There has been an ongoing back-and-forth response from the Weston A. Price Foundation (WAPF) to my literature review of the pros and cons of drinking raw (unpasteurized) milk and a more recent series comparing the food safety track record of pasteurized and raw milk products.

The WAPF had their annual meeting last weekend in the Chicago area, and hopefully they are considering some of the points raised in these discussions.

Like any other food product, there are two primary approaches to solving food safety problems:  regulation and education.

These two approaches are most effective when applied together, in an atmosphere of cooperation between the food industry, government, universities, and consumers.

Here are some of my recommendations for regulating raw milk and educating consumers about the risks associated with drinking it.  I would very much welcome comments from readers with thoughts related to this ongoing debate and how to move it forward.


Grade A pasteurized milk regulation has mostly followed Federal Pasteurized Milk Ordinance  standards.  However, states may require stricter standards for milk.

Raw milk is primarily regulated at the state and local level; interstate shipment is banned.  The question state and local jurisdictions face is:

To Ban or Not to Ban Raw Milk Sales?

The Centers for Disease Control and Prevention (CDC) has reported that the number of foodborne illness outbreaks in states where raw milk is banned is lower compared with the number that occurs in states that allow the sale of raw milk.  However, raw milk proponents argue that raw milk bans infringe on the right of consumers to make their own choice.  WAPF has stated, “Unless raw milk is unique among all foods in the supposed danger it presents, it should not be singled out.”

All sources of literature and data show that raw milk does fall into a “riskier” category of foods.  Raw milk is not alone: raw oysters, raw sprouts, soft cheeses (raw or pasteurized), unpasteurized juices, raw or undercooked beef or poultry, and ready-to-eat foods such as deli meats are examples of other risky foods.

In lieu of banning raw milk products, some states have adopted regulations that attempt to protect public health and allow for consumer choice.  This is an approach I would suggest the following:

  1. Raw milk should be sold only on farms that are certified by the state and inspected and tested regularly.  Make ambiguous black market milk/cheese sales and “pet food sales” meant for human consumption clearly illegal
  2. Raw milk should not be sold in grocery stores or across state lines–the risks of mass production and transportation are too great; the risk of a casual purchase by someone misunderstanding the risks is too great, as well
  3. Farms should be required to have insurance coverage sufficient to cover reasonable damages to their customers
  4. Practices such as outsourcing (buying raw milk from farms not licensed for raw milk production) should be illegal
  5. Colostrum should be regulated as a dairy product, not a nutritional supplement
  6. Warning signs on the bottles and at point-of-purchase should be mandatory.  An example: “WARNING: This product has not been pasteurized and may contain harmful bacteria (not limited to E. coli O157:H7, Campylobacter, Listeria and Salmonella). Pregnant women, infants, children, the elderly and persons with lowered resistance to disease (immune compromised) have the highest risk of harm, which includes Diarrhea, Vomiting, Fever, Dehydration, Hemolytic Uremic Syndrome, Guillain-Barre Syndrome, Reactive Arthritis, Irritable Bowel Syndrome, Miscarriage, or Death, from use of this product.” (emphasis added).


Regulation alone will not solve any food safety problem–whether we’re talking about raw milk, spinach, or ground beef.

Educational materials (directed to both producers and consumers) for the safe production, handling and processing of both pasteurized and raw milk products should be developed and widely distributed.

The WAPF and the Farm to Consumer Legal Defense Fund published a “Raw Milk Production Handbook.”  These materials should be updated and enhanced in cooperation with experts from universities, especially cooperative extension programs specializing in dairy food safety.

Raw milk advocacy groups should discontinue misleading advertisements directed at consumers that include unsubstantiated claims about “grass feed” animals being free of pathogens, or statements that raw milk always kills pathogens.

Similarly, raw milk advocates should not falsely advertise that their products are a “cure all,” or that pasteurized milk contains no nutrients.  These false statements (presumably made for marketing purposes) combined with misinformation about the potential food safety risks, undermine the credibility of raw milk advocates, and serve only to mislead the consumer.

A Bit of Background

“Comparing the Food Safety Record of Pasteurized and Raw Milk Products” (now available in one file) highlights significant differences between the safety of raw and pasteurized milk products.  Here you will find a brief synopsis of the four-part series.

Part 1 – History and definitions

One-hundred years ago, milk caused about one out of every four outbreaks traced back to food or water in the US.  Today, dairy products cause the fewest outbreaks of all the major food categories (e.g, beef, eggs, poultry, produce, seafood).  Most scientists agree that the high level of safety for milk today is because of pasteurization (heat treatment to kill pathogens), and improved sanitation and temperature control during the bottling, shipping, and storage of fresh milk.

The majority (approximately 99 percent) of people in the US drink pasteurized milk, but a small group of individuals prefer their milk unprocessed (no heat treatment to kill pathogens, or other processing such as homogenization).

Many states require that milk sold to the public be pasteurized, and federal law prohibits any interstate shipment of milk that has not been pasteurized.  Raw milk proponents argue that these food safety regulations are in conflict with basic “food rights,” or the choice to buy the type of foods they want to consume, including raw milk.

