The terms "real milk," "farm fresh milk," and "raw milk" are all used to refer to milk that has not been heated in the pasteurization process. But the terms encompass much more! Both farmers and consumers generally use these terms to refer to milk that has not been pasteurized AND:
- has intact cream particles. In other words, it hasn't been homogenized, and the cream rises to the top. You can see how much (or how little) cream is in your milk!
- is from cows and goats raised on pasture, whether they are 100% grass-fed or supplemented with grain.
- is from family farmers, not factory farms.
Safety of Raw Milk
***Note: Scientific studies are listed at the end of the page
• EXCELLENT SAFETY RECORD IN TEXAS: Raw milk has an excellent safety record in Texas. According to the CDC, between 1998 and 2008, there were only two reported cases of illness from raw milk. In contrast, during the same time period, there were 465 illnesses reported just from raw oysters. In fact, there were over 12,000 foodborne illnesses reported in Texas in that time period (not including multi-state outbreaks), traced to such foods as strawberries, mangos, ice cream, cake, beans, lettuce salads, salsa, cheeses, pot pie, chicken salad, hot dogs, deli meats, and beef brisket. Any food carries some risk of foodborne illness, but as shown above (see Existing Regulations, below), licensed raw milk farmers take extensive precautions to ensure the safety and quality of their product.
• OTHER STATES: Sales of raw milk are legal in more than half of the states. Ten states allow the sale of raw milk in grocery stores, which would not be allowed under HB 46.
• PROTECTIVE COMPONENTS OF UNPROCESSED MILK: Raw milk contains numerous components that assist in:
- Killing pathogens in the milk (lactoperoxidase, lactoferrin, leukocytes, macrophages, neutrophils, antibodies, medium chain fatty acids, lysozyme, B12 binding protein, bifidus factor, beneficial bacteria);
- Preventing pathogens from being absorbed across the intestinal wall (polysaccharides, oligosaccharides, mucins, fibronectin, glycomacropeptides, bifidus factor, beneficial bacteria); and
- Strengthening and modulating the immune system (lymphocytes, immunoglobulins, antibodies, hormones and growth factors).
Note that breast milk is raw. The safety and health benefits of breast milk have been well documented.
• LOSS OF PROTECTIVE COMPONENTS DUE TO PASTEURIZATION: Many of these anti-microbial and immune-enhancing components are greatly reduced in effectiveness by pasteurization.
• MODERN ADVANTAGES IN RAW DAIRY PRODUCTION: Compared to 50 years ago, dairy farmers today can take advantage of many advancements that contribute to a much safer product, including rotational pasture grazing, milking machines, effective cleaning systems, and refrigeration. Milk and herd disease testing techniques are also more thorough than when pasteurization became commonplace.
Health Benefits of Raw Milk
• BENEFITS IN HUMAN STUDIES: In early studies involving humans, raw milk was shown to help protect against infection, rickets, and TB; and children receiving raw milk had better growth than those receiving pasteurized milk.
• BENEFITS IN ANIMAL STUDIES: In an early animal study, animals fed raw milk had better growth, less anemia, fewer signs of anxiety and stress, and fewer signs of nutrient deficiency than animals fed pasteurized milk.
• ASTHMA AND ALLERGIES: Several recent studies in Europe have found that drinking “farm” (raw) milk protects against asthma and allergies.
• RAW HUMAN MILK: Infants and premature babies on pasteurized human milk did not gain weight as quickly as those fed raw human milk; problems were attributed to pasteurization’s destruction of lipase. In another study, neonates given raw human milk had a markedly lower incidence of infection than those who received pasteurized human milk and formula.
• LACTOSE INTOLERANCE: In a survey of milk drinkers in the state of Michigan, over 80% of those advised by a healthcare professional that they were lactose intolerant were able to consume raw milk without problem.
• POSITIVE TESTIMONIALS: There are hundreds of testimonials involving reversal of failure to thrive in infants; allergies, asthma and behavior problems in children; and digestive disorders, arthritis, osteoporosis and even cancer in adults.
• NUTRIENTS RETAINED IN RAW MILK:
Vitamin A: Beta-lactoglobulin, a heat-sensitive protein in milk, increases intestinal absorption of vitamin A. Heat degrades vitamin A.
B Vitamins: Significant percentages of Vitamins B6, B12, thiamin and folate are destroyed by heat treatment, although the specific percentages found vary from study to study. In addition, the folacin-binding protein in raw milk is rendered ineffective during pasteurization and processing.
