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Report On Raw Milk To The Board Of Supervisors -- January 24, 2001

LOS ANGELES COUNTY - DEPARTMENT OF HEALTH SERVICES

PUBLIC HEALTH

REPORT ON RAW MILK

GRADING, TESTING AND PUBLIC HEALTH IMPLICATIONS

JANUARY 2001

State and Local Codes and Standards

 The State Food and Agriculture Code contains the provisions which govern milk production and sale.  The State code provides that pasteurized and unpasteurized (raw) milkare graded and designated into three classes, Guaranteed at&, Grade A milk and Certified milk.

Guaranteed raw milk includes requirements that 1) the health of the cows be determined at least once a month by a State inspector or other milk inspection service approved by the State, 2) the milk is produced on dairy farms scoring at least 90 percent on the dairy farm scorecard, 3) the milk is bottled on the premises where produced and delivered to the store shelf for sale to the consumer within 30 hours of production., and 4) the milk does not contain more than 10,000 bacteria per milliliter,

Grade A raw milk includes requirements that 1) the health of the cows be determined by State inspection at least every two months, 2) the milk is produced on farms scoring at least 95 percent on the scorecard, and 3) the milk does not contain more than 15,000 bacteria per milliliter.

Certified raw milk must conform to the standards set by a county milk commission.  The Los Angeles County Milk Commission (Milk Commission) has set standards for bacteria, which are more stringent than State standards for Guaranteed or Grade A raw milk.  Total bacteria may not be greater than 15,000 per milliliter, which is consistent with the State standard for Grade A.  The Milk Commission also set a standard that coliform bacteria may not be greater than 10 per milliliter, while the State has no coliform standard.  However, the key difference between the Milk Commission's County standards adopted in 1998 for Certified raw milk and State standards for Guaranteed and Grade A raw milk is that the Commission requires the raw milk to be held for 48 hours after bottling to test for salmonella and other bacteria.  If initial tests are positive for Salmonella or exceed (do not meet) bacteria standards, the milk may not be distributed.  In contrast, the State rules permit immediate distribution.  Recalls occur if periodic tests are positive for pathogens or after it has been determined that raw milk is associated with human disease.  Due to the more lenient State standards for Grade A and Guaranteed raw milk, much of the product may be consumed prior to a recall.  Key elements of the standards and testing are summarized in the following table.

RAW MILK STANDARDS AND TESTING 

State regulationsrequire a warning label on all raw milk, to include the following:

 Raw unpasteurized milk and raw milk dairy products may contain disease-causing micro-organisms.  Persons at highest risk of disease from these organisms include newborns and infants; the elderly; pregnant women; those taking corticosteroids, antibiotics or antacids; and those having chronic illnesses or other conditions that weaken their immunity.

 State law allows counties or cities to require pasteurization of milk.  Currently, the County code requires pasteurization, but exempts Certified raw milk.  Pasadena and Long Beach, as local health jurisdictions, permit all types of raw milk to be sold.

 Milk products, such as butter and cheese, made from raw milk, are under State regulation and inspection. Cheese produced for interstate shipment is regulated by the federal g

overnment.

 Testing of Raw Milk

 The State tests samples of all market milk, including all raw milk, once a month.  Samples are obtained at the bottler's bulk tank or from bottled product ready for market, The State runs tests for totalbacteria, coliform bacteria, Salmonella, Listeria, E-coli, somatic cells, water and fat content and tests for the presence of drugs (antibiotics).  Under existing procedures, positive tests for pathogenic organisms trigger recalls.  Repeated high bacteria counts are to lead to notices, repeat testing, and eventual revocation of ability to sell, until acceptable levels of bacteria are attained, Many of these tests require a number of days to complete.  Thus positive results are not known until the raw milk has been on the shelf and most has been sold to consumers.

 Certified raw milk, even though produced under the oversight of a county milk commission, is also tested by the State, with the frequency and tests described above.

The Milk Commission requires testing Of Certified raw milk which is more stringent fl= State requirements, either in frequency of testing or types of tests.  In the early part of the 1995, the Milk Commission required daily samples, taken from the holding tank, to be tested f6r total bacteria, coliform bacteria, and E-coli.  In the mid-1990s, the Milk Commission added Salmonella testing twice a month.  In 1998, when new technologies made more rapid tests for Salmonella feasible, the Milk Commission required testing of each batch of milk for Salmonella, using a test which produced results in 48 hours, The Milk Commission also mandated that the milk be held, pending the results of the Salmonella and other bacteria tests.

 Raw Milk production in California

 The Milk Commission is the only such commission inthe State and may certify milk produced in Los Angeles County and contiguous counties.  For many years it has Certified themilk of Stueve's Dairy in San Bernardino County, bottled most recently by Alta Dena as "Stueve's Natural." However, no Certified raw milk has been bottled for over a year.  In presentations before the Milk Commission, Stueve's Dairy representatives indicated that they are attempting to identify an alternate bottler, because the bottling relationship with Alta Dena was discontinued.

 The only other dairy known to produce raw milk in California at this time is Claravale Farms, which produces Grade A raw milk from a dairy in Watsonville.  Under current State law, if Claravale wished to produce Certified raw milk from that dairy, a milk commission would have to be established in Santa Cruz County or a contiguous county.

 Other Jurisdictions

 Staff surveyed a sample of other counties to determine whether they permitted raw milk to be sold.  Alameda County prohibits sale in unincorporated areas and three cities in Alameda County, Fremont, Livermore and Alameda, also prohibit all raw milk sales.  Humboldt County also prohibits the sale of raw milk.  The counties of San Mateo, Santa Clara, Orange, Riverside, Ventura, Santa Cruz and San Francisco permit raw milk sale, as do the cities of Long Beach and Pasadena.

