Raw Milk Products (including raw drinking milk and raw milk cheese)
Safe supply of dairy products in Australia
In Australia, we are fortunate to have a very safe supply of milk and dairy products. Current regulations and practices in the Australian dairy industry ensure a high level of dairy product safety.
If there are no control measures to manage potential microbiological hazards, raw milk and products made from raw milk can present a high level of risk to public health and safety. Pasteurisation has been the most effective control measure for eliminating pathogens that may be present in raw milk, including Listeria monocytogens, Campylobacter spp., Salmonella spp. and pathogenic E.coli. Before pasteurisation was introduced, dairy products including drinking milk were frequently implicated in many different food-borne illness outbreaks such as tuberculosis, typhoid and Q Fever, both in Australia and around the world.
In addition to pasteurisation, milk production, transport and dairy processing businesses in Australia are required to control potential food safety hazards associated with their business by implementing documented food safety programs.
Current requirements in the Food Standards Code for processing dairy products in Australia
Processing requirements for milk and liquid milk products and for cheese and cheese products are specified in Standard 4.2.4 – Primary Production and Processing Requirements for Dairy Products and Standard 4.2.4A - Primary Production and Processing Standard for Specific Cheeses.
Standard 4.2.4 requires milk that is to be sold as liquid milk or used in the manufacture of dairy products to be pasteurised (or equivalently processed). Alternative processing requirements to pasteurisation are permitted for cheese production under Clause 16. These include for:
- cheeses where the milk is thermised (heated to at least 62 °C for 15 seconds) and the cheese is stored for at least 90 days at 2 °C; and
- cheeses that are curd cooked (‘extra hard grating cheeses’) – the curd is heated to at least 48 °C, the final product stored for at least 6 months and has a final moisture content of less than 36%.
Standard 4.2.4A currently allows for the manufacture of Emmental, Gruyere and Sbrinz raw milk cheese according to Swiss regulations. Also permitted is raw milk Roquefort cheese produced according to French Ministerial Orders and in accordance with some specified conditions.
FSANZ assessment of raw milk products
FSANZ is aware that there is some demand for a wider range of raw milk products to be made available in Australia. As such, we are currently assessing the requirements in the Food Standards Code for the sale of raw milk products (products that have not undergone a heat treatment or equivalent process) through Proposal P1007 – Primary Production and Processing Requirements for Dairy (Raw Milk) Products.
While FSANZ recognises there is some demand for raw milk products, we must examine permissions in a structured and scientific manner to ensure public health and safety is not compromised. |
The work under this Proposal is not intended to challenge or alter the use of existing food safety systems. Rather, it is targeted towards assessing the potential use of alternative, feasible systems for the possible production and import of some raw milk products while maintaining an acceptable level of public health and safety for the Australian population. In doing this work, the Proposal aims to achieve a nationally consistent approach to permitting the production and sale of raw milk products for domestic and overseas manufacturers.
We are being assisted during the assessment processes by a Standard Development Committee comprising members from consumer, government and dairy industry bodies with expertise in the dairy industry.
FSANZ framework for assessing raw milk products – the ‘Category Framework’ approach
We have developed a framework to consider the various dairy products that are within the scope of Proposal P1007. This ‘Category Framework’ approach defines three categories of products based on the effect of production methods and the intrinsic characteristics of final products have on the survival and growth of pathogens. If the survival and growth of pathogens is more likely in some products, these products present a greater food safety risk compared to products where pathogen growth and survival is less likely.
The potential food safety risk associated with each category increases from Category 1 to Category 3, as shown below:
While cheese is the major commercial raw milk product being considered, the framework approach will endeavour to achieve outcomes that are applicable to all products.
The framework was initially developed based on preliminary results of microbiological risk assessments undertaken by FSANZ, which examined production factors and intrinsic properties of selected dairy products. Processing factors include curd cooking temperature, acidification and storage time. Intrinsic factors include moisture content, acidity and salt concentrations. The framework was presented for public consultation in a Discussion Paperin 2008.
We have now completed a technical assessment to:
- further define each category;
- identify the production and processing controls that need to be in place to manage potential microbial hazards for each of the categories; and
- establish the level of risk associated with each category if these controls are in place.
What stage has the Proposal reached?
We have completed the first stage of assessing the requirements in the Food Standards Code for the sale of raw milk products in Australia. A First Assessment Report is available which describes the progress of the Proposal to-date including the outcomes of the technical assessment to inform the Category Framework. You can access the Report via http://www.foodstandards.gov.au/foodstandards/changingthecode/documentsforpublicco868.cfm
Opportunity to input into the process
The First Assessment Report is open for public comment from 16 December 2009 until 24 February 2010. Interested parties are invited to make a submission on the information presented in the Report. To help gather information on certain areas of the assessment, we have produced someguiding questions.
Further public comment will be invited at the Second Assessment stage of the assessment process and will be advertised on the FSANZ website. In addition, individuals and organisations can be placed on an interested parties register to receive information on the progress of the raw milk products work and to be notified when public comment is invited.
If you would like to be placed on the interested parties register, please send your contact details including name, postal and email address to information@foodstandards.gov.au
Where can I find more information about the FSANZ Raw Milk Products Proposal?
All reports and supporting documents for Proposal P1007 are located at http://www.foodstandards.gov.au/standardsdevelopment/proposals/proposalp1007primary3953.cfm
Raw milk cheeses in New Zealand
The FSANZ Proposal P1007 is assessing requirements for raw milk products only in Australia as New Zealand has its own arrangements for regulating primary production businesses. The New Zealand Food Safety Authority (NZFSA) recently introduced new legislation that allows for certain raw milk cheeses to be produced in and imported into New Zealand. Information about these new requirements can be found on the NZFSA website www.nzfsa.govt.nz/dairy/subject/unpasteurised-milk-products.
Updated December 2009