Changes to Australian Raw Milk Legislation

Australia's Department of Food Standards has released their Draft Proposal for changes to the Raw Milk Legislation.


Some progress has been made. If it goes ahead, we'll be able to purchase some Australian raw milk products made in Australia: those that are matured for over 90 days; those that can be proven to use production processes that eliminate pathogens; and those that can be proven to have undetectable levels of pathogens.


All this sounds pretty good and reasonable, as long as the assessment techniques are fair, but on closer examination it's pretty clear that the Food Safety Authorities aren't going to be examining each dairy product for their individual production processes, but rather, will see if they tick the following boxes:

1. it starts with a high standard of raw milk (ie. no pathogens, which is fair enough)
2. it uses particular starter cultures that will immediately drop the ph of the dairy product
3. it has a continued ph or salt content that makes pathogenic growth impossible
4. it has been matured for a period of time (nominally 90 days at the moment) or is kept at a temperature that makes pathogenic growth impossible.

These indicators will naturally exclude all fresh cultured products, such as yoghurt and sour cream, and many fresh and soft cheeses such as chevre and camembert.


On the even darker side, it will be illegal to purchase fresh raw milk products, such as milk, butter and cream and it will become illegal to purchase raw goat's milk. How this will be enforced, and whether the authorities will manage to put an end to such 'black market' enterprises as herd share schemes is unclear. But the draft proposal makes it perfectly clear that this 'black market' consumption is deemed an unacceptable risk to community health.


The statistics? Supposedly OzFoodNet's Outbreak Register identified 8 outbreaks of raw milk related illness in Australia over a 6 year period (1998-2003), accounting for 101 sick people. Out of this, 4 people were hospitalised, and no one died.

Two questions:


First, why is there no information collected in these statistics on where this raw milk comes from? According to research collected by raw milk experts such as Dr Ron Schmid, often these outbreaks occur in people who've been drinking raw milk from industrial milk sources, either because they live on the farm that produced it, or are related to the farm in some way.


There is absolutely no comparison to be made between the safety of industrially produced milk and the safety of small-scale organically produced milk. (Have a look at my earlier blog on pasteurisation if you'd like to read more.) So why do statisticians keep lumping them together so we can't tell the difference?


Second, are 101 illnesses over 6 years really grounds for the outlaw of all fresh raw milk sales? And if it is, why isn't the goverment outlawing all bain marie service in restaurants and the selling of fresh seafood?


If anyone is interested in making a submission, visit here to see how. Or if you would like to add your input to a submission I'll be making, please comment on this post, or email me.