Bulletin #1030, Raw Milk Production: Guidelines for Maine Licensed Dealers

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By Donald E. Hoenig, VMD, University of Maine Cooperative Extension

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Table of Contents

producer feeds dairy cows fresh hay

For many years, Maine has been one of more than 20 states in the U.S. that allows the sale of raw (not pasteurized) milk to the public by producers/dealers that are licensed with the Maine Department of Agriculture, Conservation and Forestry. Once licensed by the Department, a dealer is permitted to sell raw milk from the farm, at retail stores, and at farmers’ markets. Sale to restaurants is not permitted. This document is intended as a checklist for those dealers who are already licensed by the Department, although it may prove useful as well for individuals contemplating becoming licensed in the future. The Department’s licensing standards can be found on the Quality Assurance & Regulations: Dairy Inspection page or by calling 207.287.7627.

While milk is probably the most highly regulated, inspected, and tested food product in this country, it is nevertheless highly perishable. Milk is an ideal medium to support bacterial growth and, if not handled properly, its quality can quickly deteriorate making it unsuitable and even unsafe for human consumption. Raw milk, of course, does not have the added pasteurization (heating) step to reduce the levels of bacteria and other microorganisms. Thus, raw milk dealers need to be even more meticulous with sanitation and hygiene throughout every stage of production with particular emphasis on cow health, barn and processing room cleanliness, and overall husbandry.

Always remember: Unless an animal has mastitis (which can be readily apparent by the appearance of abnormal milk or be subclinical, meaning the milk looks normal), milk inside the udder is an ultra-filtrate of blood and is, therefore, a sterile product. Once it leaves the udder through the streak canal at the end of the teat, bacteria and other microorganisms almost immediately contaminate it. Our goal as food producers is to minimize this contamination through the use of best management practices.

The purpose of these guidelines is to provide a number of management practices and recommendations to help producers evaluate their operation and identify areas for improvement.

The Cow/Goat/Sheep

1. Animal comfort: Provide a clean, dry, comfortable bed for every animal.

Yes­­­­_____ No_____

2. Bedding: Is the bedding dry? Try the knee test: If you kneel down on the bedding, are your knees wet when you get up? If so, the bedding is too wet. The best bedding for minimizing mastitis is kiln-dried shavings but this type of bedding is often expensive and in short supply. Sand is a good alternative and often more readily available but it needs to be raked frequently with new sand added as needed to keep stalls dry.

Yes­­­­_____ No_____

3. Stalls: Are the stalls large enough for the animals to lie down and rise without injuring themselves or stepping on other animals? In cattle, the presence of hygromas (large, fluid-filled swellings on the outside of the hock joints) indicates that animals are injuring themselves as they lie down or rise and also can be associated with mattresses used without bedding.


4. Free Access to High-Quality Feed: Animals should have feed in front of them at all times so that if they wish to eat, they can. One of the most distressing things that we see on many farms is animals standing around with nothing to do but stand around. They also need to have the choice to eat whenever they want and lie down to chew their cud.

Yes­­­­_____ No_____

5. Water: Is water available at all times? Is it easily accessible in more than one place so that those dominant animals can’t prevent more submissive animals from having access? Are waterers cleaned on a frequent basis to reduce contamination and enhance palatability? Has the well been tested in accordance with Department guidelines and has it passed these tests? Note: The Department only tests for the presence of coliform bacteria. If water consumption is an issue, further quality testing may be warranted.

Yes­­­­_____ No_____

6. Animal Health Plan: Do you have a working relationship with a food animal veterinarian? Is your veterinarian aware that you are licensed to sell raw milk? Has your veterinarian developed a herd/flock health management plan for your animals including vaccination for diseases prevalent in our region, parasite control, and plans for conducting routine procedures on your animals (dehorning, castration, etc.)? Is emergency care available?

Yes­­­­_____ No_____

Milking Procedures

1. The number one best practice to simplify milking procedures is to have a clean animal entering the parlor/milking area. A hygiene scoring system used by the National Dairy FARM Program (Farmers Assuring Responsible Management) can be found on the National Dairy FARM Program website. The goal on a system using this 1-4 scale (1 is clean, 4 is dirty) is for 90% or more of the animals to score 3 or less.

