The Food Standards Agency’s (FSA) public consultation on the future availability of raw drinking milk comes to a close in a few days on 30 April. Artisan Food Law has covered many different issues surrounding raw milk over the last 12 months and more, so now seems a good time to bring some key ones together and provide, in no particular order, 10 good reasons for securing the future of raw milk.
A part of our diverse natural foods heritage
- Raw milk from pasture fed cows is an entirely different food to pasteurised industrial commodity milk. Raw whole milk has a complexity and depth of flavour which provokes the ‘wow’ factor on first tasting. Sample raw milk from different breeds – Shorthorn, Friesian, Jersey, Guernsey and Montbeliarde cows, for example – for the full experience. The pasteurised, homogenised and intensively farmed industrial milk to which so many are now used to soon “resembles watered-down whitewash and tastes as though it has had a flavour bypass”. 
Health and nutrition
- The health and nutritional value of raw milk is perhaps most written about and debated. There is no shortage of anecdotal evidence about its beneficial effects. There is also evidence drawn from scientific studies that raw milk has a protective effect on the development of asthma and allergies, but the fact is more research is needed, such as that being undertaken by Massey University in New Zealand, so we understand the benefits and mechanisms at play.
Proven safety record
- Raw milk has a proven safety record – there have been no reported outbreaks of illness associated with raw drinking milk in the UK since 2002 and in the 10 years before less than 1% of reported outbreaks of foodborne illness were associated with drinking raw milk. This is a tribute to the high standards of production adopted by raw milk producers and their scrupulous implementation. Since 2002, at a very conservative estimate which does not include dairy farmers themselves, well over 10 million litres of raw milk have been consumed without a single cause for concern.
Not a high risk food
- It is a myth that raw milk is a high risk food and many other foods pose higher risks. Canadian researcher Nadine Ijaz demonstrated how inappropriate evidence has long been mistakenly used to affirm the myth that raw milk is high risk and concluded:
… public health bodies should now update their policies and informational materials to reflect the most high-quality evidence, which characterizes this risk as low.
- The consumer demand for raw milk is real. The FSA’s own survey showed that while 77% of those surveyed supported the continued sales of raw drinking milk, some 19% wanted to buy raw milk and yet only 3% did so regularly. The potential for a six-fold increase in sales would appear to exist.
The shortest possible food chain
- The present legal controls over raw milk are fit for purpose and are not, as often claimed, outdated – see Artisan Food Law for details. In short, sales of raw milk must be “at or from the farm premises … to the final consumer”. The farmer retains ownership and control of the milk, and remains responsible for milk quality from its source in the production unit until delivered into the hands of the consumer. A food chain comes no shorter or can have greater integrity. It is the FSA’s interpretation of the law which needs a more rational and consistent approach.
Raw milk vending machines
- Vending machines are safe and great way of getting raw milk to the final consumer. The FSA’s objections to vending machines are not based on hygiene risks but the erroneous interpretation of the law and the belief that vending machines cannot be placed in a retail space. An agreed voluntary code of practice with producers is the best way to address any concerns.
Fair price for milk
- Raw milk producers can get a fair price for their milk, well above commodity milk prices. The supermarkets, led by Tesco, have driven down the retail price of commodity milk to less than 25p a pint and it is dairy farmers who ultimately lose out.
A future for small dairy farms
- The sale of raw milk represents a viable future for many small dairy farms. Steve Hook of raw milk producer Hook & Son explained how selling raw milk made him a price-maker, not a price-taker, not only could he command a fair price he could have a relationship with his customers and get feedback.
Consumer freedom of choice
- Finally, who decides what you should or should not be free to consume? The choice should be an informed one, but ultimately your choice. If you prefer not to consume raw milk that should be your decision. The choice must also be a real one and not one dictated by the lack of any opportunity to purchase raw milk, safe routes to market within the existing law should be permitted – online sales over the Internet and raw milk vending machines are particular cases in point.
There were moves to ban the sale of raw drinking milk in 1989 and 1997. The climate today is very different, not least with the resurgence of interest in what we eat, the provenance of our food and its journey to our plate. The FSA, no doubt taking into account the current context and lack of evidence on which to act, has expressed a preliminary view for a future which sees the continued supply of raw drinking milk. Nonetheless the FSA’s preliminary view is to be welcomed and it is hard to see how the Board of the FSA could not fail to agree with it when it takes a final decision later this year.
The reasons above concern raw cow’s drinking milk, not raw milk from sheep or goats which are not subject to the same level of regulation. There is, however, no evidence of any problem with raw milk from these species, so where is the need for change?
A few days of the FSA’s public consultation remain. If you are one of the 77% of people who support the continued sale and availability of raw drinking milk, even if you would personally not choose to drink it, you have a brief opportunity left to let the FSA know. Simply send a note to Freddie Lachhman at the FSA, either by e-mail to RDM@foodstandards.gsi.gov.uk or write to him at: Food Hygiene Policy, Food Standards Agency, 1st Floor, Aviation House, 125 Kingsway, London WC2B 6BH.
Make sure the message gets through by 30 April that raw drinking milk is here to stay and the choice whether to consume it must be one which is real and meaningful.
 Joanna Blythman, What to Eat, Fourth Estate, 2012, p160