National Environmental Health Association
Position Regarding


Sale or Distribution of Raw Milk

Adopted: January 28, 2008

Editor’s Note: The NEHA Board of Directors recently adopted this position in opposition to any legislation that would allow the sale or distribution of raw, unpasteurized milk to the consumer. NEHA strongly supports pasteurization before sale to the consumer. In addition, NEHA strongly supports consumer education about the dangers of consuming raw, unpasteurized milk. Below is the full text of the NEHA position.

The Cornell University Department of Food Safety has stated that “milk is a natural food. It is nutrient-rich: it contributes high-quality protein, essential vitamins and minerals including calcium to the diet” (Scott, 2002). Milk in its raw state contains a number of bacteria, some of which may be pathogenic such as enterotoxigenic Staphylcoccus aureus, Campylobacter, Escherichia coli, Listeria, Salmonella, Yersinia, Brucella, and Mycobacterium tuberculosis (Headrick et al., 1998). This is the case for all dairy animals, including cows, goats, and sheep. The process of pasteurization has been used for a hundred years to destroy pathogenic bacteria that are present in raw milk (International Association for Food Protection [IAFP], 2008). The Centers for Disease Control and Prevention (CDC), the U.S. Department of Agriculture (USDA) (U.S. Food and Drug Administration, 2006), and the World Health Organization (WHO) (WHO, 2006) endorse the process of pasteurizing milk as a public health control measure.

Milkborne disease has been reduced greatly by the use of pasteurization. Prior to 1938, milkborne illness represented 25 percent of all foodborne illness outbreaks. As a result of efforts by the U.S. Public Health Service and individual states requiring the mandatory use of pasteurization, milkborne illness represents less than 1 percent of foodborne illness outbreaks. Cases of illness caused by the consumption of raw, unpasteurized milk have continued to occur (Headrick et al., 1998). FDA and CDC have noted the following outbreaks:

Moreover, the occurrence of outbreaks due to raw milk has been found to correlate with the legal status of raw milk sale within a state. In a review of raw milk–associated outbreaks reported to CDC during 1972–1992, Marcia L. Headrick, D.V.M., M.P.H., and colleagues found that the rate of raw milk–associated outbreaks was higher in states in which the sale of raw milk was legal. The authors concluded that banning the intrastate sale of raw milk could reduce the number of milk-associated outbreaks (Headrick et al., 1998).

Recently, advocates of the consumption of natural food have approached legislators in a number of states to allow the sale of raw milk to the consumer. They have contended that the pasteurization process destroys the nutritional benefits of milk. In some instances they have pushed for the adoption of legislation that would allow individuals to purchase a portion of the production of a milk cow through an arrangement know as “Cow Share.”

John Sheehan, Director of the U.S. Food and Drug Administration’s Division of Dairy and Egg Safety, stated that research showed that there is no significant difference in the nutritional value of pasteurized and unpasteurized milk. He indicated that the caseins, the major family of milk proteins, is largely unaffected and any modification in whey protein that might occur is barely perceptible (Bren, 2004). Sheehan further stated: “Raw milk is inherently dangerous and should not be consumed. Raw milk continues to be a source of foodborne illness and even a cause of death within the United States.… Pasteurization destroys pathogens and most other vegetative microbes which might be expected and have shown to be present in milk” (Testimony of John F. Sheenan, 2007).

A number of regulatory, educational, and public health organizations have issued position papers regarding the dangers associated with the consumption of raw milk. These include:

The National Environmental Health Association recognizes the nutritional value of milk, and it further recognizes the overwhelming scientific evidence that raw milk can transmit pathogenic bacteria to the consumer. The National Environmental Health Association further recognizes the overwhelming scientific and public health evidence that pasteurization of milk has been proven to be a sound method of preventing milkborne disease. NEHA therefore

The National Environmental Health Association has long supported preventive measures to protect the safety of food for the public. NEHA acknowledges the importance of milk as source of nutrition and is concerned about the safety of milk and products made from milk. NEHA’s position regarding raw milk is consistent with sound, science-based, preventive public health measures.


