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Italy’s Experience Liberalizing Raw Milk Sales: Can’t Put the Genie Back in the Bottle

On Jan. 25, 2007, Italy formally authorized the sale of raw milk to consumers through automatic vending devices. The decision had its legal basis in the generous interpretation  of a 2004 provision in European Union hygiene law, and followed intense lobbying from farmers and local authorities.

In fact, since 2004, local authorities had permitted sales of raw milk in their territories.

The 2007 decision requires registration of vending devices with the authorities, and authorized the placing of devices not only within farms, but also elsewhere in the same province. Pooling of milk from different farms is not permitted; each device corresponds to an individual farm.

The decision also mandates two analytical controls per month, on farm (and not in the end product), on Plate count (at 30 °C , per ml, with a limit of ≤ 100 000) and somatic cell count (per ml, with a limit of 400,000), and requires compliance with the limits, set by EU law, for the average of the two measurements. An unfortunate consequence of this requirement has been that compliance with the limits has been interpreted as proof of safety of the final product.

In the technical annex to the decision, a number of mandatory procedures are named, and the legal requirement for raw milk to be safe is repeated multiple times. In language which lends itself to multiple interpretations, analytical monitoring is required for pathogens (S. aureus, Listeria monocytogenes, Salmonella spp, E. coli O157, Campylobacter) and contaminants (aflatoxins) on animals and milk, though no minimum frequency is mandated.

Moreover, fresh raw milk has to be supplied daily, and unsold milk from the previous day has to be collected and cannot be sold as such.

The vending devices can provide raw milk from tap, or automatically fill bottles, which need to carry the label “unpasteurized raw milk.” Moreover, raw milk has to be kept between 0 and 4 C (32 to 39 F) at all times, with an automatic mechanism to stop distribution if temperature exceeds the limits. A temperature data logger needs to be installed.

The decision helped boost a booming market, a growth which continues today. Unaffected by safety issues, as of 2012, more than 1,400 distribution vending machines exist in Italy.

Raw milk is promoted for its supposed health benefits and, regrettably, also to children by organizations such as Slow Food, an international movement that supports traditional and local cuisine and farming. The key touted benefit is for allergy prevention, and nutrition.

Problems became apparent early on. A 2006 survey by a consumers’ organization found 5 out of the 10 vending machines tested with distributed milk temperature above 4 C (39 F), and in one case above 10 C (50 F). The survey was performed in March, a cool month. It also found that 7 of the samples had total microbial load above statutory limits, though no pathogens were found.

In 2007, out of 39 samples from vending machines, one E. coli O157 positive sample, and three Campylobacter positive samples, were reported to a local congress. In the generally supportive climate and with misguided reading of microbiological evidence from a food safety standpoint, the authors interpreted their overall results as satisfactory.

Sadly, in 2009, a team from Italy’s Istituto Superiore di Sanità, in charge of a national registry of hemolytic uremic syndrome (HUS) cases, reported that, in a case-control study, the only food significantly associated with HUS in 60 Italian children who developed the disease was raw milk.

On Jan. 19, 2009, following cases of HUS possibly linked to raw milk, Italy’s Ministry of Health ordered temporarily all raw milk sold to carry the label “to be used only after boiling” (in red and at least 1 cm, .39 inch, high); for on-farm sales, the warning has to be given verbally.

A mandatory use-by date of three days was also set. Use of raw milk in catering premises, including school cafeterias, was also banned. It is debatable whether people would actually buy raw milk in order to then boil it. More recently, data on microbiological quality of Italian raw milk from vending machines have been reported, and are commented here.

Two years later, on March 23, 2012, the Ministry of Health formally asked pediatricians and physicians, through their associations, to warn patients and parents to boil any raw milk they intend to consume. The 2009 temporary ordinance was also reiterated.