Hygiene Score_____

2. Another basic principle to keep in mind is to minimize water use when prepping animals for milking. Excessive water use can give bacteria “legs” making it easier for them to enter the milk.

Minimize water_____

3. Wear nitrile gloves. They’re cheap and it’s easier to keep clean than your bare hands and they’ll also protect your hands over time from chapping (which can be a source of bacteria, especially Staph).

Glove use_____

4. If teats are dirty when the animal enters the milking stall, they should be washed with a single-service paper towel or single-service washcloth that has been dipped in an udder sanitizing solution. Once again, keep water to a minimum. If teats are relatively clean (that is, no evidence of manure or gross contamination), they can be brushed off manually.

Clean teats_____

5. Predip with a National Mastitis Council (NMC)-approved predip.

Brand of Predip_____

6. Allow a 30-45 second contact time.

Adequate Contact time_____

7. Check the fore milk while the dip is still on the teats. Forestripping allows you to check for mastitis; removes milk that has been sitting in the teat since the last milking; and gives the animal better udder stimulation resulting in a more effective milk letdown.


8. Wipe off the dip with a single-service paper towel or a single-service washcloth making sure to wipe the ends of the teats as well as the sides.

Single Service Towel_____

9. Attach the milking unit. The time elapsed from when udder preparation begins to when the milking unit is attached should be about 60-90 seconds.

Unit attachment_____

10. Remove the milking unit promptly when milk flow has ceased. “Machine stripping” is acceptable for 10-15 seconds but should be kept to a minimum and is usually not necessary.

Timely unit removal_____

11. Post dip with an NMC-approved post dip. The best practice is to use separate dip cups for post dipping.

Brand of post dip_____

12. Avoid using a dipper that allows the dip to flow back into the reservoir. Although dips are disinfectants, they can become contaminated over time and lose effectiveness as they become contaminated over time with bits of organic matter.

Proper dip cups_____

13. If possible, dip the teats and don’t spray them. Spraying wastes dip (large quantities just go into the air) and, unless great care is taken, the coverage is not as thorough as dipping.

14. Empty and wash the dippers at the end of each milking.

Wash dippers twice a day_____

15. Always remember: If the teats aren’t thoroughly clean at the beginning of milking, they will be at the end. Why? Because during milking all the dirt will have been washed off the teats into the milk that now sits in your bulk tank.

Tests Conducted by the Department of Agriculture on Your Milk (and what they mean)

In addition to the quality tests conducted by your dairy processor (if you are selling some of your milk for pasteurization), the Maine Milk Rule requires that certain tests be carried out on your milk on a regular basis. While the dairy processor may test your milk on a more frequent basis, the Department conducts quality tests on your raw milk a minimum of four times in a six-month period. These tests and an explanation of them are as follows. Note: one milliliter equals one cubic centimeter or 1/29 of an ounce.

1. Standard plate count (SPC): The SPC (sometimes also called the “raw count”) tests for the total amount of aerobic bacteria (those that need air to grow) in your milk. A sample of your milk is incubated on an agar plate at 90 degrees F for 48 hours and then the analyst counts how many bacterial colonies have formed. The legal limit for this is 100,000 colony forming units per milliliter of milk. Most producers have values well below 10,000 and less than 5,000 should be a goal. High SPCs are often indicative of poor cleaning of equipment. But remember, even at a count of 5,000, this means that there are still 5,000 bacteria in one milliliter of milk. Or, 5 million in a liter (about a quart).

SPC below 5,000_____

2. Somatic cell count (SCC): Somatic means “body” and this count measures how many white blood cells (indicators of infection) and epithelial cells (those that line the inside of the udder) there are in your milk. The legal limit for this count is 750,000 cells per milliliter but the European Union standard is 400,000. Since much of our milk is exported to the EU, the U.S. has effectively been requiring a 400,000 standard for several years. A high SCC is an indication of infection (mastitis) in the udder. Mastitis causes not only inflammation in the udder but can result in severe drops in milk production. In fact, every time the SCC doubles over 100,000, milk production drops by 400 lbs. per lactation. For example, a cow with an SCC of 800,000 is losing 1200 lbs. of milk per lactation. There will always be white blood cells and epithelial cells in the milk so the goal is not to achieve a count of 0 but to try and maintain an SCC below 200,000.

