New rules for raw milk in NZ proposed

The New Zealand Food Safety Authority is proposing a framework that would allow a wider variety of raw milk products to be sold and produced in New Zealand.

Director of Standards Carol Barnao says the new raw milk products framework, if implemented, would address the concerns of some cheese producers, who are unhappy with what they see as an uneven playing field that currently allows importation of raw milk cheeses made overseas while domestic manufacturers cannot make their own equivalent products.

Currently, food regulations only allow a narrow range of raw milk products to be imported and sold. NZFSA's proposed framework for the manufacture, importation, sale and export of raw milk products would allow for the manufacture and sale of raw milk products that have been produced to an acceptable level of microbial safety from a number of milking animals including cow, goat, sheep, buffalo, horse and camel. Under this framework it is expected that not all raw milk products will be allowed to be manufactured or imported into New Zealand. For example, general sale of raw drinking milk is not expected to be permitted, although the existing allowance for up to five litres of raw milk to be purchased for personal consumption from the farm gate would stay in place.

The proposal is detailed in an NZFSA public discussion document, with submissions closing on Tuesday 30 September.

"NZFSA believes it is possible for some raw milk products to be manufactured and sold in New Zealand and equivalent products to be imported here, by ensuring they are made from milk produced under particularly stringent conditions of animal health, and by following appropriate processing hygiene and controls," Barnao says. Only products that are assessed to achieve an acceptable level of microbial safety for the general population would be permitted under the new framework.

Raw milk products are inherently higher risk foods than pasteurised products, because they have not undergone enough heat treatment to kill pathogens such as Listeria monocytogenes and E. coli, which can cause foodborne illness. Products with high moisture levels can support the survival and growth of these pathogens and internationally, illness caused by high numbers of Listeria monocytogenes and E. coli have been traced back to raw milk products.

Barnao says the proposed framework is based on risk assessments of the hazards associated with raw milk products and how these could be managed. "Letting more raw milk products onto the market would mean striking a balance between ensuring the safety of our food while giving consumers the right to choose."

Under the proposed framework, raw milk products would be categorised according to the risks they present. Examples of products that could be in category one would be those products that pose no greater food safety concerns than pasteurised cheeses, such as the extra-hard grating, Parmesan-style raw milk cheeses. Category two would contain products that are low risk for the general population but may pose a higher risk for vulnerable consumers, such as Roquefort. Risk management strategies would be put in place to manage those risks, including public awareness campaigns and further requirements for production. Category three would cover those raw milk products that cannot currently be produced to an acceptable level of safety for the general population.

Barnao says the framework recognises that some raw milk products can be produced so they pose low risk for all consumers or low risk to the general population, but also that vulnerable consumers are more at risk of falling ill from some raw milk products. These vulnerable consumers include babies and toddlers under three, the frail elderly, expectant mothers and those whose immune systems may be weakened. The new rules would include strategies to mitigate risks for these vulnerable consumers by making them aware that raw milk products can pose a higher risk than traditional, pasteurised products. Raw milk products would be labelled so these vulnerable groups can avoid them.

If the framework is progressed, a second round of consultation is scheduled to be carried out in 2009 on the specific details.

The raw milk discussion document can be found on NZFSA's website.