Additional Raw Milk Facts from FTCLDF

File: RawMilk--Fact-sheet-state-issues.pdf Rev. 0405-2013 Page 1 of 6

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Support Access to Raw Milk

Consumers are increasingly seeking out raw milk as a natural, unprocessed food. Unfortunately,

some people in the conventional dairy industry and medical fields are seeking to restrict people’s

informed choices through banning or unreasonable restrictions on the sale of raw milk. We urge you

to reject such efforts and support consumer choice.

The justification for bans or severe restrictions on raw milk is that it is supposedly dangerous, but this

is not supported by the data. It is important to recognize that any food can be the source of foodborne

illness under the wrong conditions. When thousands of people became sick from spinach, peanut

butter, and cantaloupes, no one urged that we ban these products or severely limit consumers’ access

to them. The issue isn’t whether some people have become sick from raw milk on occasion –

the issue is whether raw milk poses such an unusually high level of risk that it somehow

justifies the government interfering with people’s choices.

All of the data discussed below is from the CDC for the 13-year period from 1998 to 2010, based on

the online database at http://wwwn.cdc.gov/foodborneoutbreaks. Nationwide, in that 13-year period,

there were 1,414 illnesses, 80 hospitalizations, and no deaths attributed to raw milk.a

To put these numbers in context, there were 2301,076 illnesses, 10,317 hospitalizations, and 223

deaths reported to the CDC in that time period from all foods. [wwwn.cdc.gov/foodborneoutbreaks]

Consider the illnesses attributed to a few other foods:

 Fruit salad: 1,323 illnesses, 29 hospitalizations, and 1 death;

 Tuna: 1,415 illnesses, 41 hospitalizations, and 3 deaths (not including raw tuna or sushi);

 Pizza: 1,614 illnesses, 20 hospitalizations, and 3 deaths.

The numbers of illnesses attributed to fruit salad, tuna, and pizza are similar to those attributed to raw

milk during this time period – with the exception that, unlike these foods, raw milk has not caused

any deaths. While more people may consume these foods occasionally, few people consume these

foods day-in and day-out, in contrast to raw milk.

Consumption rates:

How many people drink raw milk? According to a CDC survey, an average of 3% of the population

has drunk raw milk within the last 7 days. Foodborne Active Surveillance Network (FoodNet)

Population Survey Atlas of Exposures (2006-2007), www.cdc.gov/foodnet/surveys/FoodNet

ExposureAtlas0607_508.pdf. That translates to approximately 9.4 million raw milk consumers

nationwide. So, out of 9.4 million raw milk drinkers, approximately 110 allegedly become sick each

year from raw milk, or 0.001% annually.

a A few of the larger outbreaks during this time period are listed as having multiple causes, such as “1% milk,

unpasteurized; sauces, unspecified” or “butter ; goat cheese/chevre, unpasteurized; goat milk, unpasteurized; whole milk,

unpasteurized”, making it unclear whether it was raw milk or some processed product that was truly the causative agent.

We have erred on the side of including these outbreaks, thus overestimating the number of illnesses properly attributable

to raw milk.

File: RawMilk--Fact-sheet-state-issues.pdf Rev. 0405-2013 Page 2 of 6

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Pasteurized milk also carries some risk of foodborne illness

What about the numbers for pasteurized milk? In the same time period (1998-2010), 2,227 people

became ill, 27 people were hospitalized, and 3 died from pasteurized milk. A large number of people

drink pasteurized milk, so the relative risk is not high. But no food is risk-free.

In fact, a massive foodborne illness outbreak was linked to pasteurized milk in the 1980s. In 1985,

there were over 16,000 confirmed cases of Salmonella infection that were traced back to pasteurized

milk from a single dairy. Two surveys estimated that the actual number of people who became ill in

that outbreak were over 168,000, “making this the largest outbreak of salmonellosis ever identified in

the United States.”

[Ryan, CA et al. Massive outbreak of antimicrobial-resistant salmonellosis traced to pasteurized

milk. J. American Medical Assn. 258(22):3269-74 (1987),

http://www.ncbi.nlm.nih.gov/pubmed/3316720?dopt=Abstract

Raw milk is a separate issue from fresh raw cheeses, which pose a higher risk

Some industry groups have presented higher numbers of illnesses allegedly due to raw milk,

including two deaths. But these numbers are not attributable to raw milk, but rather to all raw dairy

products. This is an important distinction because of the extensive problems reported from raw queso

fresco, often imported from Mexico or made under unsanitary conditions at home and therefore

nicknamed “bathtub cheese.” See Queso Fresco: Cheese with a reputation,

http://www.foodsafetynews.com/2010/05/queso-fresco-cheese-with-a-reputation. Many of the

illnesses and all of the deaths that the industry attributes to raw milk were in fact linked to raw queso

fresco, which is an illegal product.