References

Bren, L. (2004). Got milk? Make sure it’s pasteurized. FDA Consumer Magazine, September-October. Retrieved January 21, 2008, from www.fda.gov/fdac/features/2004/504_milk.html.

Centers for Disease Control and Prevention (CDC). (2007a). Salmonella typhimurium infections associated with raw milk and cheese consumption—Pennsylvania, 2007. Morbidity and Mortality Weekly Report, 56(44), 1161-1164.

Centers for Disease Control and Prevention (CDC). (2007b). Escherichia coli O157:H7 infection associated with drinking raw milk-Washington and Oregon, November-December 2005. Morbidity and Mortality Weekly Report, 56(8), 165-167.

Centers for Disease Control and Prevention (CDC). (2003). Multistate outbreak of Salmonella serotype typhimurium infections associated with drinking unpasteurized milk—Illinois, Indiana, Ohio, and Tennessee, 2002-2003. Morbidity and Mortality Weekly Report, 52(26), 613-615.

Centers for Disease Control and Prevention (CDC). (2002). Outbreak of Campylobacter jejuni infections associated with drinking unpasteurized milk procured through a cow-leasing program—Wisconsin 2001. Morbidity and Mortality Weekly Report, 51(25), 548-549.

Centers for Disease Control and Prevention (CDC). (2001). Outbreak of listeriosis associated with homemade Mexican-style cheese—North Carolina, October 2000—January 2001. Morbidity and Mortality Weekly Report, 50(26), 560-562.

Centers for Disease Control and Prevention (CDC). (1999). Mass Treatment of Humans Who Drank Unpasteurized Milk from Rabid Cows—Massachusetts, 1996–1998. Morbidity and Mortality Weekly Report, 48(11);228-229.

Headrick, M.L., Korangy, S., Bean, N.H., Angulo, F.J., Altekruse, S.F., Potter, M.E., & Klontz, K.C. (1998). The epidemiology of raw milk–associated foodborne disease outbreaks reported in the United States, 1973 through 1992. American Journal of Public Health, 88, 1219-1221.

International Association for Food Protection. (2008). Position paper: Milk pasteurization and the consumption of raw milk in the Unites States. Food Protection Trends, 28(1), 45-47.

Scott, D.L. (1998, rev. May 2002). Why pasteurize? The dangers of consuming raw milk. Dairy Foods Science Notes. Ithaca, New York: Cornell University Department of Food Science. Retrieved January 28, 2008, from www.dairystore.cornell.edu/cals/foodsci/extension/milk-quality-improvement-program.cfm#Publications.

State of North Carolina. (2007, December 18). Listeria warning issued [Press release]. Department of Health and Human Services, Public Information Office.

Testimony of John F. Sheehan, B.Sc. (Dy.), J.D., Director of Plant and Dairy Food Safety, Office of Food Safety, Center for Food Safety and Applied Nutrition, U.S. Food and Drug Administration, before the Health and Government Operations Committee, Maryland House of Delegated, March 15, 2007.

U.S. Food and Drug Administration. (2003). Letter dated March 18, 2003 from Joseph R. Baca, Director, Office for Compliance Center for Food Safety and Applied Nutrition-FDA to Capt. Richard D. Eubanks, Senior Milk Sanitation Officer & Capt. Robert F. Hennes, Chief, Milk Safety Branch. Subject: Regarding Sale/Consumption of Raw Milk-Position Statement.

U.S. Food and Drug Administration. (2007, January 24). Raw milk–associated public health risks [PowerPoint presentation]. College Park, MD: Dairy and Egg Safety Division, Office of Plant and Dairy Food, Center for Food Safety and Applied Nutrition.

World Health Organization. (2006). Populations at risk, 2006. Geneva, Switzerland: Food Safety Programme, Department of Protection of the Human Environment, Cluster of Sustainable Development and Healthy Environments.


 

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