Updates: Review of FSANZ Raw Milk Products Discussion Paper P1007

LINKS

www.realmilkaustralia.com

UPDATES

EARLY PRESS RELEASE INFORMATION

….Raw MILK, Senator Dean Florez and Martin Sheen !!

Senator Dean Florez has called a Press Conference to be held at “Pacific Coast Greens” Store ( 22601 PCH, Malibu CA 90265 ) at 1400 hours on Tuesday September 9th 2008.

Senator Dean Florez, Martin Sheen and other Sheen family members will be speaking about SB 201 "The Fresh Raw Milk Act of 2008". This historically important bill will assure a high level of raw milk food safety and secure raw milk for the California market place. Raw Milk has recently emerged as a hot topic nationally. The “FDA has condemned its consumption” yet each state regulates raw milk production and sale independent of the FDA. In California raw milk is legally sold in more than 375 stores. SB 201 could very likely set the standard for other states and countries to follow, it is a “World Class Food Safety Bill”.

Also in attendance at the conference will be Christine Chessen the founder of CREMA, other raw milk consumers and the two CA raw dairy producers; Claravale since 1927 and OPDC since 2000.

SB 201 now sits before Governor Schwarzenegger for signing into law. SB 201 could be vetoed because of forces deep inside the executive branch and big dairy interests.
“GOT MILK” can not do raw milk and compete in this market, so it has become a “hot subject”.

Arnold grew up on raw milk and built his body building career around its whole, enzyme rich and pro-biotic nutrition.

Unlike pasteurized milk, raw milk does not cause lactose intolerance, has strong immune system rebuilding properties and has all of its enzymes still active.

To learn more about SB 201 and the Raw Milk debate see this very professional video that chronicles the entire story from farm to consumer and through its successful legislative process.

Press contact: Mark McAfee
www.organicpastures.com
559-846-9732 office or 559-351-2453 cell

Review of FSANZ Raw Milk Products Discussion Paper P1007

Published 6 August 2008 by Paul Neaves

In general, we support the objectives of the Discussion Paper and offer the following comments.

1.   P(iv) …. A Standards Development Committee, consisting of representatives from the dairy industry, consumers and jurisdictions, is advising FSANZ on this work …. In addition, FSANZ has established a Dairy Scientific Advisory Panel to provide technical assistance and advice to FSANZ during the preparation of the microbiological risk assessment. The Panel consists of experts from industry and government.

      and,

       p3 …. A Standard Development Committee has been established by FSANZ to assist and advise with this Proposal. The Standard Development Committee consists of representatives from the dairy industry, consumers and jurisdictions who are recognised for their skills and knowledge of dairy processing, on-farm practices and veterinary practices.

      and,

       p17 …. In May 2007, the FSANZ Board appointed members of this [Dairy Standards Development] Committee to continue the work on raw milk products under Proposal P1007 as well as increasing membership by adding additional expertise in raw milk issues.

      and,

       p17 …. In addition to the overarching SDC a smaller Communication Sub – Committee comprising of volunteer members from the SDC has been formed to assist with addressing communication issues for the Proposal. This Sub - Committee will participate in the development and review of the Proposal communication strategy, communication materials, communication activities and assist in the implementation of the communication plan and activities.

      Question: Does any of the SDC, DSAP and CSC members have experience with raw milk cheese and artisan cheesemaking? What is in their CVs? Are the CVs available?

2.   p2 …. Raw milk is not defined in the Code but is defined for the purpose of this Proposal as milk that has not been treated in accordance with the processing requirements of the Code1. The use of the term ‘raw milk’ rather than ‘unpasteurised milk’ recognises that there are processes other than pasteurisation currently permitted (e.g. thermisation for cheesemaking) and that other non-thermal processing treatments may be applied.

           1 Internationally, the use of the term raw milk may differ. For example the Codex Code of Hygienic Practice for Milk and Milk Products CAC/RCP 57-2004 defines raw milk as ‘milk which has not been heated beyond 40°C or undergone any treatment that has an equivalent effect’.

      This is confusing and does not make sense because milk that has been thermised is unpasteurised but not raw. Having identified that the term ‘raw’ will be used, the term ‘unpasteurised’ appears on pages 4, 5, 6, 31, 32 and 35. So, why not use the term ‘unpasteurised milk’ to mean milk that has not been processed in accordance with the requirements of the Code and ‘raw milk’ to mean milk that as received no heat-treatment, as used in other countries?

3.   p2 …. The heat treatment2 of milk and milk products has therefore been mandated via the Code as an important public health measure to destroy microbiological hazards that may be present in milk and has provided the benchmark public health and safety measure for dairy foods in this country.

           2 Heat treatment includes pasteurisation or thermisation processes whereby microbiological hazards are eliminated from the milk.

