• The Acheson Group

Raw Milk Again Holds Headlines. Are You Controlling the Risk?

Updated: Nov 22, 2018


Raw Milk Again Holds Headlines. Are You Controlling the Risk?

According to a study published by CDC in May, if all milk and cheese consumed in the U.S. were pasteurized, an average of 732 illnesses and 21 hospitalizations, primarily from salmonellosis campylobacteriosis would be prevented every year. Additionally, the study showed that:

  • Although raw milk is consumed by only 3.2% of the population and raw-milk cheese by 1.6%, unpasteurized milk was linked to 96% of all illnesses caused by contaminated dairy products.

  • Unpasteurized dairy products cause 840 times more illnesses and 45 times more hospitalizations than pasteurized products.

  • Despite a decrease in dairy consumption in the U.S., recent studies suggest that the number of outbreaks associated with unpasteurized dairy products has increased over the last 15 years.

The study used outbreak data from the National Outbreak Reporting System (NORS) to estimate the incidence rates of illnesses and hospitalizations. But NORS is a passive surveillance system with inherent underreporting, so FoodNet data was used to estimate an underreporting factor. Additionally, data from the FoodNet Atlas of Exposure enabled estimates for pasteurized vs. raw milk consumers. (For more information on methodology and citations, see the full report.)


It’s not the first study CDC has published on the impacts of raw milk consumption – or the first discussion by a federal agency. In fact, an FDA web page, titled The Dangers of Raw Milk: Unpasteurized Milk Can Pose a Serious Health Risk, cites an earlier CDC analysis showing that between 1993 and 2006 more than 1,500 U.S. consumers became sick from drinking raw milk or eating cheese made from raw milk.” The page goes on to explain pasteurization and how it kills harmful bacteria without a meaningful difference in nutrition; debunk milk myths; and describe the dangers of unpasteurized milk products. Additionally, CDC has a number of web pages  and videosciting the risks associated with drinking raw milk and USDA has a set of warnings at Foodborne Illness: What Consumers Need to Know, which includes repeated variations of “Do not drink raw (unpasteurized) milk or foods that have unpasteurized milk in them” in recommendations for prevention of foodborne illness caused by various bacteria.


What does it mean to you?

The concern over public health due to foodborne illness-producing pathogens in raw milk and cheeses is particularly relevant and is continuing to increase because of the growing popularity of unpasteurized milk products in the U.S. and the disproportionate percent of illness in those who consume them. The study calculates that as consumption of unpasteurized dairy products grows, illnesses will increase steadily – with a doubling in the consumption of unpasteurized milk or cheese potentially increasing outbreak-related illnesses by 96%. It’s not just popularity that is leading to the increase, rather there also has been an easing of regulations enabling greater access to unpasteurized milk, with fewer states prohibiting the sale of unpasteurized milk in 2017 (10) than did in 2011 (20) or in 2004 (29)..


That said, we don’t expect the federal government to follow that trend. This isn’t the first time we’ve written about federal food agency studies on raw milk products. In an August 2016 newsletter, Results Beginning to Be Seen in FDA's Microbiological Sampling Program, we discussed FDA’s findings on aged, raw-milk cheese, conducted as a part of a large-scale microbiological surveillance sampling program. Although FDA found its 1,606 studied samples to have less than a 1.0% contamination rate for Salmonella, Listeria monocytogenes, E. coli O157:H7 and Shiga toxin-producing E. coli, with an overall contamination rate for generic E. coli of 5.4%, because of the prevalence and known pathogenicity of Listeria in this ready-to-eat cheese, the agency continues to be concerned.


At that time, we said we expected that those who import or sell aged raw milk cheese will be in the FDA “gun sights” to some extent. With the CDC-published study results added to the mix, those gun sights could become even more targeted. How much responsibility will fall on the raw-milk product provider and how much on the consumer who chose to consume it despite warnings, is unknown. But I wouldn’t want to be the producer who finds out as the subject of a liability lawsuit for a life-threatening or life-changing illness or death – particularly of a child.


So, I would expand the recommendations I made to producers of aged raw milk cheese in August to anyone using raw milk in any product to focus on your process control, post-processing environment and safety of ingredients. The data on unpasteurized milk and its products should not come as a surprise to anyone, raw milk holds inherent risk. As the risks become more obvious with growing numbers of raw milk consumers, one has to wonder if states will reverse their decisions.  But I fear that politics may play a greater role in that decision that public health.  But if it were me, I would treat any raw milk product in my facility with the respect and preventive controls due any bacterial risk; and make sure that those inherent and deadly risks are controlled.

About The Acheson Group (TAG)

Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG's team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com

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