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Feed Management

Risk Category 5

This is part of an 11 category program to help farmers learn to identify and manage the unique risks on their farm. This may help them to grow a food safety mindset, that may enable them to write their own food safety plans for the production of raw drinking milk. In Australia, raw milk from cows for human consumption is only allowed if you own the animal, but that doesn't stop farmers from becoming acquainted with practises that are delivery great results overseas. Farmers may need to read the introduction first before continuing on this page:  Introduction to the Risk Identification and Risk Reduction Program



The health of the animal is the most important factor when producing raw drinking milk (RDM). What the cows eat can contribute, or subtract from their health.

It is a concern that many dairy farmers who start to produce RDM come from a high-input system, and they do not understand that certain kinds of feeds from the industrial dairy system, can pose risks to the raw milk. They may not understand yet how they can use regenerative/biological farming methods instead, to significantly increase food safety and create abundant pasture, instead of relying on feeds like grass silage and maize silage, or monocultures like maize or turnips, like this example. Some RDM systems - like the system New Zealand installed in 2016 - doesn’t specify in sufficient detail what the cows producing RDM are NOT ALLOWED TO EAT. This leaves room for situations to develop where the raw milk and the dairy farmer will be blamed, when the real cause can be viewed as a potential flaw in the system instead, which the media is unlikely to mention if the milk makes someone sick.

Experts say keeping cows on pasture is the best way to get a high-quality nutrient-dense raw dairy product with a low-risk profile.

Cows are ruminants and they are meant to eat grass. It is what their stomachs digest with ease, what keeps them strong and robust and allows them to produce disease-free milk that is high in vital nutrients. 

Grass and hay is the appropriate food for cows producing raw drinking milk (RDM). According to Australian microbiologist Dr. Ron Hull on this page “farm fresh unpasteurised milk produced by grass- or hay-fed animals and handled appropriately can be just as safe as pasteurised milk.” In this video, Dr. Sylvia Onusic PhD Nutrition and Public health, explains why grass is the perfect food for cows producing RDM.

Many overseas raw milk dairies are organic 100% grass-fed. The fat profile of this milk is different and healthier. It is also not uncommon for some of these 100% grass-fed dairies to get milk quality lab test results back for coliforms as undetectable (example). This is often true of micro dairies (example) where the milkers can provide attention to detail but also of dairies who take extraordinary care with the use of prevention strategies and Standards Operating Procedures. Many farmers and scientists say 100% pasture-based farming makes their animals and the food they produce healthier. When animals are fed all sort of strange feeds this increases the risk of pathogens, which may overwhelm the natural protective systems of raw milk. Pasture feeding increases the food safety of RDM in multiple ways... 

The true measure of the cow's udder health lies in the testing of milk for Somatic Cell Counts. The true measure of good quality raw milk lies in the screening for microscopic organisms in the milk. Australian farmers who produce for the industrial milk market may become defensive when it comes to issues around animal feed, and how it relates to animal health. In the end, producing raw drinking milk (RDM) in a regulated system will require that the farmer achieve pathogen-free and low bacterial counts. If Australian regulators/policymakers decide to make the standards very strict, the tools explored below will help farmers meet the required milk standards. We want to encourage a better understanding. We do not want to make farmers feel guilty for following the advice given by industry for producing raw milk meant for pasteurisation.

The raw milk movement's many pioneers now show a new way of farming that moves away from pastures with a monoculture of ryegrass, to pastures with a large variety of grasses, forbs, herbs and legumes. Pioneers in America and New Zealand grow cover crops in their paddocks with amazing results. The idea behind a large variety of plant species is to allow nature's system of nutrient cycling between plants and microbes to function. The result is lush, re-mineralised pasture with a large variety of minerals and trace elements, in the right proportions. This contributes to both soil fertility and robust health of animals, as well as more resistance to bacterial infection. Humans who consume re-mineralised plants and animal products will also enjoy the increase health benefits. Turn up the volume to watch the video below:


Restore the Soil: Prosper the Nation

A report on soil security

Recently Australian Agriculture Minister David Littleproud received and welcomed a new report urging the government to focus on sustainable soil health, watch the video here. The report was compiled by Australian Soils Advocate Major-General Michael Jeffery. He suggests that Australia’s water, soil and vegetation assets should be made key national strategic assets and managed in an integrated way. Read the report in full here. Farmers depend hugely on the health of soil for farm productivity. Healthy soil micro-biome is essential for the production of RDM as well. According to this article Minister Littleproud said: “without healthy soil the Australian economy and food supply would be at huge risk because our farm sector would falter." According to this article the report also says: 

“Farmers have primary responsibility for managing the soil, water and vegetation on their land and hence in effect they are managing the majority of the country on behalf of 24 million largely urban Australians.”