Conclusion

The data, as opposed to the rhetoric, shows that raw milk does not pose an unusually high risk of

foodborne illness.

There are multiple principles that support continued, reasonable access to raw milk:

 Americans have a right to decide what they feed themselves and their families.

 Direct sales of raw milk provide a reasonable income for small family farms, often making

the difference between being able to continue farming and going out of business.

 Supporting family farms supports rural economies in general by promoting local businesses

and keeping money circulating locally.

File: RawMilk--Fact-sheet-state-issues.pdf Rev. 0405-2013 Page 3 of 6

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Attachment 1: Scientific studies have documented benefits

from raw milk

The claim that raw milk has no benefits over pasteurized milk is, on its face, false. Does anyone

contend that cooked strawberries or spinach are no different than raw strawberries or spinach? It’s

well-accepted that heating foods not only changes the taste, but destroys enzymes and certain

nutrients.

In addition, there are published, peer-reviewed scientific studies showing health benefits from raw

milk.

Several recent studies in Europe have found that drinking “farm” (raw) milk protects against

asthma and allergies. [See Riedler, J. et al. 2001. Exposure to farming in early life and

development of asthma and allergy: a cross-sectional survey. Lancet 358:1129-33. Perkin, M.R.

and D.P. Strachan. 2006. Which aspects of the farming lifestyle explain the inverse association with

childhood allergy? J Allergy Clin Immunol. 117(6):1374-8. Waser, M. et al. 2006. Inverse

association of farm milk consumption with asthma and allergy in rural and suburban populations

across Europe. Clinical and Experimental Allergy 37:661-670. Perkin, M.R. 2007. Unpasteurized

milk: health of hazard? Clinical and Experimental Allergy 37:627-630.]

Raw milk retains higher levels of Vitamins A, B, C, and D than pasteurized. [See Haug, A., A.T.

Hostmark, and O.M. Harstad. 2007. Bovine milk in human nutrition—a review. Lipids Health

Disease 6:25 (“Proteins and peptides are heat sensitive, and their bioactivity may be reduced by

pasteurization of milk. Heating of milk may also result in the formation of potentially harmful new

products, i..e. when carbohydrates in milk react with proteins.”). Wong, D.W.S. and W.M.

Camirand. 1996. Structures and functionalities of milk proteins. Critical Rev Food Science Nutr.

36(8): 807-844. Runge, F.E. and R. Heger. 2000. Use of microcalorimetry in monitoring stability

studies. Example: Vitamin A Esters. J Agric Food Chem 48(1):47-55. Kilshaw, P.J., L.M. Heppell,

and J.E. Ford. 1982. Effects of heat treatment of cow's milk and whey on the nutritional quality and

antigenic properties. Arch Disease Childhood 57: 842-847 (heat treatment destroyed all of the

Vitamin B12, about 60% of the thiamin and Vitamin B6, 70% of the ascorbic acid, and about 30% of

the folate). Gregory, J.F. 1982. Denaturation of the folacin-binding protein in pasteurized milk

products. J Nutr. 112: 1329-1338. Effect of several heat treatments and frozen storage on thiamine,

riboflavin, and ascorbic acid content of milk. J Dairy Sci. 66: 1601-6. Rajakumar, K. 2001. Infantile

scurvy: a historical perspective. Pediatrics 108(4):E76. Hollis, B.W. et al. 1981. Vitamin D and its

metabolites in human and bovine milk. J Nutr. 111:1240-1248. See also Levieux, D. 1980. Heat

denaturation of whey proteins: comparative studies with physical and immunological methods. Ann

Rech Vet. 11(1): 89-97 (“Nutritionists believe that high losses of nutritive value occur in heated

proteins following cross-linking since high cross-linked proteins cannot be degraded by digestive

enzymes.”).]

Moreover, there are numerous testimonials about the benefits of drinking raw milk. See

http://www.realmilk.com. While these do not provide scientific evidence of benefits, it is clear that

individuals choose to expend significant time and money to drink raw milk because they see a

benefit.

File: RawMilk--Fact-sheet-state-issues.pdf Rev. 0405-2013 Page 4 of 6

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Attachment 2: Improving legal access to raw milk will not

increase foodborne illness outbreaks

Some groups have argued against allowing or expanding legal access to raw milk on the grounds that

if you make it easier to get raw milk legally, more people will drink raw milk, and more people will

get sick. While that argument is intuitively appealing, it is contradicted by the CDC’s data.