SCC below 200,000_____

3. Coliforms: The coliform test measures the number of coliform bacteria in milk. Coliform bacteria are present in large numbers in manure and in fact, they are essential for the digestion of food. Since they are found in such high quantities in manure, they are widely distributed on farms. They also can be important mastitis pathogens and a particular strain of coliform, E. coli, 0157:H7, has been implicated in numerous human disease outbreaks linked to the consumption of raw milk. The coliform test is a critical measure of farm sanitation and, if elevated, is a cause for great concern. Maine’s legal limit for coliforms is no more than 10 per milliliter.

Coliform below 10_____

4. Drugs: No positive drug test results are permitted on any of the tests performed in the Maine Milk Lab. Usually, these tests detect beta lactam (penicillin-like) antibiotics.

Zero tolerance on drug tests_____

5. Temperature: Milk must be cooled to 45 degrees F or less within two hours after milking, provided that the blend temperature after the first and subsequent milkings does not exceed 50 degrees F.

Temperature standards met_____

6. Consequences of abnormal tests: Whenever 2 of the last 4 SPCs, SCCs, coliform determinations, or cooling temperatures, taken on separate days, exceed the limit of the standard for the milk and/or milk products, the Department shall send a written notice to the producer or milk distributor.

When a producer’s bulk tank milk is in violation of standard for 3 of the last 5 samples, the permit shall be suspended by the Department and the following steps shall be taken: (a) For violation of bacterial standards (SPC or coliform), the Department shall conduct a farm inspection. This inspection shall note the probable cause of the violation(s) and any corrective action(s) necessary. A permit shall be issued upon inspection. (b) For violation of the SCC, the permit will be issued when an official bulk tank sample is tested within the Department’s standard at an official laboratory.

For bacterial or somatic cell violations, the producer’s bulk tank milk will be sampled on an accelerated schedule (not more than 2 samples per week for 3 weeks). Once the accelerated sampling has begun, the previous test history will not be used to calculate 2 out of 4 or 3 out of 5 violations. Calculations will be based on test results from the accelerated sampling schedule.

In the case of a drug test positive, a product recall is mandatory due to possible public health implications. The Department also requires a facility inspection by the dairy inspector.

The Milk Room

The milk room holds the receiver group; the bulk tank; equipment-washing sinks; a hand-washing sink; and sometimes the compressor that cools the bulk tank. If at all possible, people traffic should be kept to a minimum through the milk room. It is advisable to keep it locked at night. For biosecurity reasons, the public should never be allowed access to the milk room and raw milk customers should pick up the product in another room. The milk room should never be as a storage area for cleaning chemicals or other farm supplies. According to the Maine Milk Rule, “Only equipment directly related to the processing operations or to the handling of containers, utensils, and equipment shall be permitted in the pasteurizing, processing, cooling, packaging and bulk milk storage rooms.”

It is recommended (but not required by the Department) that a separate room be used for bottling raw milk. A separate room for bottling minimizes the chances for contamination during the bottling process and makes cleaning and disinfection much easier. Maintaining a separate room for bottling is analogous to why hospitals devote a specific room for surgery — both procedures achieve the best results if contamination can be reduced.

Separate room for bottling_____

If the milk room is used as a bottling site for raw milk, it needs to be kept meticulously clean. The walls should be composed of smooth, washable materials and be in good repair. The floor needs to be constructed of concrete or other equally impervious and easily cleanable material and shall be smooth, properly sloped, provided with trapped drains and kept in good repair.

Clean and clutter-free milk room_____

Individuals involved in bottling raw milk should never come directly from the barn into the bottling area and should always wear clean shoes and clothes, hairnets and nitrile gloves when bottling.

Staff hygiene_____

Remember: You are involved in the production of a raw food product whose quality will only deteriorate after it leaves your farm. Please do everything in your power to minimize the possibility of product contamination during the bottling process.

