willing.

    Mind, I have nothing against traditional, organic, local, artisan food, and I am no friend to big industry. I love and support it. However, there need to be priorities. Nothing is risk free, but I don’t let my children play where there’s traffic.

    A discussion should start from acceptability of risk. How many cases of illnesses do we accept from raw milk that consuming pasteurized milk would have prevented? I’d say none, at least in children, in the vulnerable and in uninformed adults. If this is agreed, we can discuss perhaps what should be done with raw milk to achieve that goal.

    Or perhaps a more useful discussion would be what technology can preserve the (supposed) benefits and flavor of raw milk while making it as safe as the pasteurised variety. That would be a sensible way to go for raw milk lovers, IMHO.


    PS: raw milk cheese. Possible to make it safe but challenging, like dry-cured sausages. And with lots of salt.

    • I can’t speak for Italy, but the situation in the UK has changed markedly over the years in terms of restricting sales of raw cows’ drinking milk to the farm gate, introducing health warning labelling and increasing the frequency of inspection and microbiological sample testing of raw cows’ drinking milk at registered production holdings. The FSA summarise current controls:

      “The current controls on the sale of raw cows’ drinking milk in hygiene and food labelling regulations are:
      a) the milk may only be sold direct to consumers by registered milk production holdings (at the farm gate or in a farmhouse catering operation) or through milk roundsmen. Sales through other outlets have been banned since 1985 (although sales by the farmer at farmers markets are allowed);
      b) the supplying animals must be from a herd that is officially tuberculosis free, and either brucellosis free or officially brucellosis free;
      c) the production holding, milking premises and dairy, must comply with hygiene rules;
      d) the milk must bear the appropriate health warning;
      e) compliance with a) to d) above is monitored by inspections twice a year; and
      f) the milk is sampled and tested quarterly under the control of Animal Health Dairy Hygiene to monitor compliance with standards for total bacterial count and coliforms.”

      That these measures have been shown to be effective is illustrated by the absence of any reported cases of food borne illness attributable to raw milk over the last 10 years and even before then cases were rare. This does not, of course, guarantee that none will ever arise, but the same could be said of pasteurised milk the production of which is not fool proof. You say the discussion should start from the acceptability of risk but then say none is acceptable. This doesn’t give much scope for discussion, but I do say that, as in so many areas of life, this is an area where prudent measures can provide effective risk management. The concern I have, evidenced by the FSA Board discussion, is that issues of a cultural, social, sustainability, diversity, community and, not least, nutritional nature are being completely overlooked. You may take the view they ought to be, but I do not.

      More importantly, when even members of the FSA Board are saying where’s the problem and questioning whether the review is a priority, in these cash strapped times there are much bigger, more important things the FSA should be focused on.

      Thanks for contributing. The debate is important.

      • Gerry,

        in my comment I state “How many cases of illnesses do we accept from raw milk that consuming pasteurized milk would have prevented? I’d say none, at least in children, in the vulnerable and in uninformed adults”. I am not say none. I am ready to discuss how much extra risk due to raw milk is acceptable for informed adults. Saying that pasteurised milk is not 100% safe is beyond the point. The argument that everything is risky so all risks are ok is surely against common sense. The point is that pasteurised milk is much safer than raw milk, and the discussion is whether raw milk is safe enough to be permitted at all. Where you have not replied is whether you accept that any children, vulnerable person, or uninformed adult becomes ill because of raw milk, when they could have been ok with pasteurised milk. If you don’t accept this risk, we can then discuss if the rest of the public is entitled to take the raw milk risk – for example under the conditions that you have in England.

        As for the FSA debate, I remark that it was caused by some operators trying to get into an Italian situation, ie vending machines. And unless you oppose vending machines, you should be interested in what happens in Italy: no compliance on temperature, microbes out of control in the vending machines, and disease. It’s not because of Italy, since enforcement of food law is normally stronger here than in the UK. Information to the contrary, I’d like to discuss. I have not reflected as to whether England should ban raw milk totally as Scotland has done, certainly raw milk use should not be expanded.