“The cumulative impact of their daily decisions not only affect the condition of the soil, vegetation and water assets on their farm, but also the air and water quality and the biodiversity enjoyed by the broader community.”

According to the report, a recent survey shows that nearly 90 percent of farmers had undertaken activities to improve natural resources on the farm. It's good that farmers are proactive and taking the initiative. The information below however shows that more issues on the farm may need to be considered when it comes to producing RDM.

Video: Patrick Holden, director of the Sustainable Food Trust, and former director of the Soil Association, talk about how powerful Holistic Management is. Patrick a dairyman in the UK raising heritage breed cows and producing some of the finest raw milk cheese in the world, explains his view of regenerative agriculture and how it can heal many of societies problems. Video by the Savory Institute.

Please note that this particular page explores both pasture management and feed. Pasture management is examined predominantly on the Farm Conditions page. 

Risk Exploration

Cover crops with Dr Christine Jones and no-till veteran Gabe Brown

Cover crops is a method of biological farming that is increasingly used by farmers in the raw milk movement and elsewhere. In this article Australian soil ecologist Dr Christine Jones explains that one of the keys to building soil carbon is cover crops  — plants that keep the land covered with something green and growing at all times, even in winter. A conversation among plants starts when there is plant diversity year round, along with biological activity, which means more CO2 is absorbed and increases the amount of carbon available to roots. This feeds the microbes, which builds soil. More moisture is trapped underground. A diverse cover of crops put down deeper roots that tap resources and grows abundant life. "Cool-season grasses (such as barley, wheat and oats) and cool-season broadleaf plants (such as canola, pea, turnip, lentil, radish and mustard), she said, need to dialogue constructively with warm-season grasses (including millet, corn and sorghum) and warm broadleafs (such as buckwheat, sunflower and sugar beet)."    

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“It’s not enough to simply have green plants, like ryegrass and clover. It’s not possible for livestock to thrive on ryegrass and clover 365 days of the year.” - Soil ecologist, Christine Jones

According to this article, Christine says that diversity matters and that diverse plant communities always produced more biomass than single plants grown in a monoculture. "Diversity is the way of the future". There are many international examples of farmers growing "cocktail crops" or "snack paddocks" consisting of a diverse mix of plants, vegetables and even flower species that were loaded with trace elements. Plants release different exudates to stimulate microbes into releasing different nutrients, which is one reason why plant diversity is so important. Christine says that cows thrive on a varied diet and will queue up at the gates of those paddocks. The Jena experiment - mentioned in the Farm and Land category - found in one particular experiment that plant diversity is more important than fertiliser. High diversity can produce greater plant yield than high nitrogen, more about that at the 29 minute time marker of the video below: 

Video: Christine Jones, PhD, soil ecologist speaking at the 2017 Soil & Nutrition Conference. An aspect of plant community structure that is gaining increased research attention is the presence of 'common mycorrhizal networks' (CMNs) in multi-species cover crops, cash crops grown with companion plants and high-diversity pastures. It has been found that plants in communities assist each other by linking together in vast underground superhighways through which carbon, water and nutrients are exchanged. Video by Bionutrient Food Association.

Image: dairy cows in New Zealand on a diverse species pasture, click to enlarge.

Cover crops do more than just offer high-quality forage for livestock. They supply the soil with nitrogen, carbon, and organic matter via root systems, and create a robust environment for microorganisms to convert dead root matter into soil. Cover crops are a great tool for both large- and small-scale operations to rapidly build soil. The purpose of cover crops and high diversity of plants are to increase soil fertility and regenerate the soil.


A research demonstration in Ohio recently showed how total soil nutrients can double in one year from a cover-crop and grazing combination. The increases in soil health were dramatic. Haney nutrient testing before, during and after the cover crop treatments showed these benefits:

  • Total nutrient value increased 121%

  • Pounds nitrogen per acre increased 78%

  • Pounds phosphorus per acre increased 133%

  • Pounds potassium per acre increased 144%

  • Total organic carbon increased 23%

  • The Solvita ranking, a measure of soil life, increased by 44%

Image: a cover crop of hairy vetch, peas and winter wheat, click to enlarge

American soil scientist Ray Archuleta told the reporter in this article that when you maintain a multi-species continual cover on the soil, this protects the soil like a ‘skin,’ preventing compaction, feeding the soil biology with a diversity of plant exudates, and supporting the formation and maintenance of soil aggregates. This, in turn, produces nitrogen so the need for inputs is reduced, and maintains the air spaces in the soil so that the rainfall stays in the soil where the farmer needs it, and doesn’t run off into the water.  Like Christine, Ray also explains why growing abundant soil microbes doing nutrient cycling, are more important that chemical fertiliser. "Once healthy soils are cycling, nitrogen will not be an issue... You have to focus on the carbon first – the nitrogen processes the food, and 90 percent of nitrogen comes from the soil microbes. When you apply a chemical fertiliser, only about 40 percent reaches the plant, and 60 percent is leached."

