Is Raw Milk Increasing Risk in Our Food Supply?

By Michael J. Pearsall

Recently, there has been trend in the marketplace to produce, sell and consume raw, or unpasteurized, milk products. This is being driven by a belief by some consumers that pasteurized milk is not as wholesome as raw or unpasteurized milk—in spite of the facts from many studies that have shown that pasteurization does not significantly change the nutritional value of milk and dairy products.

milkThis movement toward a preference for raw milk products is being adopted by concerned parents, vegetarians and organic food enthusiasts. While they are entitled to their beliefs, the introduction of raw milk for packaging—without pasteurization—into the same facilities producing pasteurized milk products could pose a very real risk to the safety of the food processing and delivery system.

People worldwide have been consuming pasteurized milk since the early 1900s because it is nutritional and safe. The pasteurization process reduces or eliminates pathogenic bacteria, that is, species of Listeria, Campylobacter, Escherichia coli and Salmonella, that cause a number of diseases that lead to sickness, disability and/or death, particularly in younger children.

If the consumers of raw milk products want to accept these disease risks and consume a raw milk product, that is their privilege. But how does this small number of buyers impact the rest of us?

Ask yourself this question: Where are most raw milk products are processed? Answer: In the same facilities that process pasteurized milk products. This means that raw milk products are being introduced to the normally “clean” side of the dairy operation. In this case, “clean” means all apparatus after the kill step of pasteurization that comes into contact with the product.

These dairy products could be milk, cheese, yogurt, sour cream, butter or others. Knowing that pathogenic bacteria could be in the raw milk, contaminants are purposely being introduced into what was previously the clean side of the operation. Thus, the risks of infection have increased for the general public.

If a dairy processor decides to begin producing raw milk products, they must adjust their processes to ensure they can prevent the raw milk products from contaminating the safe dairy products with their control. This will involve a thorough hazard analysis as to how the safe products can become contaminated within the manufacturing process.

Pathogen risks post-pasteurization will obviously increase, therefore, sanitation methods and microbiological testing regimes may have to change. Not to mention the handling of raw milk products in processes such as aging, warehousing and transport. The practices would be kin to the storage and handling of allergens.

When there is such a dramatic change such as the introduction of a known high-risk material into a system that has spent years lowering their risks of food contamination, pre-emptive planning should be in place regardless of the public demand put on the system. This may come in the form of regulation as is prevalent in many states.

In any case, a dairy processor that has been producing pasteurized products who is considering introducing raw milk products to their product portfolios should weigh gains in profits with the much higher risks to the safety of their customers and the potential financial liability to their business.

Michael J. Pearsall is food safety business development director, UL-DQS Inc. He has over 30 years of professional experience in food and beverage processing, packaging material manufacturing, product development and implementation, process improvement, quality system development and auditing.

*This article first appeared  in January 7th Food Safety Magazine eDigest.

Food Safety and the Media

Anyone who is keeping up with the political primaries is well aware of actions taken by politicians along the campaign trail.  Every misstep is documented, scrutinized and goes viral rapidly.  The same can be said about food safety missteps at the manufacturing level.  Now that we have the technology to test for outbreaks rapidly and medical experts have the knowledge of identifying common food borne illnesses it seems like we are hearing about people getting sick much more often than previous times.  Case in point, the Jensen Farms facility that has been accused of improperly processing cantaloupe and causing the death of 30 people and causing illness in approximately 150.

Food borne illness is a very serious issue that affects an untold number of people each year and it still remains poorly understood.  More than half of the known outbreaks are caused by unknown sources.  The reality is that our media focuses on topics such as the Listeria outbreak when there were more than five million cases of Norovirus and more than one million Salmonella cases that received significantly less attention.

Even the best implemented HACCP plan by a manufacturer comes to an end once the product has been shipped out the door.  The does not mean that food safety ends at the manufacturing site, it is just as important for basic GMPs to be followed at home such as hand washing and avoiding cross contamination between raw and cooked products.

By:  Jill Carson, Lead Auditor

Food Packaging, the Last Frontier in Food Safety

In the recent decades food manufacturers have started taking a more active interest when it comes to their packaging suppliers, such as supplier audits, and including them in traceability studies.  Food manufacturers quickly realized that packaging suppliers were just as important as food ingredient suppliers and therefore deserved the same attention.  As a result, packaging suppliers began implementing Good Manufacturing Practices as well as Hazard Analysis and Critical Control Point (HACCP) plans.

Food packaging is responsible for protecting food products from outside influence and damage, to contain the food, and to provide consumers with ingredient and nutritional information.  Traceability, convenience, and tamper indication are secondary functions of increasing importance.  The goal of food packaging is to contain food in a cost effective way that satisfies industry requirements and consumer desires, maintains food safety, and minimized environmental impact.

With such an important function, food packaging should be required to meet applicable GMP standards as required by the other food chain suppliers.  UL DQS offers a certification audit according to the BRC/IoP standard specific to food packaging suppliers.  Companies that have already achieved ISO9001 certification may already meet many of the requirements of the BRC/IoP standard.  This standard has a comprehensive scope that covers areas of quality, sanitation and safety that is applicable to both low risk and high risk food contact and non-food contact packaging.

Food Safety: On-site Training Plan Needed for Farmers

The industry’s reaction to the Jensen Farm cantaloupe issue seems reminiscent of a scene from the Keystone Cops. It is an example of our ability to “capture the cow” and indiscriminately blame someone instead of focusing on how to “keep the barn door shut”.

The FDA stated a need for the cantaloupe industry to align its practices with it’s “Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables,” (click here to read more) and the corresponding guide for “Fresh-cut Fruits and Vegetables” (click here to read more). The Western Growers and United Fresh Produce Association reviewed existing research on cantaloupe safety to determine the most effective measures in preventing contamination. (click here for more information) These possible solutions, in my opinion, do not address one of the core issues.

No mention is made of the immediate need to develop an on-site training plan for growers in applying systems that can minimize the risk of these dramatic occurrences no matter the size of the operation. They need help. These growers, whether they have two or two hundred employees, should be looked at as a manufacturer of food that supplies to a global marketplace. This requires disciplined adherence to global good agricultural practices and food safety standards. This is how members of the supply chain can work to “keep the barn door shut” with a plan that prevents the “cow” from escaping in the first place!

Submitted by Michael Pearsall, Director of Food Safety Services, UL DQS Inc.