The Milking Facility

In accordance with the Maine Milk Rule, the area used for milking purposes (milking parlors, stables or barns) must have “floors constructed of concrete or equally impervious material.” The walls and ceilings need to be constructed of smooth material, be in good repair, dust tight, and be painted or finished in an approved manner. Natural or artificial light must be provided and well distributed for day and/or night milking. Swine and fowl need to be kept out of the milking facility. In the case of a milking parlor, at the end of milking, all walls and floors should be hosed down and cleaned of any visible manure or dirt.

Milking facility clean, well lighted, kept clean_____

Cleaning Equipment

Whether cleaning is accomplished through a clean-in-place (CIP) system or by hand washing, the principles are the same. Cleaning can be thought of as a three-step process: 1) lukewarm pre-rinse; 2) hot wash, which primarily helps to remove butterfat; and 3) acid rinse, which aids in the removal of protein (milk stone and precipitated minerals).

The lukewarm rinse helps rid the system and equipment of most residual milk, which makes the next step, hot water wash, more effective. The water for the pre-rinse should be 100-110° F. Water that is too hot in the pre-rinse can denature protein causing a surface film and water that is too cold can cause fats to solidify resulting in a greasy film.

Lukewarm pre-rinse_____

For the wash step, always mix the soap or detergent according to the manufacturer’s instructions. If manually cleaning equipment, soak all parts at 120-135° F for five minutes, brush thoroughly and drain, then rinse with an acidified solution and drain again.

Manual clean: proper temperature_____

For CIP systems, make sure the hot wash water starts out at 165-170° F and circulates for 6-10 minutes. The water temperature at the end of the wash cycle should not fall below 120° F. If the wash water temperature falls below 120°, butterfat and milk can start to redeposit on the equipment.

CIP: proper temperature_____

Brand of cleaner used_____

Dilution and method of measurement_____

The acid rinse chemicals should be mixed and circulated in lukewarm water according to the manufacturer’s directions.

Acid rinse_____

Brand of Acid Rinse_____

Dilution and method of measurement_____

The Maine Milk Rule requires that all containers, equipment, and utensils used in the handling, storage and transportation of milk be sanitized before use. Commercially available sanitizers can be used for this purpose and can be chlorine, iodine or quaternary ammonium-based. All sanitized equipment should be allowed to drain before use.

Sanitize equipment before milking_____

Brand of Sanitizer_____

Raw Milk and Foodborne Illness

Remember: All raw milk contains bacteria and some of these bacteria can be harmful and, at times, even fatal. Statistics show that the risks of getting sick from drinking raw milk are greater for young children, pregnant women, the elderly and individuals with compromised immune systems but it’s important to remember that people of any age can get sick from drinking raw milk. While it’s true that food-borne outbreaks have been linked to pasteurized dairy products as well as raw milk, a study released by the Centers for Disease Control and Prevention in March 2012, Nonpasteurized Dairy Products, Disease Outbreaks, and State Laws—United States, 1993–2006 (PDF) reported that the relative risk of food-borne illness is 150 times greater for raw milk than for pasteurized milk.

From 1998 through 2011, 148 outbreaks due to the consumption of raw milk or raw milk products were reported to the CDC. These resulted in 2,384 illnesses, 284 hospitalizations, and 2 deaths. Most of these illnesses were caused by Escherichia coli, Campylobacter, Salmonella, or Listeria. The CDC also reports on their website’s Raw Milk Questions and Answers page that a substantial portion of the raw milk-associated disease burden falls on children. Among the 104 outbreaks from 1998-2011 with information on the patient’s ages available, 82% involved at least one person younger than 20 years old.

Thanks to the following reviewers:
Gary Anderson, Extension animal and bio-sciences specialist, University of Maine Cooperative Extension
Michele Walsh, DVM, Maine Department of Agriculture, Conservation and Forestry
Dr. Beth McEvoy, DVM, Assistant State Veterinarian,
MDACF; Vickie Rea, Maine Centers for Disease Control;
Amy Robbins, Maine CDC
Anne Lichtenwalner, DVM Ph.D., University of Maine Extension

Information in this publication is provided purely for educational purposes. No responsibility is assumed for any problems associated with the use of products or services mentioned. No endorsement of products or companies is intended, nor is criticism of unnamed products or companies implied.

© 2014, 2022

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