The Ministry also reported that, since 2007, 18 children who later developed HUS have been exposed to raw milk (though a causal link has not been proven), and very recently cases have been identified. There has also been one death. If possible, the magnitude of the health burden appears also underestimated, or underreported, as aggressive identification and early investigation of sporadic cases or outbreaks is not pursued. The recent developments did attract media attention; however, the travails of children with HUS have received little publicity.

From a public health standpoint, the experience of Italy underlines the perils, and difficult reversibility, of policies that expand the availability of raw milk. It is relevant for countries, or jurisdictions, contemplating such policies. The present state is such that only an outbreak large and severe enough to be detected by Italy’s epidemiological means seems likely to question the current policy of pretending that consumers actually boil the raw milk they buy.

The experience also exemplifies the significant health burden that the Italian society – like others – is willing to shoulder as the natural/traditional discourse trumps the health/science perspective. As a consequence, the challenge for the public health community to prioritize safety and overcome cultural and communication barriers has become enormous, against perceived consensus. Even scientists who have highlighted safety issues publicly state that safe raw milk is possible, and do not dare advocate the only protective solution: ban sales of raw milk, especially through vending devices.

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Luca Bucchini, a Rome-based food risk scientist and consultant, is co-founder and managing director of Hylobates, a European food safety and nutrition consultancy.

 

References

Intesa, ai sensi dell’articolo 8, comma 6, della legge 5 giugno 2003, n. 131, tra il Governo, le Regioni e le Province autonome di Trento e di Bolzano in materia di vendita diretta di latte crudo per l’alimentazione umana. 2007. Available at http://www.normativasanitaria.it/normsan-pdf/0000/26733_1.pdf (Italian).

Regulation (EC) no 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for on the hygiene of foodstuffs. Available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:139:0055:0205:en:PDF (English).

Slow Food. I benefici del latte crudo. 2012. Available at http://www.slowfood.it/rawmilk/ita/17/benefici (Italian).

Milk maps. Vending machines in Italy. 2012. Available at http://www.milkmaps.com/index.php (Italian).

Altroconsumo. Latte crudo. 2006. Available at http://www.altroconsumo.it/alimentazione/sicurezza-alimentare/speciali/latte-crudo/4 (Italian).

Giaccone V, Ferioli M, Paiusco A, Miotti Scapin R, Gazzetta A (2007) Profilo microbiologico del latte bovino crudo venduto per consumo umano diretto in veneto. Atti XVII Convegno AIVI.

Scavia G., Escher M., Baldinelli F., Pecoraro C., Caprioli A.  Consumption of unpasteurized milk as a risk factor for hemolytic uremic syndrome in Italian children. (2009) Clinical Infectious Diseases, 48 (11), pp. 1637-1638.

Ministero della Salute. Segnalazione casi di Sindrome emolitico-uremica pediatrica da probabile consumo di latte crudo. 2012. Available at http://www.iss.it/binary/seur/cont/NotaMinSalLatteCrudo27_3_2012.pdf (Italian)

