Raw Milk-Associated Public Health Risks

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Raw Milk-Associated Public Health Risks. January 24, 2007 Dairy and Egg Safety Division Office of Plant and Dairy Foods Center for Food Safety and Applied Nutrition U.S. Food and Drug Administration. No, It’s Not New… - PowerPoint PPT Presentation

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  • Raw Milk-Associated Public Health Risks

    January 24, 2007

    Dairy and Egg Safety DivisionOffice of Plant and Dairy FoodsCenter for Food Safety and Applied NutritionU.S. Food and Drug Administration

  • RAW MILK No, Its Not New There have been and continue to be Public Health Risks of Consuming Raw Milk and Raw Milk Products

  • Outbreaks 2004 National Association of State Departments of Agriculture (NASDA) Survey indicated 29 States have recorded milkborne outbreaks traceable to raw milk consumption.

    In 2005-2006 more than 10 outbreaks caused by the consumption of raw milk or raw milk cheese were reported to FDA.

  • Raw Milk Safety Concerns Information Available On the Safety of Raw Milk (with a Word about Pasteurization) presented to the 2005 National Conference on Interstate Milk Shipments (NCIMS) by Div. of Dairy and Egg Safety/CFSAN/FDA.Includes Myths and Claims with Science Responses

    http://www.cfsan.fda.gov/~ear/milksafe.html

  • Raw Milk Safety Concerns Information AvailableFDA has been providing information and assistance to states dealing with raw milk issues, including to legislative committees.DDES Director, John Sheehan, J.D., B.S. Dy Sci., provided FDA written Testimony on Raw Milk to Ohio House of Representatives Agriculture Committee, May 24, 2006. http://www.ohioagriculture.gov/dairy/documents/FDATestimonyRawMilk.pdf

  • Raw Milk CheeseFood Safety Risk

  • Long History of RiskFDA and other Federal and State agencies have acknowledged a long history of the risks associated with the consumption of raw milk. Raw milk (no bactericidal/bacteriostatic treatment, apart from cooling) is a vehicle for transmission of pathogens, such as:Listeria monocytogenes Brucella spp. E. coliCampylobacter spp.Mycobacterium bovis Coxiella burnettiSalmonella spp.

  • National Policy and Position Statements U.S. Food and Drug Administration (FDA)Centers for Disease Control and Prevention (CDC)National Conference on Interstate Milk Shipments (NCIMS)National Association of State Departments of Agriculture (NASDA)Association of Food & Drug Officials (AFDO)

  • FDA Sale/Consumption of Raw Milk-Position Statement (M-I-03-4)

    strongly advises against the consumption of raw milk"Raw milk, no matter how carefully produced, may be unsafe." In the court case Public Citizen v. Heckler, 653f. Supp. 1229 (D.D.C. 1986), the federal district court concluded that the record presents "overwhelming evidence of the risks associated with the consumption of raw milk, both certified and otherwise". The court stated that the evidence FDA has accumulated concerning raw milk "Conclusively shows that raw and certified raw milk are unsafe" and "There is no longer any question of fact as to whether raw milk is unsafe". http://www.cfsan.fda.gov/~ear/mi-03-4.html

  • CDC

    Memo from CDC to FDA:

    CDC strongly endorses regulatory efforts to restrict the sale of raw milk and soft fresh cheeses made from unpasteurized milk to consumers. We also support health education efforts to inform consumers of the health risks of these products.

    CDC continues to receive reports of foodborne illness outbreaks due to unpasteurized milk and soft fresh cheeses, such as queso fresco, often made from unpasteurized milk.

  • 2005 NCIMS Resolution 10Therefore, Be It Resolved: That the NCIMS, due to the serious public health concerns, discourages the consumption of raw milk and encourages states to pass laws or adopt administrative rules that prohibit the sale of raw milk directly to the household consumer and to the unlawful manufacturers of unlawful dairy products; Be It Further Resolved: That the NCIMS continues to support the motto of the conference, which is To assure the safest possible milk supply for all the people.

  • NASDA Policy Statement

    National Association of State Departments of Agriculture (NASDA) issued policy statement September 18, 2006.

    only pasteurized milk, milk products and properly aged cheeses should be sold for human consumption.

    Defines Sale

    http://www2.nasda.org/NR/exeres/480DACB7-AC68-4980-AB3C-3F50BCEC252F.htm

  • NASDA Policy Statement Milk Quality: Pasteurization - Inasmuch as apparently healthy cows and goats can shed in their milk organisms which are pathogenic to human beings and may cause diseases such as brucellosis, Campylobacter enteritis, salmonellosis, and tuberculosis; and inasmuch as milk handlers may introduce pathogenic agents during the handling of unpasteurized milk (including certified raw milk), only pasteurized milk, milk products and properly aged cheeses should be sold for human consumption.