        What about local farms, tradition, etc? All great things. Certainly there are ways to do all those things in a way that does not expose people to risks. Make milk that tastes like raw milk but is as safe as pasteurised milk. I’d love that.


      • Luca,

        Sorry if I misunderstood. In short, I don’t think any level of illness in anybody is acceptable, any more than I think illness or injury from any other activity is acceptable. The mitigation of risk is something we should strive for but not for its own sake and at any cost. I also think that to try and distinguish between who is, and who is not, an informed adult is pretty much doomed to failure. Who could possibly make such a judgement? You can’t put people into categories and say, you can but you can’t because you are not an informed adult. There is a statutory health warning on all raw milk sold in the UK highlighting the risk. There is also such a thing as personal responsibility, people should be allowed to make their own choice in such matters.

        You also misunderstand me. I did not say “everything is risky so all risks are ok”. I did say that prudent measures should be taken to mitigate risk where possible. Taking the train is safer than driving a car, but we don’t ban car driving, despite the 100s killed on our roads every year. There are many similar examples, many much more mundane, but I use the car to make the point.

        I really am interested in what is happening with vending machines in Italy and it may highlight the need for the imposition of minimum (dare I say EU) standards or possibly, although I fail to see why this should be the case, that such machines are not appropriate for raw milk distribution.

        In a world, as I pointed out, in which we can save 40,000 lives by cutting fat and salt in processed food, this issue is simply not a priority for a major public body to devote its resources, when it does so it has lost sight of the bigger picture, the things that make a real difference to food quality and public safety.

    • The health problems associated with raw milk only became apparent once we started intensive farming; raising cows in confined areas, feeding them an unnatural diet and injecting them with antibiotics and growth hormones. As the milk producers got bigger, and wanted more profit, they needed to distribute to a larger area, so they needed to increase shelf life.

      Don’t make the mistake of thinking this is a health issue, this profit and politics, and nothing more. Keep the milk producers natural, small and local, and there is no health problem, just like there hasn’t been for thousands of years! And any information to the contrary is simply anti-scientific, confu-babble design to keep the general public confused.

      What? Politicians and big business are not going to lie? Get real!

      • David,

        I couldn’t agree more that small is beautiful. Industrial food production has broken the link that people used readily to make with the food they consumed and from where it came. So many people no longer know and so have ceased to care about where food comes from and how it has been produced. The result is industrial scale agriculture, poor animal welfare, denuded crops and, at best, third rate food.

        Thanks for your contribution to the debate.

  3. People have to be made aware that pasteurization is only necessary when cows are unhealthy. Humans have been cultivating cows for centuries, so that there evolves a perfectly symbiotic relationship between cow and human. Perfect that is until “scientists” start messing with it, and decide it would be better to introduce some artificial processing, to increase shelf-life and profitability, and dress-up this new process as a public health benefit. Politics, profit and healthcare – a mix that’s never going work is it..

  4. I can’t believe all the big milk producers are really as stupid as they seem. What the mainstream milk industry is afraid of is once it becomes accepted that raw milk is much healthier for you than pasteurized, then they will lose market share that they will not be able to win back because they cannot compete. I would imagine (I am guessing) that raw milk would be more difficult to distribute over a large distance due to shorter shelf life, so can only be produced and distributed locally – leaving the big guys flapping in the breeze!

  5. Reblogged this on naturallywells and commented:
    Food Standards Agency threatens the sale of raw milk to the public.

  6. Alistair Danby

     /  3 April 2012

    I see raw milk as a life style choice.
    There are no significant health benefits from drinking it in the quantities the average person would consume. The level of protein denaturisation through pasteurisation is practically nil, compared to the level of monitoring (and policing) required to guarantee a quality raw milk from healthy animals and stored in clean equipment. I’m not sure it’s worth the effort.