© Food Safety News
  • Sara

    The anti-raw milk agenda in the US is fascinating to me. The press regarding raw milk is constant and negative. There are overtones of children’s rights, wherein parents are faulted by press and critics for how they feed their children in the face of “facts” of raw milk dangers. Farmers are criticized and their motives questioned, as they are subject to the investigations of governments and agencies. Calls to action regarding banning raw milk are frequent and common. This is all in the face of incredibly small numbers of sicknesses occurring and growing consumer demand.
    According to the CDC, food borne illnesses resulting from raw milk account for .5 percent of all food borne illnesses, causing only approximately 50 to 150 illnesses per year in the US among the millions of Americans that consume raw milk. This is also in an emerging market where dirty production practices once “cured” by pasteurization are now in the spotlight and requiring big changes to move toward food safety absent of pasteurization.
    Raw milk isn’t like cantaloupe or spinach or peanut butter, which have caused food-related illness recently but aren’t usually eaten daily. Raw milk consumers drink a significant amount of raw milk usually on a daily basis. Considering the distribution of raw milk, and its continual consumption by millions of people nationwide, the occurrence of illness is very small. So why the anti-raw milk agenda? Why the push toward government control of something that causes infrequent illness?
    A mother several years back was feeding her children Twinkies and Sunny-D for breakfast. When a friend of mine asked her why she picked those things for breakfast, she replied, “It says right on the Twinkies package ‘nutritious and delicious’ and Sunny-D is full of vitamins too, right?” Of course, the packages made these and more claims of health. No one blinks an eye the junk food industry from labeling their sugary fortified refined grains as healthy and nutritious. No one is lobbying for warning labels on junk food and its terrible health effects, why? Because Cocoa Pebbles aren’t giving anyone HUS, right? And we don’t like to tackle lingering debilitating diseases like heart disease or diabetes, just quick acting ones like E-coli 0157.H7 poisoning. That’s too messy.
    But it’s pretty easy to see the terrible effects of poor diet and hosts of other COMMON lifestyle choices on American Health. Check out healthcarereform.com and learn how healthcare costs for Americans have increased by 45% from 2001 to 2006 and I am sure by a much greater margin since then. A middle-income family with individual coverage spends on average 22 percent of household income on health care. THIS is a REAL problem, one not solved by banning raw milk. THIS is WORTH reporting and raising awareness about. Our country’s overdependence on drugs, particularly those that destroy immunity, of which 85% resides in the gastro-intestinal tract and is nourished by food rich in healthy bacteria like raw milk and is eradicated by unnecessary antibiotics and crippled by poor diets high in rancid oils, refined sugars, and white flours.
    Organizations like Slow Food are working to combat the effects of poor diet on human health, something our FDA and CDC is NOT doing. Poor diet and poor health are a much more serious concern than raw milk, which in turn works TOWARD overall health and vitality by feeding the immune system via the digestive track and providing nutrients that can actually be assimilated by the body.
    The FDA, on the other hand, is a major player in on of the biggest killer of Americans. Adverse drug reactions (ADRs) are a leading cause of death in the USA. Bruce Pomeranz and colleagues at the University of Toronto estimate that ADRs could account for more than 100 000 deaths in the USA each year, making them the fourth commonest cause of death after heart disease (nearly 750000 deaths), cancer (530000), and stroke (150000) ( JAMA 1998; 279: 1200—05). I would postulate that poor diet is the leading cause of the first 3 killers of Americans.
    So tell me again why the FDA and CDC and the ever-supportive press are all demonizing raw milk when much more serious health concerns exist, ones that the agencies themselves have created? And why is it that foreign countries without an anti-raw milk agenda treat raw milk with much less zeal? Reminds me of a story I once heard about a beam and a mote…

  • Michael Bulger

    Sara,
    Can you really take yourself seriously when you say that CDC and FDA are doing nothing to combat the effects of poor diet? You sound absurd. That is a major part of their mission and many millions of dollars are devoted to promoting healthy diets. Many of Americans enjoy healthy diets while also minimizing food safety risks.
    Further, it would be irresponsible of health agencies to look the other way while raw milk marketers mislead consumers about the attendant data on raw milk.
    Perhaps if raw milkers would step down their campaign and lower the number of outbreaks they are responsible for, the agencies could devote more resources to other areas.
    http://www.foodsafetynews.com/2012/04/post-5/

  • Lawrence Woodward

    Raw milk is beneficial but lets also recognise the problems
    I am a huge supporter of raw milk and the rights of people to consume it. I believe it should be more widely and readily available. The Food Sterilisation agencies have done a depressingly good job at highlighting the problems with raw milk and hiding the benefits. And the benefits of whole, fresh foods are manifest and well documented. However, it would be wrong to deny that there are problems associated with how raw milk is too often produced and distributed. It is after all a living food and needs to be treated with care and consideration. Until the law in the UK made it impossible to sell raw milk through retail outlets I milked dairy cows and sold raw milk and cream through local shops and restaurants. We were meticulous about the hygiene of our operation and the quality of out milk and would never have allowed the conditions described in the article. Unfortunately not all raw milk producers and sellers are similarly disposed. That situation is appalling and certainly should not be tolerated. But banning raw milk sales is not the answer; banning “dirty” producers and retailers is. Those of us who wish to preserve and increase the consumption of raw milk can justifiably demand a more positive regulatory approach than the article’s author wishes but in turn we have to own up to the fact that raw milk can cause health problems and demand the highest standards of hygiene, consistently met, from raw milk producers and retailers. In reality this is most likely to be achieved through short supply chains where there is a local and close relationship between producer and consumer. I’m not sure that vending machines in large stores is a way to achieve that.