Throughout decades of debate about how to regulate raw milk, the public health and medical communities have remained steadfast in their support of pasteurization as a key measure to protect public health.

Part 2:  Bacteria and other microorganisms in milk

Sick animals may carry pathogens that can be transmitted to people through their milk and cause life-threatening illnesses such as bovine tuberculosis and brucellosis.  In the US, almost all dairy and beef herds are free of these diseases, but travelers to developing areas like Mexico, Africa, and the Middle East are sometimes infected by drinking raw milk, eating raw milk cheeses, or being exposed to sick animals.

Healthy dairy animals such as cattle and goats may shed foodborne pathogens like Campylobacter, E. coli O157:H7, Listeria monocytogenes, and Salmonella in their feces.  These foodborne pathogens can cause mild illness in some people, and life-threatening or long-term debilitating disease in others including paralysis, kidney failure, and arthritis.  Children, the elderly, and people with weakened immune systems (chemotherapy, AIDS patients) are more likely to become severely ill from these pathogens.

Pasteurization involves heat treatment of milk to a temperature that destroys foodborne pathogens.  The only way to keep these pathogens out of untreated raw milk is through very strict sanitation, which can be difficult because of the large volume of feces produced by dairy animals including during the time they are being milked.

Some raw milk advocates believe that only feeding a grass-based diet will prevent shedding of pathogens in the feces of food animals, and later contamination of raw milk or meat.  Since grass-fed cows have been linked to outbreaks, and pathogens have been found in their feces and milk, it does not appear that “clean grass-fed” cows or goats are safer than conventionally raised food animals based on diet alone.

Pasteurized milk can become contaminated if the equipment fails (if the milk does not reach the right temperature for long enough), or if it is contaminated later through poor hygiene (unsanitary conditions) or cross-contamination.

Part 3.  Foodborne illnesses and disease outbreaks from milk

Both pasteurized and raw milk products have caused foodborne illnesses and outbreaks.

A review of thirty years of data in the US showed that there are a disproportionate number of outbreaks due to raw milk.  While only approximately 1 percent of the population consumes raw milk, raw dairy products caused over 50 percent of the outbreaks during that time period.

In the same analysis, most pasteurized and raw dairy-related outbreaks involved less than fifty illnesses per outbreak.

The conventional pasteurized milk supply is more vulnerable to massive (over 1,000 illnesses) food poisoning events because of its wider distribution and frequency of consumption.

Part 4.  Weighing the risks and benefits

Consumers must weigh many different factors when choosing the most appropriate dairy product for themselves and their families.

A comparison of the nutrition labels on raw and pasteurized milk purchased at a retail store shows very little difference between commercial raw, organic milk and organic or conventional pasteurized milk products.

The medical benefits of dairy products (raw or pasteurized) beyond basic nutrition are unclear. Epidemiological studies in Europe suggest that consumption of raw milk products in childhood may help prevent some allergic conditions (e.g., asthma, hay fever, eczema).

Consumers should be wary of product claims that appear to be implausible, or “too good to be true.”  For example, claims that raw milk cures everything from autism to allergies to tooth decay to lactose intolerance and heart disease. Often such broad claims are made simply to market the product, and are not based on sound medical research.

Recent data from 2000-2007 in the US on outbreaks and illnesses from milk products shows that there is currently more risk from Campylobacter and E. coli O157:H7 due to drinking raw milk compared with drinking pasteurized milk.

In the same analysis, pasteurized milk and Mexican-style soft cheeses (e.g., queso fresco) that were contaminated during or after processing were associated with illnesses, miscarriages, and deaths from listeriosis.

Multi-drug resistant salmonellosis continues to be a concern in the dairy environment, and has caused outbreaks linked to raw and pasteurized milk/cheeses, and queso fresco cheeses.

Both pasteurized and raw dairy products can be dangerous if produced under unsanitary conditions, which are more likely if the product is being sold illegally. Consumers should avoid any dairy products sold illegally, especially “black market” or “underground” raw milk/cheeses, and soft Mexican-style cheeses such as queso fresco sold by unlicensed vendors, or imported illegally into the US.

  • Bill, I’ve come to the conclusion – after much thought – that interstate retail sale of raw milk should be legalized so that it can be regulated on the same regulatory basis as pasteurized milk. The interstate regulatory framework already exists in the Pasteurized Milk Ordinance and the federal-state regulatory partnership.
    I think the prohibition model has failed. It has produced a patchwork of state regulation (or lack thereof) that is harming both producers and consumers. While I have a number of problems with how FDA is doing its job (change I don’t yet believe in), there needs to be consistency in this as in the regulation of other food commodities.
    IMHO, anyway.