The attached chart shows the consumption of raw milk in 10 states, the raw milk laws in each state,

and the incidence of foodborne illnesses.

First, note that in every state, the number of illnesses attributed to raw milk is a very small

percentage of the total number of foodborne illnesses.

Second, there is no pattern indicating that making raw milk legally accessible increases

consumption. Maryland (where raw milk sales are illegal) had the exact same percentage of people

who had drunk raw milk within the last 7 days as California (where raw milk can be sold in grocery

stores). And Georgia, where raw milk can only be sold as pet food, had the highest consumption

rates of all.

Third, there is also no pattern of increasing rates of consumption correlating to increasing

illnesses. The two states with the highest rates of consumption -- Tennessee and Georgia -- had

lower rates of raw milk illnesses than the three states with the lowest rates of consumption --

Minnesota, Colorado, and Connecticut.

How can this be true? The most likely reason is that the risk of foodborne illness from raw milk is

low enough that the outbreaks are sporadic and occasional. Because raw milk is not a high-risk food,

the incidences of illness are too low to show a pattern.

The data directly contradicts the assertion that increasing legal access to raw milk will increase the

number of people who get sick.

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Chart of Raw Milk Consumption, Legal Status, and Illness Rates

State Percentage of

population

consuming

raw milkb

Legal state of

raw milk

# outbreaks

allegedly

traced to raw

milk, 1998-

2010c

# illnesses

allegedly

traced to raw

milk, 1998-

2010

Total # foodborne

illnesses, 1998-

2010, excluding

multi-state

outbreaksd

% of foodborne

illnesses

allegedly traced

to raw milke

Minnesota 2.3% Farm sales

legal

4 16 10,021 0.16%

Colorado 2.4% Herd shares

legal

5 143f 8,330 1.71%

Connecticut 2.7% Retail sales

legal

1 14 3,023 0.46%

Oregon 2.8% Farm sales

legal

1 0-18g 7,514 0 – 0.23%

California 3.0% Retail sales

legal

4 45h 35,313 0.12%

Maryland 3.0% No legal

salesi

0 0 7,883 0

New Mexico 3.4% Retail sales

legal

1 20j 1,017 1.96%

New York 3.5% Farm sales

legal

5 66k 14,802 0.44%

Tennessee 3.5% Herd shares

legal

2 7 6,464 0.1%

Georgia 3.8% Legal only as

pet food

1 8 8,515 0.09%

10 State total 3% 24 299-337 102,882 0.29 – 0.32%

b Foodborne Active Surveillance Network (FoodNet) Population Survey Atlas of Exposures. Atlanta, Georgia: U.S.

Department of Health and Human Services, Centers for Disease Control and Prevention (CDC), 2006-2007 (identifying

the percentage of people who had consumed raw milk within the last 7 days)..

www.cdc.gov/foodnet/surveys/FoodNetExposureAtlas0607_508.pdf

c Note: an "outbreak" according to the CDC can involve as few as 2 people.

wwwn.cdc.gov/foodborneoutbreaks/Default.aspx

d The total foodborne illnesses are actually higher than listed in this chart because all data attributed to multi-state

outbreaks was excluded for these purposes because the CDC table does not indicate how many illnesses were attributed to

each state.

e Because of the undercounting of the total number of foodborne illnesses (see note 2), the true % of illnesses allegedly

traced to raw milk is lower than indicated.

f In the same time period in Colorado, there was an outbreak linked to pasteurized milk that sickened 200 people

g Oregon was part of a multistate outbreak allegedly traced to raw milk in Nov. 2005. The total number of illnesses in

that outbreak were 18, but we cannot determine how many occurred in Oregon.

h In the same time period in California, there were two outbreaks linked to pasteurized milk that sickened 1,744 people.

i Note that even though raw milk sales are illegal in Maryland, 3% of the Maryland residents surveyed stated that they

drank raw milk. Prohibition doesn’t work.

j The New Mexico illnesses are from a single outbreak listed as being from "1% milk, unpasteurized; sauces, unspecified"

in a restaurant.

k In the same time period in New York, there were two outbreaks involving pasteurized milk that sickened 18 people.

File: RawMilk--Fact-sheet-state-issues.pdf Rev. 0405-2013 Page 6 of 6

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Attachment 3: Raw milk does not pose a threat to

conveFile: RawMilk--Fact-sheet-state-issues.pdf Rev. 0405-2013 Page 1 of 6