Vitamin C: Heating leads to a loss of Vitamin C in pasteurized milk. “Without doubt, the explosive increase in infantile scurvy during the latter part of the 19th century coincided with the advent of use of heated milks and proprietary foods. … Hess [a pediatrician] was able to effect a cure for scurvy by providing raw milk or orange juice or potatoes.”
Vitamin D: Vitamin D is present in milk in protein-bound form, which may be lost during pasteurization.
Economic Benefits of Raw Milk
Direct farm-to-consumer sales of raw milk can mean the difference between a net loss on the farm and the ability to provide a reasonable income for the farm family. Below are numbers drawn from actual Texas dairy farmers. These numbers do not cover the full range of potential situations, but provide a sample of the real-world economics of dairy.
Every $1 earned on the farm equates to $5-$7 for the local community. By providing a fair income for rural dairy farmers, Grade A sales of raw milk can help our struggling rural economies.
CONVENTIONAL DAIRY FARM
• Cost of production:
100-cow dairy: $1.50/gallon
• Price for milk sold for pasteurization: $1.13/gallon (current price) to $2.19/gallon (2008 high price)
• Net: ranges from 33 cents/gallon loss to 69 cents/gallon profit
Price is based on market forces outside the farmers’ control. While consumers pay $3 to $6.50 for a gallon of pasteurized milk, farmers see only a small percentage of that money.
In 2002, dairy farms in the U.S. went out of business at the rate of 16 farms per day. Dairy farms are currently facing a crisis.
DIRECT SALES OF RAW MILK
• Cost of production:
100-cow dairy: $1.64-$2.36/gallon
10-cow dairy: $9/gallon
30-goat dairy: $8.50/ gallon
Plus capital investment in milking barn that meets Grade A Standards: $40,000 and higher
• Price for raw milk sold directly to consumers: $5/gallon to $10/gallon for raw cow’s milk; up to $14.50/gallon for raw goat’s milk
• Net: ranges from $1/gallon to $6/gallon profit
Price is not subject to typical market fluctuations, but is generally based on factors within the farmers’ control, such as the breed of cow and extent of pasture grazing. The farmer captures the full retail value.
Our proposed change is narrowly tailored to address the marketing barrier created by the current restriction on the location of sales. We are not recommending any changes to the extensive regulations placed on Grade A producers that address health and safety concerns, found at 25 TAC Chapter 217. Below are some highlights of the existing regulations that would remain unchanged.
- Dairy farms, both facilities and records, are inspected twice every six months (217.26a)
- If a condition is found that poses an imminent health hazard, the department is required to suspend the dairy’s permit immediately (217.26d)
- Samples of the milk are collected at least every six weeks and tested for bacterial counts, coliform counts, somatic cell counts, water adulteration, and cooling temperatures (217.27)
- At least twice every six months, the samples are also tested for pathogenic bacteria
- At least four times every six months, the samples are also tested for antibiotics
- Grade A raw milk must meet the following standards (217.28)
- Cooled to 45 degrees or less within two hours (also regulated in 217.29s)
- Somatic cell counts not to exceed 750,000 per milliliter (ml) for cow’s milk or 1,000,000/ml for goat’s milk
- Bacteria limits of 20,000 per ml (not applicable to cultured products)
- Coliform not to exceed 10 per ml
- Pathogen limit of zero
- Section 217.29, Sanitization Requirements for Grade A Raw Milk, has 20 subparts, which have in turn multiple sub-subparts, of rules (217.29). Some highlights include:
- Abnormal milk shall be discarded, and animals which show evidence of abnormal secretion must be isolated from the non-abnormal milk and equipment cleaned (a)
- Milk barn must meet detailed construction and cleanliness requirements (b,c, e-g)
- Animal yard shall be properly graded to prevent standing pools of water or waste, housing areas maintained to prevent soiling of animals udders and flanks (d)
- Clean water in sufficient quantity for the dairy operations (h)
- Containers, utensils and equipment must meet standards for construction (type of materials), cleaning, sanitization, storage and handling (i-m)
- The animal and the milking equipment must be free from contamination (n-p)
- People doing the milking must have clean hands, wear clean outer garments, and be free of infection (q, r)
- Effective insect and rodent control is required (t)
- Animal Health: All herds shall be tested and found free of tuberculosis and brucellosis before any milk is sold; herds shall be retested at least every 12 months; cattle herds participate in brucellosis ring testing by Texas Animal Health Commission. For other diseases, the department may require physical, chemical, or bacteriological tests. (217.20)
- Plans for Grade A Raw for Retail Milk Dairy Farms shall be submitted to the department for approval before work is begun (217.30)
- More than half of the States in the US allow for legal sales of raw milk, and ten States (Arizona, California, Connecticut, Maine, Missouri, New Hampshire, New Mexico, Pennsylvania, South Carolina, and Washington) allow raw milk to be sold in grocery stores -- which would not be allowed under HB 46. HB 46 is a moderate bill that simply removes an artificial marketing barrier while preserving the requirements for raw milk safety.