  • sbemis

    I agree with a number of your points, and have made recommendations similar in many respects several times since early this year in an attempt to stimulate discussion (repeated most recently as the third comment on the October 29, 2009 posting at – see There is one huge problem with your recommendation, however, and it is spelled FDA. The federal agency simply should not be in the interstate raw milk business. It has proved itself implacably hostile to raw milk, and giving it and state agencies homogeneous control over all raw milk would simply mean the end of raw milk: FDA would see to it, that raw milk would be regulated and enforced out of existence. Nor, for that matter, should state agencies regulate cow shares and other private contracts. There should be a small-producer exemption, just as exists under the federal egg law and numerous similar state laws. I would suggest 100 lactating cows be the cut-off, but that can be decided state-by-state. Let the FDA do what it needs to do, regulating large producers and importers of the myriad of other processed foods that are chronically poisoning us – and which occasionally acutely succeed. Speaking now to S. 510 and all its progeny, leave the small farmer, and especially the raw milk farmer, alone. That said, I do agree that labeling, warnings and education are all important, as well as a clearer understanding both by producers and consumers of the benefits and limitations of grass-based dairy, particularly where the needs of the soils and proper animal husbandry might require mixed rations, including grain. I also believe there should be limits on claims by producers for raw milk; however, there should be no limit on what an individual is willing to say about his or her personal experience with raw milk. These and several other considerations are set forth in more detail in my above-linked comment from the October 29 posting (note: these are all my personal comments, and are not authorized by any organization).

  • Think your label suggestion is way too wimpy. How about this (what’s used at the dairy display cases at The Co-Op Food Stores, two large food co-ops in Lebanon, NH, and Hanover, NH), as follows:
    “Raw Milk is Not Pasteurized
    To make an informed choice, Co-op consumers need to know the following facts:
    * Raw milk potentially contains a wide variety of harmful bacteria – including Salmonella, E. coli O157:H7, Listeria, Campylobacter and Brucella – that may cause illness and possibly death.
    * This information is particularly important for persons at high risk of developing serious illness due to food borne disease, such as children, pregnant women, the elderly, and persons with weakened immune systems.
    * The U.S. Food and Drug Administration and the Centers for Disease Control and Prevention have concluded that the health risks associated with the consumption of raw milk far outweigh any benefits derived from its consumption.
    * The New Hampshire Dairy Sanitation Inspection & Licensing Program regulates raw milk sold at the Co-op.”
    Having informed and warned consumers this fully, though, you need to be willing to go the next step and let them make their own choices, and here you hem and haw.
    David Gumpert
    Author: The Raw Milk Revolution: Behind America’s Emerging Struggle Over Food Rights

    • Aussie Sutra

      Very fascinating. Do you propose that all things sold for human consumption in which the benefits cannot be shown to outweigh the risks (this would NOT include raw milk BTW!) should be banned? Coco Cola? Jolly Ranchers? Krispy Kreme Donuts? Nutella? Spray cheese? Just how far do you think the nanny state should go with our food choices?

      Meanwhile, research just released in Europe shows raw milk consumption to improve the immune function of infants by over 30%.

  • Ed Davis

    You really are milking this foodborne illness from raw milk for all of the profits it can make. I do not trust the CDC (really the state data) information regarding outbreak related to raw milk. I do not suggest that the some outbreaks have not occurred, but the survey methods of the states are too variable and biased. There are too many examples of “outbreaks from raw milk” that had more logical and reasonable vehicles. Consequently, the CDC statistics do reflect the actual events, which is supported by the extreme measures against milk producers versus other dangerous produce producers.

  • Chaunce Stanton

    Bill, thank you for this well-reasoned piece.
    As a raw milk drinker, I think your suggestions strike a good balance, arriving at “informed choice” for consumers.
    Clearly there is a market for raw milk, and I am personally frustrated by the “drug dealer” feel to raw milk transactions in states with nebulous regulatory language (Minnesota being one of them). If we can get to a place where the FDA doesn’t have to raid small, local farmers, and confiscate goods and interrupt local commerce, I think we’d all agree that would be a good thing.

  • Polak Karlo

    I am from Serbia, and this site is very interesting, to compare Europe and USA.
    I am a raw milk consumer for long time, and that is my way to care about myself and my family. I buy it from little local farmers, and there are different between milk of pregnant and not pregnant cow, young and old, kind of food she eat, water she drink… Raw milk is very sensitive product, and I can explain it with more details. But, if producer respect all of the sensitivity of process, tell that milk is danger to children is big lay. I have never had health problems related with raw milk, but have had problems related with industrial food. That is one of the reason why I am organic farmer (by now only vegetable).
    Just every nation in Europe have their own kind of raw milk cheese. In EU, only export and import of raw milk products is prohibited, but every country can have local and domestic products. In the most of cases it is legal to produce this kind of products only from your own cows.
    It look like that in USA there is double standards about food. On one side, there are bans on raw milk, on other GMO and hormones is legal, without any warning signs. GMO is totally banned in the most of European countries.
    P.S. Sorry if my English is bad. I hope that you understand the point of my comment.

  • Dina Farrell

    Know your farmer, know yours cows, no problem!
    Let people make there own choices.
    I feel sorry for people that do not have access to fresh raw milk and especially the amazing raw products such as butter and yogurt that can be made from it.

  • Aussie Sutra

    Considering the author is in agreement that there are other foods that are for sale quite freely which have an equivalent capacity for contamination, are you promoting that your regulatory suggestions be applied to all of those foods? If not, why not? Why would milk be unique? Surely if you think that raw milk should not be sold in grocery stores, then you should feel the same about oysters and deli meats.