  • NASDA Policy Statement contd Sale includes distribution by use of animal or herd sharing, bartering, exchange or agistment. In those states where the sale of unpasteurized milk is authorized, those products should be labeled, "Not Pasteurized and May Contain Organisms that cause Human Disease."

  • AFDO Position StatementAssociation of Food & Drug Officials (AFDO) December, 2006

    Supports Mandatory Pasteurization

    http://www.afdo.org/afdo/position/PosStmt-2006-RawMilk.cfm

  • From AFDO Position StatementBy building consensus with program managers at the state and local levels, AFDO is able to establish united positions on national food safety matters that affect all of us.

    AFDO supports mandatory pasteurization for all milk and milk products intended for direct human consumption except where alternative procedures to pasteurization are provided (i.e. curing of certain cheese varieties) to ensure the safety of finished products.

  • From AFDO Position Statement contdFoodborne illnesses related to the consumption of fresh, soft, raw milk cheeses such as queso fresco and queso cotija point out the hazards of consuming raw milk products. These products are popular among people from societies where milk pasteurization is not as common as in the United States, and the product is distributed mainly through unregulated practices.While mandatory pasteurization requirements will not stop black market distribution, they will curtail mass distribution and facilitate raising the awareness of potential consumers.

  • Pasteurization

    Pasteurization destroys pathogenic bacteria

    Such as Listeria monocytogenes

  • Why Pasteurize?Pasteurization was first implemented to destroy Mycobacterium bovis, which causes systemic tuberculosis in humans. Pasteurization temperatures were later increased to destroy Coxiella burnetii, which causes Q-fever.Pasteurization can destroy emerging pathogens, such as E. coli O157:H7 and Salmonella typhimurium DT-104, which cause serious illness and are difficult to treat due to resistance to many common antibiotics (Cornell Univ.).

  • Pasteurization RegulationsIn 1987, FDA implemented a ban on the interstate sale of raw milk. (21 CFR 1240.61)

    However, each state regulates the sale of raw milk within its jurisdiction (intrastate commerce).

    Some states permit the sale of raw milk to local retail food stores or directly to consumers from the farm or at community events.

  • CFR Pasteurization RegulationThe federal regulation describing mandatory pasteurization requirement is 21 CFR 1240.61.

    In promulgating this regulation, FDA made a number of findings relative to raw milk, including the following: "Raw milk, no matter how carefully produced, may be unsafe." (52 FR 29514, Aug. 10, 1987)

  • Methods of Raw Milk SalesCow SharesHerd SharesCow Boarding Co-OpsPet Food Sales

  • Cow SharingCow sharing or cow leasing has occurred in states where intrastate sale of raw milk is prohibited.Consumers buy a percentage of a cows milk production for a fee and then receive a certain amount of raw milk per week.

  • Survey of Raw Milk Sales 2005March, 2005, John A. Beers, Program Supervisor, Virginia Department of Agriculture and Consumer Services, Division of Animal and Food Industry Services surveyed 50 U.S. states and Puerto Rico to determine the extent of regulatory requirements on the sale of raw milk and cheese products.

  • Cow Sharing

    4 states* allow animal shares with licensing or permitting and inspection:

    Arizona, Idaho, New York and Washington

    7 states and Puerto Rico ban animal shares as a means to obtain raw milk:

    Florida, Iowa, Montana, Nevada, North Carolina, West Virginia and Wisconsin

    The remaining 39* states do not have specific laws or regulations pertaining to animal shares as a means to obtain raw milk.

    *Adjustment made to survey per Illinois

  • Legal Actions Wisconsin has prosecuted several cases of "cow share" schemes under their State law.

    Indiana currently has Cease and Desist Orders on Sales of Raw Milk and Cow Sharing.

  • FDA Warning Letters Organic Pastures Dairy Company, Fresno, California, February, 24, 2005Distribution of unpasteurized milk, buttermilk, butter, cream and colostrums in interstate commerce, in finished form for human consumptionViolation PHS Act, Title 42, U. S. Code, Sections 264(2) and 271(a) and 21 CFR 1240.61

  • FDA Warning Letters White Egret Farm, Austin, Texas, December 15, 2005Distribution of unpasteurized goat milk in interstate commerce, in finished form for human consumptionViolation of PHS Act, 42 U.S.C. 264(2) and 272(a) and 21 CFR 1240.61

  • FDA Warning Letters Dee Creek Farm, Woodland, Washington, May 2, 2006Dairy Farm caused to be delivered into interstate commerce unpasteurized milk, in finished form for human consumptionViolation of PHS Act, 42 U.S.C. 264(2) and 272(a) and 21 CFR 1240.61

  • Raw Milk Confiscate