“If you get the ecology right on your farms then the money will follow.” - Soil Scientist, Ray Archuleta

No-till veteran Gabe Brown from North Dakota has become an expert on growing highly profitable cover crops. He and others are returning to a style of farming that existed before: regenerative farming. They are part of a growing number who are weaning themselves from the grip of chemical corporations. In this amazing video, he explains why soil carbon is the key driver for farm profit. Also why cover crops need to be seeded in multi-species combinations. At least 6, 7 or 8 species need to be grown together to capture the symbiosis we see in nature, because that is how nature functions. In the video Gabe shows photos of his experiments that indicate how mono-crops continue to fail, but multi-species cover crops flourish. In the video he mentions the research also cited by Dr Christine Jones:  that 85 - 90% of nutrient acquisition is microbially mediated, which means nutrients has to come via the microbes. Plants feed the microbes with liquid carbon, and in return they receive nutrients and minerals in the right proportions. According to Gabe mycorrhizal fungi are the most important microbe of them all. He says that soil should resemble dark cottage cheese due to the formation of soil aggregates. In the video, Gabe mentions SARE's free book download called Managing Cover Crops Profitably, click here to download. It is important to watch Gabe Brown's entire presentation to understand why there are a variety of reasons why farmers manage cover crops differently; it depends on the results they want to achieve. For more information on Dr Elaine Ingham's compost tea that is mentioned in the video, for rapid full scale biological restoration, go to the Farm and Land category. This is risk reduction in action with real results!

“Only plants and their associated microbes can make fertile topsoil - and a diversity of plants and microbes makes it even better!” - Dr Christine Jones

At the 22: 38 time marker, Gabe shares how to integrate and grow cover crops. He is against bailing hay from regenerating soil because it sets the carbon building of those paddocks back. He has seen first hand that there are more benefits in keeping a good cover on the soil year round. Gabe also report that animals grazing on his pastures don't need help with calving and their health is considerably different from the norm. This is because nutrient cycling results in mineral- and trace element rich plants, which results in robust animals. Gabe has done thousands of public speaking events. He is 100% confident that the principles that he uses to convert his ranch in North Dakota into an ecosystem, are the same no matter where he is presenting this information. 

“Monocultures are a detriment to soil health.” - Gabe Brown

Image: a highly diverse species cover crop, click to enlarge.

There are some American and New Zealand dairy farmers who are inspiring pioneers in the field of cover crops and getting great results, see the video above by Essex Farm, who supply raw milk to their members in New York state. In the video, cover crops of oats and pea are grown. Also see how New Zealand raw dairy farmers at Lindsay Farm grow highly diverse cover crops as part of perennial pasture in this video. Australian farmer Colin Seis has an innovative method he calls pasture cropping. For the last few years Colin has been developing 'multi species pasture cropping', which uses a group of plant species that produce good quality forage, have a range of different root systems, includes legume species, flowering plants, and species that will add to organic matter. His technique however, has the added benefit of being able to still harvest a grain crop after the multi species crop is grazed, and therefore functions somewhat differently than how raw dairy farmers generally graze cover crops. More on Colin's technique here.



Many of the images contain plants that are a high source of nitrogen, like peas, hairy vetch and clover, also called nitrogen-fixing plants. The nitrogen-fixing bacteria that colonise the roots of legumes can convert nitrogen from the air, into a form plants can use. In this way, clovers help build organic matter in soil, improving water and mineral retention, microbacterial activity, and helping to sequester carbon from the atmosphere. As a risk reduction strategy, it is clearly more beneficial to rely on a high diversity of these plants and their associate microbes, to provide nutrients to all the plants, than to rely on expensive nitrogen fertiliser that has negative environmental impacts, as discussed in the Farm Conditions category. 

Image: This photo was taken on Australian farmer Colin Seis' farm at Winona of his Multi Species Pasture Crops, click to enlarge.