  7. marc

     /  3 April 2012

    raw milk is a lifestyle choice but we should all be free to make that choice. The government food advice has done enough damage as it is getting us to eat a diet based on starch and carbohydrates and processed food when humans are adapted to be the best hunters on the planet and eat an animal based diet. The effects of pasteurisation are not nil the proteins are denatured the vitamin c is reduced the beneficial gut flora are killed (which is showing to be a cause for numerous modern illnesses including allergies eczema and a lot of mental illnesses including autism and schizophrenia) the enzymes are all denatured the fat molecules are altered the body is a remarkable thing and can put up with a lot of abuse which is obvious seeing as everyone in the supermarket now has trouble identifying real food from the junk that is sold in packets yet we dont die instantly we just get obese and sick with diabetes and all the other ailments that real science has proven to be caused by the food industry tampering with our natural diet thanks to the government people now think that crisps and cheerios are real food it is amazing brain washing. What do you think would end more sickness in the world banning raw milk or banning processed food and fast food restaurants, This is obvious though which one would the government and food industries get more money from banning now you see where they are coming from. 0 deaths in 10 years of drinking raw milk now look at the amount of people who have died as a result of eating processed food in my opinion this would include most cancers diabetes obesity mental illness cardiovascular disease. Infact i would go as far as saying that even if someone died of drinking contaminated milk it would probably be a result of the processed foods and sugars effect on the persons immune system that would make them more susceptible the fact is raw milk contains bacteria that fight our battles for us if you get a bad bacteria and put it in pasteurised milk there is a much greater chance of it killing the person who ingests it than if you put the same bacteria in raw milk where it would be out competed and killed by the bacteria mankind has evolved to live with for thousands of years the same bacteria that would also stimulate our immune systems to assult the invader if it ever went that far.

    • Marc,

      I think you hit the nail on the head when you said: “What do you think would end more sickness in the world banning raw milk or banning processed food and fast food restaurants”. The evidence is incontrovertible. If nothing else, this is a case of a major public body, the Food Standards Agency, that has simply got its priorities all wrong.

      Thanks for joining in.

  8. marc

     /  4 April 2012

    Also ever wonder why the scottish have some of the highest rates of heart disease in the world despite banning raw milk. It clearly has not helped them. Even more critical things for the FSA to spend their time and money on are banning GMO crops.Isn’t it interesting that all the foods that bring them money are the ones being supported they are supposed to be protecting the public yet all they care about are their pockets. Someone is clearly trying to make everyone less healthy and more stupid so that we are more susceptible to getting hooked on the crap food they promote hence the scaremongering going on with meat causing cancer and eggs containing fat and cholesterol all foods that feed our brains and now raw milk which contain bacteria that feed what many people consider to be our second brains our guts where most of our immune system lies and where many of our nutrients are made such as our b vitamins and where seretonin is produced. Plus the cholesterol milk contains and saturated fat are important in building healthy brains and hormones and for our body to repair itself pasteurisation oxidises the cholesterol making it toxic and causes increased inflammation which is the route of most disease. It is obvious how much we have all been brainwashed in society nowadays and the lack of knowledge people have about food. People now believe that things they have evolved along side are bad for them come on use your common sense how can eating meat cause cancer we have been eating meat for an age along with the rest of the carnivores and omnivores? and salt is our oldest food preservative once used as currency oh but now we are told that is bad for us(salt also important for the brain development by the way there is a theme here). Oh and now the sun causes skin cancer… common sense people! the sun doesn’t cause skin cancer if it did none of us would be here today the thing that is causing skin cancer is eating all this processed food which is ‘saturating'(dont’ be scared) our skin with oxidisable omega 6 fatty acids where there should be stable saturated fatty acids but yet again another product benefits from this advice think how much money suncream companies are making. The more our diet deviates from fatty animal foods the sicker and less intelligent we all become the further we get away from unadulterated nature the sicker and thicker we all become. Now this is perfect for the government as they get to tax people for NHS services and then get the money right back from the pharmaceutical companies who supply the drugs. Or they get the money back from the FSA who get money from benecol and kelloggs who sell the ‘solution’ to the peoples illnesses low fat cereals with all the vitamins we could possibly need despite the fact the reality is the packaging contains more nourishment than the foods. The whole system is so corrupt it is sickening all these big organisations are in each others pockets. Food should be our medicine our ancestors knew this but we have been made to forget this fact. Plus there has been a lot of research lately on nutrients in plants they are finding more and more tiny plant nutrients everyday and these nutrients are eaten by herbivores and undergo changes and then we reap the health rewards when we drink the cows milk. However it is obvious that heating this milk is going to damage some of these important phytonutrients as they are known. I could be wrong with some of these ‘conspiracy theory’ sounding theories but it is either true or these large organisations really are getting stupider with us.