  • Marco Hoffman

    There are no current efforts in the U.S. to ban raw milk — not a single state legislature has considered a ban in recent years nor have any bills been proposed in Congress to outlaw it.
    The push has been from the other side, from those who wish to liberalize the sale of raw milk, including expanding it in the states where it is limited or prohibited, removing all dairy-code regulations for schemes such as cow shares or allowing easy access such as vending machine sales.
    The debate is whether liberalization is in the public interest.
    Anyone who wants to drink unpasteurized milk is already free to do so. The issue is whether the rest of us — including those like me who support the local food movement — are willing to pay for the consequences of unregulated “food freedoms.” Also there is the problem of raw milk drinkers — unlike people who eat cantaloupe, spinach or peanut butter — spinning falsehoods about its imaginary curative powers or citing as fact unproven claims that it can strengthen immune systems and often denying that raw milk has ever caused any illness.
    Raw milk is no more beneficial than pasteurized milk and there are greater risks associated with drinking it, especially for children.
    Yet how many times have we seen in the comments on this food safety site — not to mention in countless posts elsewhere — the dangerous fictions that milk from cows exposed to sunshine, green grass, exercise and not given drugs or hormones can’t possibly become contaminated with pathogens that can kill?
    The costs of these distortions are significant because poisoning from contaminated raw milk can cause such severe illness — perhaps because of the potentially heavy bacterial load. According to the CDC, 85 percent of the hospitalizations in dairy-related outbreaks between 1993 and 2006 involved individuals who drank raw milk. Outbreaks since 2006 — like the ones involving Organic Pastures in California, Your Family Cow in Pennsylvania and the ongoing Foundation Farm outbreak in Oregon suggest that recent hospitalization rates for raw milk-caused disease are even higher.
    The average cost of an E. coli O157 case varies according to severity, but has been estimated to be as high as $6.2 million for individuals who develop HUS, like the unfortunate children now in critical condition in Oregon hospitals after being fed raw milk.
    While such illnesses are beyond devastating for the families involved, the public also pays a heavy burden in terms of costs of outbreak investigations, the strain on the medical system, and increased insurance premiums.
    Any raw foods or undercooked foods contaminated with pathogens from fecal matter can cause illness. Milk, which is so much more easily contaminated than other foods because of its proximity to cow excrement, gets a measure of protection from pasteurization. It’s a simple way to reduce but not eliminate risk — like seat belts in automobiles or helmets for bicycle riders.
    Drink raw milk if you like the way it tastes. But understand that it has harmed far more people than any sugary cereal or GMO food or whatever it is you fear about the contemporary food supply. Treat raw milk like the biohazard it is. Handle it carefully — unpasteurized milk becomes especially dangerous if it is left unrefrigerated for any length of time, including the time it takes you to drive home from the farm.
    As Mr. Bucchini so eloquently states about Italy’s harsh experience in allowing vending machines to dispense raw milk, with a subsequent increase in HUS cases among Italian children, the natural/traditional discourse about milk has trumped health and science.
    The alleged war on raw milk is another cunning fiction pushed by Sara and others who subscribe to conspiracy theories (and know that anti-government sentiments help them sell raw milk). Not a war at all, it is actually just a responsible attempt by public health agencies and others to counter with facts the mountains of misinformation on the Internet about raw milk.
    No one is demonizing raw milk. Raw milk generates bad press all by itself, as the families in Oregon praying for the children hooked up to dialysis machines can attest.

