Question of the Week
Answer: Thank you for contacting ATTRA for information about testing raw milk and your dairy goat herd to ensure safety.
As we discussed, you are aware of the risk of drinking raw milk. I understand that you have been reading about the health benefits of drinking raw milk as opposed to pasteurized. I believe that most food products have some risk attached to them; for instance, milk can be contaminated AFTER pasteurization, and raw milk that is very healthful as it is drawn from the animal can become unsafe due to improper chilling and poor sanitation in handling. We always have to be careful to treat food with respect, even when we know the animal is healthy and even though we believe the food is nutritious.
Having said that, there are some precautions we producers can take to make it likely that our product is safe. Referenced below are regulations in various states pertaining to the sale of raw milk. I will summarize some of the main points.
From Utah’s Administrative Code R70-330. Raw Milk for Retail:
1) animals examined by veterinarian before inclusion in the raw milk supply, and every 6 months thereafter
a) California Mastitis Test (CMT)
b) udder health
c) general health evaluation
2) Tuberculosis testing; 60 days prior to the beginning of milk production, retest each year
3) Brucellosis testing—vaccinated or testing negative within 30 days prior to beginning of each lactation
4) bulk tank testing at least 4 times yearly with brucella milk ring test. Any positive test means each animal in the herd must be tested with official blood test
5) persons handling milk should not be sick, and cannot have exposed infected cut or lesion on their arms or hands
6) all milk shall be cooled to 41 degrees F. or less within two hours after milking. If it is pooled, blend temperature shall not exceed 50 degrees F.
7) Somatic Cell Count (SCC) shall not exceed 350,000 cells per milliliter (ml).
8) bacterial standard: Standard Plate Count (SPC) of no more than 20,000 per ml.; Coliform count shall not exceed 10 per ml. (no note of how often to test)
9) no drug residue or other adulteration
My understanding is that you don’t intend to sell milk, but want to use it for your family. If you are interested in selling raw milk, though, you will be interested in the Texas Administrative Code (which is a bit more lax than Utah’s). In Texas you can sell raw milk off your farm if you have a license. I like the way the code is written in an understandable manner, with justifications; they state the reasons for the rules. The phone number for the regulatory office is 512-834-6758.
I called the office and found them very helpful; I spoke with Mr. Jim Fraley. He told me that while it is legal to sell raw milk if you have a license, they do not advocate it due to the health risk. I told him that you understood that. He said that for licensed dairymen, there is a charge of $400/2 years for the license, and then testing is done monthly, inspections every two months. In addition to the SCC and other tests noted in the regulations, there is a monthly test for pathogens. These pathogens are:
• E. Coli
• E. Coli 257
• Staph. Aureus
The regulations state pathogenic tests will be done quarterly, but in practice they do it every month.
Mr. Fraley suggested you check with the El Paso health department, 915-543-3538; they can do the basic tests (not the pathogenic ones, he said). Ask them about fees. Also referenced below is a fee schedule from the Tarrant County lab. I think the tests are more expensive than I expected, and they do not list pathogenic tests, either. I asked Mr. Fraley how you could get those done, and he didn’t know but suggested you check your Yellow Pages for “commercial laboratories” and then call a few to inquire.
Other than the animal tests (TB, brucellosis, CMT) you don’t need to do individual testing, you can submit a pooled sample from your whole herd. That is what they do for licensed dairies, of course. I encourage you to call Mr. Fraley if you have any further questions; he was glad to answer questions when I called and was very courteous.
Texas Department of State Health Services. Milk Group information. 2 p.
Texas Administrative Code. Title 25. Part 1. Chapter 217. Subchapter B. Rule §217.27-33.
Utah Administrative Code R70-330. Raw Milk for Retail. 3 p.
NOFA Massachusetts: Programs: The Campaign for Raw Milk. 6 p.
NOFA/Mass Raw Milk Campaign brochure. Raw Milk Production. 2 p.
Massachusetts 330 CMR 27.00: Standards and Sanitation Requirements for Grade A Raw Milk. 19 p.
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