      The footnote is incorrect. It is universally recognised, including in this Discussion Paper (p20), that thermisation is a sub-pasteurisation process that does not eliminate all relevant microbiological hazards from milk. Thermisation may well eliminate hazards due to Gram-negative bacterial pathogens but it will not eliminate Gram-positive bacterial pathogens; its main purpose is to extend the shelf life of unpasteurised milk and to improve the quality of certain cheeses.

4.   p9 …. This includes information and data on:
               • potential food safety hazards associated with animal disease and treatments and on-farm inputs (e.g. feed, water, veterinary interventions)

      Other important factors include maintenance of a closed herd, bedding or pasture, inspection of the foremilk and teat dipping.

5.   p9 …. Australian epidemiological data on the extent and cases of human disease associated with the consumption of raw milk products are being sought.

      Are there any plans to compare it with anything, such as epidemiological data on disease associated with pasteurised milk products? Data on unpasteurised milk products are relatively uninformative without a benchmark.

6.   p20 …. 1.2 Thermisation
      The Code permits a time-temperature process of milk for cheese production that is less rigorous than pasteurisation (62ºC for 15 seconds), providing that the cheese is stored for at least 90 days from the date of manufacture. This heat treatment is generally referred to as thermisation.
       While thermisation kills psychrotrophs (microorganisms active at lower temperatures), it may not destroy all pathogenic microorganisms that may be present. This heat treatment, however, may not be sufficient to destroy all pathogenic microorganisms that may be present and so a further safeguard is required and the cheese produced must be stored for at least 90 days at a temperature greater than 2ºC. During this time, depending on the physical and chemical characteristic of the cheese such as pH, water activity and salt content, it is expected that pathogenic bacteria present will die off.

      Not strictly true. A) “psychrotrophs” should read “Gram-negative psychrotrophs” since some sporeformers are also psychrotrophic. B) The 90 day rule applies mostly to raw milk cheeses (i.e. made from milk that has not been thermised) rather than thermised milk cheese as it is principally the Gram-negative bacteria that die during maturation and these are destroyed by thermisation.

7.   p22 …. 4. Hazards associated with raw milk products
      4.1 Microbiological hazards
      A broad range of microbiological hazards may be introduced into raw milk products during primary production and processing.

      Hazards introduced during processing apply equally to cheese made from pasteurised milk!

8.   p23 …. raw milk may have a mixed microflora which is derived from several sources including the interior of the udder …

9.   Although this is technically correct, it is misleading. To the best of my knowledge, in healthy animals the interior of the udder is sterile; it is in cases of mastitis that it becomes infected.

9.   p23 5. Public health risks
      In countries where raw milk products are routinely available, they have frequently been implicated in foodborne illness. Internationally over the last 30 years, raw cow and goat milk has been associated with over 50 outbreaks of food borne illness involving 1051 cases and 38 deaths. Over the same time period, raw milk cheeses produced from either cow, goat or sheep milk, were implicated in a similar number of outbreaks (n = 56), although were more serious in their impact. More than double the number of people (n = 2691) were affected than in raw milk outbreaks, with 56 deaths reported.

      I dispute the adjective ‘frequent’; in my opinion, over a period of 30 years, internationally, these data demonstrate an excellent track record!
       A) 1051 cases over 30 years due to raw milk – by comparison , in 2000 more than 1,000 cases were associated with contaminated drinking water in Ontario (Woodward et al., 2002).
       B) 2691 cases due to raw milk cheese over 30 years - by comparison, in the US, at least 1319 people have been infected in 2008 with Salmonella Saintpaul that contaminated jalapeno peppers, IN ONE OUTBREAK (IFSN, 2008).

1.   p31 4. Exclusions from the microbiological risk assessment
      Animal health issues other than those that specifically impact upon human health via foodborne transmission …

      What are these? Examples would be helpful.

General
      A) To put raw milk and raw milk products into perspective, statistics should be sought for human disease associated with the consumption of other raw foods and for the incidence of pathogens in raw milk compared with other raw foods, e.g. fresh produce.
       B) Not nearly enough emphasis is made of the importance of raw milk quality and source. For example, the Proposal does not appear to provide for the acquisition of data on milk buying practices, e.g.:

Own herd.
Vertically integrated co-operative in which the milk producers own the dairy.
Independent milk producers under direct contract to the dairy.
'Open market' milk; i.e. supplied by a primary purchaser / regional haulier.

Of these, a cheesemaker's own herd is likely to provide the least risk of pathogen contamination and 'open market' milk the greatest. This is critical when making soft cheese.

References

International Food Safety News, Editorial, in World Food Regulation Review, 18, (3), August 2008.

Woodward, D. L., et al., (2002) Verotoxigenic Escherichia coli (VTEC): a major public health threat in Canada. Can J Infect Dis 13:321-30.

Dr Paul Neaves FIFST
20 August 2008