  9. marc

     /  4 April 2012

    Most of this bad science that gets in the media is only concerned with correlation i.e skin cancer increases with sun exposure now this doesn’t prove that the sun causes skin cancer as there are too many other variables that could affect the way the sun is interacting with our bodies such as diet.

    or eating meat causes cancer…
    how can we prove this unless we know what temperature all this meat was cooked at, or what the animal ate during its life or what the pan was made out of that the meat was cooked in or what other things that person ate that might have interacted with the meat.

    It is the same with raw milk is it the raw milk that is causing TB to be contracted or is it the fact that most of the farms supported by the FSA etc are feeding the animals foods they shouldn’t be eating like grains instead of their natural grass and herb diet and the animals are kept in concrete sheds all day in their own faeces. Now there hasnt been a case of food poisoning from raw milk since 2002 could this be because farming conditions are better now and the raw milk producers now know more about what foods animals should be eating and how they should be kept clean. By eating grass and herbs which contain all the phytochemicals the animal needs to build an immunity(unlike grains) I believe the risks are close to zero

  10. “Meanwhile, drinkers and advocates of raw milk, and those who believe in the consumer’s right to choose should be very concerned….”

    …and concerned we damn well are! The key issue is what can/should we all do to – quickly – to make our cohesive voice(s) heard in the right places?

    • Isabel,

      Last time around, in the late 1990s, when there was a review of raw milk the campaign to keep it was spearheaded by Julian Rose a leading pioneer in organic farming and raw milk champion. He was on Farming Today a little while ago defending raw milk. There’s also the UK Alliance for Raw Milk (UK-ARM) which is on Facebook (they don’t appear to have a website) but they seem to have been a bit quiet on this issue so far and there’s also the Weston A. Price Foundation which has a base in London and they have always been active in defence of raw milk.

      The FSA has not yet announced when the consultation will start and what form it will take, but I’ll be posting updates here on my blog as things progress, meanwhile it would do no harm to contact the organisations I mentioned. They are best place to co-ordinate action.

      Thanks for your interest.

      • Hi Gerry,

        I recently attended the Weston Price conference and am fairly new to this. Never-the-less, more I dis(un?)cover about the raw milk issue -and other food issues – the more it provokes a sense of outrage. I have a reasonable skill set to offer (no, not dairying!) a campaign, and have responded to Philip Ridley’s (WAPF) plea for help to co-ordinate a response to the FSA. I guess you may also have had contact with him on this issue?Please let me know if there is anything I can do.

        Kind regards, Isabel

  11. Caroline DownUnder

     /  27 April 2012

    The following is a response from Sally Fallon Morell, to a recent update, to the New Zealand Ministry of Agriculture and Forestry (MAF) Food Safety recommendation regarding consumption of raw milk –
    It is interesting to note that the update to the MAF advisory occurred within 45 minutes of the end of Sally’s Nourishing Traditional Diets presentation in Wellington, our capital city last month.

    “Sally Fallon Morell, president of the Weston A. Price Foundation, states that there have been no deaths from consuming raw milk in the United States for decades. However there have been deaths from consuming soft cheeses, that were made from raw milk in very unsanitary conditions.

    By comparison there have been 3 deaths in 2007 from pasteurized milk and 7 deaths in 2009 from pasteurized cheese.

    MAF claims two incidences of illness from raw milk. They need to supply details. Were these illnesses confirmed by tests showing the same organization causing illness found in the milk? If not, then there is no proof that the raw milk caused illness.

    Raw milk is especially important in the diets of pregnant women, growing children, the elderly and those with compromised immune systems. Raw milk contains many components that build the immune system, these components are compromised by pasteurization.

    For more information, visit .”

  12. Good day! Do you use Twitter? I’d like to follow you if that would be okay.
    I’m definitely enjoying your blog and look forward to new updates.

  1. Defra reviews compulsory flour fortification – the right to choose what goes in our bread? « pause for food

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