 San Francisco and Santa Cruz, which allow see, require additional signage in stores, that warns of the dangers of raw milk to those at risk.

A 1995 survey by the State Department of Food and Agriculture found that 22 states and the District of Columbia prohibit sale of raw milk, 19 states including California permit sale of raw milk, 3 other states permit its sale on the farm only, and 7 states did not reply.

 Health Risks

 Diseases which may be transmitted by micro-organisms in raw milk or raw milk products include salmonellosis, campylobacteriosis, brucellosis, yersiniosis, listeriosis, staphylococcal enterotoxin poisoning, streptococcal infections, tuberculosis and E. Coli 0157:H7 infection.  Although the initial impact of the disease is on the individual consumer, many pathogens may be transmitted from person to person, including to family members, and patrons of restaurants if the individual is a food handler.  The fetus of a pregnant woman may be at risk.  Some of the diseases associated with the pathogens can lead to death, particularly among vulnerable persons.

 SamoneIIa Dublin, one strain of the, bacterium, appears to be particularly severe for very young children, the elderly or those with underlying medical conditions.  Listeriosis is particularly dangerous for pregnant women and can cause pre-term labor, miscarriage, still birth, or neonatal death.

 The federal Centers for Disease Control and Prevention estimates that no more than five percent of food home illnesses are reported to local health departments.  Because salmonellosis and many other intestinal diseases are under reported and because there is often no definitive identification of the source of the pathogen, (existing data do not accurately report the number of diseases caused by consuming raw milk or raw milk products each year or how significant this disease is for the overall population.  However, there are reports from several outbreaks and other disease surveillance.

 In 1985, an outbreak of Listeriosis was linked to soft cheese produced in Los Angeles County, which contained raw milk 142 cases were reported, 93 of which were in pregnant women or their children and 49 in non-pregnant adults.  There were 48 deaths, including 20 fetuses, 10 neonates, and 18 non-pregnant adults.

 Since 1973, 394 cases of Salmonella Dublin, the type of salmonella most commonly affecting cows, have been reported in Los Angeles County.  Of these, 101 (25.6%) have been consumers of raw milk.  This is a much greater percentage than would be expected if raw milk did not increase the risk of infection.

 During 1995, ten persons statewide in California were confirmed with Salmonella typhimurium var. Copenhagen, who stated that they had consumed raw milk in the week prior to their illness.  Molecular fingerprinting determined that the strain from ill persons was the same as found in raw milk,

 A study of Salmonella Dublin cases in California from 1990 through 1983, conducted by researchers at the UCLA School of Public Health, found that more than 37 percent of reported Salmonella Dublin infections were acquired from raw milk.  In addition, immunocompromised persons who of insured unpasteurized milk had a 20 times higher risk for serious illness or death than I healthy persons.

 A report by researchers at the federal, Centers for Disease Control and Prevention, published in 1998, identified 46 disease outbreaks associated with raw milk reported by the states from 1973 to 1992.  Forty of these were in states where the sale of raw milk was legal.

 We were not able to obtain accurate data on either the number of persons consuming raw milk and raw milk products or the total amount bring sold in Los Angeles County recently.  The total raw milk production of Claravale Farm is estimated to be between 130 - 200 gallons per day.  We assume that the amount being sold in Los Angeles County will increase if Grade A and Guaranteed raw milk may legally be sold.

Results of Testing of Raw Milk

Prior to 1998, the Los Angeles County Milk Commission did not require holding raw milk for 48 hours for testing prior to distribution.  Therefore, recalls were initiated after distribution and sale whenever State or local test results indicated a pathogen in the milk - At least 51 recalls of raw milk were conducted statewide from 1977 to 1998.  Twenty of these recalls were based on the monthly State tests, ten were based on tests by the Los Angeles County Milk Commission, nine were based on tests by other local or state health laboratories, and laboratory information is not available for the other twelve.  Fifty recalls were for Salmonella and one was for Listeria.

 In the eleven month period, July 1, 1998 through May 31, 1999, with the 'hold and test' requirements in place, raw milk received for bottling did not meet County Milk Commission standards fifty-eight percent (58 %) of the days (193 of 333) and was not distributed as raw milk.  All but one of the days where the milk did not meet standards were due to the total bacteria or coliform bacteria.  The-re was one instance where initial testing revealed Salmonella, which was confirmed.  Since the product was held, a time-consuming recall was averted and no public exposure to the Salmonella occurred.

 Information was obtained from the State Department of Food and Agriculture about the Claravale Dairy in Watsonville.  The laboratory results from State tests from March 1999 through December 2000, indicated that the total bacteria detected in raw whole milk exceeded the State standard for Grade A raw milk in eight of seventeen tests, Similar results were found in raw nonfat milk and raw cream.  State protocols should have resulted in Claravale being ordered to cease production until total bacteria were consistently within acceptable limits.  However, the State failed to implement its own standards.

 Although there is no State standard for coliform bacteria, the Claravale results exceeded those standards established by the Milk Commission on several occasion.  Specific tests for Salmonella, Listeria, and E. Coli 0157:H7 in September and October 2000 were negative.

 In addition to the laboratory testing of market milk, the State also inspects dairies for the health of the herds and the sanitation of the dairy facility.  Correspondence from the State dairy inspector to Claravale Dairy in the past year indicates substantial health issues with the operation, such that the dairy was not even scored under the State format, yet allowed to continue operations.

 Health Benefits of Raw Milk

 A review of the literature found no scientific study which demonstrates medical or health benefits of raw milk.  However, many consumers of raw milk claim that drinking raw milk has improved their overall health and the consumers are very strong advocates for their right to consume these products.

JS:lm

01/24/01

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