CDC data: http://wwwn.cdc.gov/foodborneoutbreaks/
Arnold, D. et al. 2002. "Antiadenovirus activity of milk proteins: lactoferrin prevents viral infection." Antiviral Res. 53:153-158.
Campanella, L. et al. 2009. "Determination of lactoferin and immunoglobulin G in animal milks b new immunosensors." Sensors 9: 2202-2221.
Cornish, J. et al. 2004. "Lactoferrin is a potent regulator of bone cell activity and increases bone formation in vivo." Endocrinology 145(9):4366-74.
Cross, M.L. and H.S. Gill. 2000. "Immunomodulator properties of milk." British J. of Nutrition 84 (Suppl. 1): S81-S89.
Dionysius, D.A. and J.M. Milne. 1997. "Antibacterial peptides of bovine lactoferrin: purification and characterization." Journal of Dairy Science 80, 667-674.
Gregory, J.F. 1982. "Denaturation of the folacin-binding protein in pasteurized milk products." J Nutr. 112: 1329-1338.
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.”).
Hollis, B.W. et al. 1981. "Vitamin D and its metabolites in human and bovine milk." J Nutr. 111:1240-1248.
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).
Korhonen, H., P. Marnilla, and H.S. Gill. "Milk Immunoglobulins and complement factors." British J. of Nutrition 84 (Suppl. 1): S75-S80.
Ladd, M. et al. 1926. "The relative efficiency of certified and pasteurized milk in infant feeding." Arch. Ped. 43:380-85 (found that babies fed raw milk had less frequent rickets and better weight gain compared to those fed pasteurized milk).
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.”).
Newman, J. 1995. "How breast milk protects newborns: some of the molecules and cells in human milk actively help infants stave off infection." Scientific American. Dec. 1995, pp.76.
Parliamentary Intelligence. 1937. "Milk Pasteurization: The Poole Experiment." Lancet 1141-43 (comments in the House of Lords referencing a study showing that raw milk decreases the likelihood of tooth decay and increased resistance to tuberculosis, compared to consumption of pasteurized milk).
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.
Perkin, M.R. 2007. "Unpasteurized milk: health of hazard?" Clinical and Experimental Allergy 37:627-630.
Pettifor, J.M. et al. 1986. "Mineral homeostasis in very low birth weight infants fed either own mothers’ milk or pooled pasteurized preterm milk." J Pediatr Gastroenterol Nutr. 5(2):242-53.
Rajakumar, K. 2001. "Infantile scurvy: a historical perspective." Pediatrics 108(4):E76.
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.
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.
Said, H.M., D.E. Ong, and J.L. Shingleton. 1989. "Intestinal uptake of retinol: enhancement by bovine milk Beta-lactoglobulin." Am J Clin Nutr. 49:690-694.
Scott, E. and L.E. Erf. 1931. "Ohio tests prove natural milk is best." Jersey Bulletin 50:210-211, 224-226 (documented normal growth, good health and gentle disposition in rats fed an exclusive raw milk diet. Rats fed pasteurized milk were anemic, had slow growth, rough coats, loss of vitality and weight, and were very irritable, often showing a tendency to bite when handled).
Seifu, E., E.M. Buys and E.F. Donkin. 2005. "Significance of the lactoperoxidase system in the dairy industry and its potential applications: a review." Trends in Food Science & Tech. 16(4):137-154.
Shah, N.P. 2000. "Effects of milk-derived bioactives: an overview." British J of Nutrition 84 (Suppl. 1):S3-S10.
Wong, D.W.S. and W.M. Camirand. 1996. "Structures and functionalities of milk proteins." Critical Rev Food Science Nutr. 36(8): 807-844.
"Antibiotic-like action of essential fatty acids." 1985. Can. Med. Assoc. J. 132:1350 (referencing Naranyanan, I. et al. 1984. Randomised controlled trial of effect of raw and holder pasteurized human milk and of formula supplements on incidence of neonatal infection. Lancet 2:1111-1113).
"Effect of several heat treatments and frozen storage on thiamine, riboflavin, and ascorbic acid content of milk." J Dairy Sci. 66: 1601-6;