  • Sara

    Lawrence – I absolutely agree with you. I don’t think vending machines are a good way to distribute raw milk, especially if 50% of them can’t keep the raw milk and the proper temperature. I think obtaining milk from the farm is ideal, and that conscientious distribution directly to the customer would be next best. We’re so trained to go to the store for food that it’s hard for some people to go directly to the farmer. I know there are raw milk producers our there whose practices should be improved. That’s another great reason consumers should know condition of the the farm where they get their food. I actually get annoyed with people claiming that raw milk is completely safe and that modern technology makes keeping milk clean easy. That isn’t really true. I agree that there are inherent risks with producing and drinking raw milk. I know firsthand the care required in handling to produce high quality raw milk and frankly it takes a motivated producer willing and able to do so. It is not easy to make a living as a raw milk producer whose goal is milk quality, not quantity and efficiency. I also monitor my state’s raw milk quality tests carefully and am aware of the difficulty facing both small and large operations producing raw milk.
    I think that this point in time is an essential moment to SUPPORT and educate raw milk producers; help them acquire the skills and methods that benefits consumers and quality standards, not to try and shut them down. No, I don’t think authorities should “look the other way” when it comes to raw milk, I think they should support consumers’ right to food of their choice and support raw milk producers instead of slander them. As a raw milk drinker, I don’t think the FDA should shut down processed milk producers, or look the other way to their dangerous practices either.
    Who’s attempting to improve raw milk safety by educating producers? Not the FDA or the CDC, but private individuals and organizations like the Raw Milk Institute. Our state Dairy Bureau chief has been a great resource to many raw milk producers and I feel like my state (Idaho) has done a good job so far supporting raw milk producers and trying to monitor and empower farmers and consumers. It’s been a well-thought-out compromise between pro and anti-raw milk advocates, as it should be, and it’s been done at a state level where people know what’s going on, understand what’s at stake, and are the ones directly involved.
    I just get sick of all the bad press and choruses of “people shouldn’t drink raw milk” or “raw milk drinkers are misinformed” and the denials that there are any benefits or nutritional differences between cooked and raw milk. That’s absurd. So is telling grown adults and parents what they should or shouldn’t feed themselves or their families.
    I’ve never heard of the FDA or the CDC improving diet in any meaningful way. My attempt to Google that topic yielded no significant results, unless meddling with sodium or trans-fat content of processed foods counts (which it doesn’t). I AM aware that our “concerned” federal government subsidizes the farming of food products that cause health problems of many kinds, approves chemicals for use in agriculture and food processing industries that cause health problems and nutritionally deplete our food, approves dangerous prescription drugs for use that cause hundreds of thousands of deaths and injuries annually, and does a lot more that causes damage. I’d actually like to hear something they have done (and that doesn’t count attempted to do) to truly improve the American diet.
    The good news is, I don’t think it’s the government’s job to improve the American diet. It would be nice if they just quit incenting the unhealthy foods and farming practices, stopped pushing dangerous drugs, and stopped supporting Monsanto, big Ag, and the food industry’s quest for fortune at the expense of human health. A healthy American diet should be an individual and family concern. I could go on but I won’t.
    Americans shouldn’t be treated like cattle. We can choose what we eat and how, and we DON’T need the government’s permission. Isn’t that a fundamental freedom? Not according to the FDA. Responding to a Farm-to-Consumer Legal Defense Fund lawsuit, the FDA clearly states that you do not have the right to freedom of choice in your diet. Did someone say absurd?

  • Michael Bulger

    I said absurd. You obviously are passionate about the subject. You should try to improve your research skills so that you can get a clearer picture of this situation. Also, ask yourself: just because other people promote hazardous, does that mean I am justified in promoting a particularly hazardous product?

  • mmconiglemartin

    Sara, you mentioned the Raw Milk Institute. How can an entire website that is devoted to raw milk safety not mention pathogens?

