The Raw Milk Debate - Submissions close February

Food Standards News Summer 2009
from The Newsletter of Food Standards Australia New Zealand No. 71

Raw milk products

FSANZ is assessing Primary Production and Processing (PPP) Requirements for Dairy
(Raw Milk) Products, which we have listed as Proposal P1007. We have now released our
First Assessment Report for public comment.

Because of the known potential for raw milk to be contaminated with pathogens, raw milk,
and any products made from it, can present a high level of risk to public health and safety.

Pasteurisation has long been the most effective method of eliminating pathogens that may
be in raw milk. However, issues such as market access, consumer demand for raw milk
products and the need for national consistency in legislation, have led us to look at
alternative production and process controls that could manage the risks posed by raw milk.

We developed a framework for this assessment process, which groups raw milk products
in terms of the effect that processing factors and the properties of the final product have on
pathogen survival and growth. We created three categories:

o Category 1 - products in which pathogens will be eliminated
o Category 2 - products where pathogens may survive but will not grow
o Category 3 - products where pathogens can survive and grow.

Our scientific assessment used this category framework and identified production and
processing controls that need to be in place to manage potential microbial hazards. This
assessment has found that, for Category 1 and 2 products, it is possible to put processing
and production controls in place to provide for a low level of risk.

However, for Category 3 products, which include raw drinking milk, the level of risk cannot
be reduced sufficiently and such products present a high level of public health and safety
risk. We considered these risks unacceptable and therefore propose that these products
should not be permitted.

The findings of our assessment are in our report, which is currently open for public
comment. You can find this report, the 'First Assessment Report' for Proposal P1007, and
other supporting documents, on the FSANZ website at

http://www.foodstandards.gov.au/foodstandards/proposals/proposalp1007primary3953.cfm


We will accept submissions until 24 February 2010. Instructions for making a submission
are in the report.

The next stage of the work, which involves us releasing a Second Assessment Report for
public comment, will involve developing draft amendments to existing Standard 4.2.4
Primary Production & Processing Standard for Dairy Products. For this we will work with
the dairy industry and government enforcement agencies to determine how any changes to
permissions will work in practice, and undertake a full cost-benefit analysis. We expect to
complete this work later in 2010.

The idea of PPP standards emerged in 2000 when the Council of Australian Governments
agreed to major changes to the food regulatory system, one of which was a mandate for
FSANZ to address food safety across the entire food chain where appropriate.

http://www.foodstandards.gov.au/_srcfiles/FSN%2071web2.pdf