  • Sara

    From the Raw Milk Institute page:
    “When you enter RAWMI’s Farmer Program, we will assess your farm’s unique attributes including facilities and animals. Then, we will help you to develop your own Food Safety Plan. This plan and its accompanying check lists will help you to create the conditions that are optimum clean, safe, delicious milk. You will also learn how to demonstrate that your milk is pathogen-free and low in bacteria counts…”
    Here the stated purpose of the Raw Milk Institute is to work with farmers to develop a food safety plan to eliminate pathogens from the milk, proven by testing, and following a track record that the milk is high quality, it provides outreach to customers. It seems to be the basis of what they do: work with farmers to educate them about potential risks and help them to produce clean, quality raw milk. The purpose of their website isn’t to complain and talk about risks, it is to reach out to farmers and empower them to tackle those risks. Raw milk isn’t perfect, and neither are farmers or founders of the Raw Milk Institute. But I appreciate that they are actively working to improve raw milk quality, working on behalf of interested consumers and producers, rather than sitting on the sidelines waiting to point the finger and launch an attack at anyone who produces or consumes raw milk. I haven’t had personal experience with the institute, I have a support system here where I live, but from what I have heard I applaud them.
    Michael- you couldn’t find anything about the FDA improving health either, could you? I don’t think it’s our research skills, I think the data isn’t there.
    You asked about promoting a hazardous product. I think LIFE is hazardous, full of hazardous lifestyle choices, and that we make decisions daily about what we eat, whether we drive a car, fly in an airplane, use a public drinking fountain, take our children to daycare, swallow a pill, carry a cell phone, and a hundred other things that can cause illness, injury or death on a daily basis to ourselves and others. We weigh benefits and risks, and hopefully make the best choice we can. I not only promote raw milk I produce it, and yes, I feel fully justified in doing so. Raw milk is what I want for myself, that’s why I own cows, and I believe others who want to make that choice and can’t/don’t want to have cows deserve to have a quality source. I do inform each person who wants to purchase raw milk from us that there are risks, that they need to be aware of them, they need to understand what we do and why, and make an informed choice. I direct people to the realrawmilkfacts.com website, share information from the WAPF, and more sources of information – and do so on an ongoing basis. I actually posted that last anti-raw milk story from FSN on our Facebook page for our customers to look at and consider, so it’s not all pro-raw milk information I share. I share our milk quality tests results with customers, invite them to come see what we do. I don’t believe in making a choice with one-sided information, and I hope everyone makes as informed a choice as possible with as much information as possible.
    People that drink raw milk aren’t wrong, they have just made a choice others might not make. I don’t think people that drink pasteurized milk, or none at all, are wrong either. What each of us chooses isn’t a one-size fits all choice. In fact, one of our customers decided to home-pasteurize their milk, while most choose to drink it raw. We all have the right to make our choices, whether the FDA (or you) says so or not. Judging others and slandering isn’t productive.
    My whole point in commenting here is that don’t like the media exaggerating the scope of raw milk illnesses compared with other food and health safety concerns and making a mountain out of a molehill to try and scare people to make the choice they believe is right. Inform, educate, be fair. Empower people to make the right choice for themselves, don’t try to push them around. That’s my point.

  • Mary McGonigle-Martin

    Sara, you mentioned the Raw Milk Institute. How can an entire website that is devoted to raw milk safety not mention pathogens?

  • Michael Bulger

    Sara,
    I can find a mountain of examples of FDA working to improve diet. I guess that went over your head.
    FDA is actually a part of the Department of Health and Human Services. DHHS does extensive work on nutritional education. In regards to diet, FDA’s job is mostly to regulate safety and health claims. You know nutrition labels? That’s FDA. Here is there food website: http://www.fda.gov/Food/default.htm
    You also mentioned CDC in your comment. The CDC, similar to DHHS, provides resources for improving diets. Here is an example: http://www.cdc.gov/nutrition/everyone/index.html
    Why don’t you start there, and then let us know if you still think FDA and CDC are not working to combat the effects poor diets or promote safety.