“The greater the diversity of plants, the greater the
diversity of microbes and the more robust the soil ecosystem.” - Dr Christine Jones

An old permanent pasture converted to a herbal pasture

British Raw dairy farmer Christine Page from Smiling Tree Farm runs a micro dairy of about 10 cows, and has planted what she calls a herbal pasture. The image below shows an old permanent pasture that they over-sowed, adding new plants and herbs. As a result, they contain a wide diversity of grasses and other herbaceous plants. The dense and thick sward provides excellent soil protection, and can hold a mixed cache of seeds for many years until the right conditions for germination occurs. They also started to plant trees within the permanent pastures, to develop the woodland edge benefits of a silvo-pastoral system, providing shelter for the animals. Some of the trees even provide fodder for the animals, and some leaves have both nutritious and medicinal properties. They also increase the health of the soil with mob grazing, long pasture rest and 'knee-high grazing', as advocated by Australian soil scientist Christine Jones.  

Image: herbal pasture at Smiling Tree Farm, click to enlarge image.

In this article, Christine explains why the diverse species rich pastures are the basis for amazing and complex flavour. The herbal pastures contain a range of over 15 different plants, including yarrow, salad burnet, chicory, birdsfoot trevoil, as well as several different clovers. The field is also home to 20 species of wildflowers. According to the website: "Some, like sanfoin and sheeps parsley, are particularly deep-rooting and pull up minerals from deep down in the soil. Others, like chicory and plantain, have unique anthelmintic properties that naturally remove any parasites from the sheep and cattle." In this article, Christine Page explains how roaming grazing cows sequesters carbon. 

"The herbal pastures at Smiling Tree form an integral part of our farming practices that are designed to keep our animals vibrantly healthy and to give us highly nutritious meat and milk."

“Nutritionally replete animals are healthy and content.” - micro dairy owner Christine Page

Overabundant ryegrass Lolium perenne in Victoria

The dairy industry in Australia has encouraged dairy farmers to plant more ryegrass or monocultures of ryegrass in their pastures to supposedly increase profits for years. However, there are many risks connected to this practice and it is setting dairy farmers up for failure. Monocultures reduce plant diversity and soil fertility as discussed in the Farm and Land Conditions risk category. Less plant diversity means fewer nutrients and minerals available to the plants and the animals via nutrient cycling. There is lots of evidence that monocultures perform poorly compared to multi-species pasture. Farmers may be creating drought and financial hardship on the farm without even realising it, as ecosystems collapse. Ryegrass in itself is not harmful, but too much of it upsets the natural order in nature...

Image: Lolium perenne, image via Wikimedia Commons.

The thunderstorm asthma outbreak of 2016 that killed ten Victorians is also linked to the overabundance of pollen from perennial ryegrass Lolium perenne. Professor Cenk Suphioglu from Deakin University says that he doesn't doubt that the thunderstorm asthma event will re-occur. He says the sheer presence in high numbers is why Melbourne is the thunderstorm asthma capital of the world. We have yet to see the results of the inquest.  As a risk reduction strategy, it is best for farmers to return to a diverse species pasture to feed the animals. This will also improve the health and well-being of everyone in this system. Hay-fever sufferers are in agony every year due to overabundant ryegrass pollen. 

Many farmers are now returning plant diversity, microbes and carbon to their pastures. The organic farmers from New Zealand in this article asks: "why should cows eat ryegrass every single day?" As part of their soil restoration program, they planted a 26-seed cocktail mixture including chicory, plantain, yarrow, fescue, lucerne, Italian ryegrass, linseed and many clovers. 

"Every soil microbe has a relationship with different plants. Every plant has something different to contribute." 

Agrochemicals and Biological Farming don't go together

Risks come in varying degrees. This is true of all the things that have been added to the cow's diet and environment since industrialisation started. The rumen of the cow is a fermentation vessel powered by diverse, beneficial bacteria living in harmony. That balance may be vulnerable to disturbance from herbicides, pesticides and antibiotics and other agrochemicals. Their active ingredients can have antibiotic properties. These may cause beneficial microbes to die off and be overtaken by pathogens. When pathogens take over in a mammal's digestive system, the animal can become ill, malnourished, mineral deficient or mentally depressed. When pathogens overgrow, they shed in the faeces, and this ends up in the terrain around the farm. Grain-feeding has unfortunately become a vehicle for transferring these chemicals into the cows with potentially harmful effects. Academics have raised concern and veterinarians have spoken about seeing how serious animal health problems were improved or resolved after removing feed that had been sprayed with chemicals like glyphosate, more here. A toxicologist warned that even low-level exposure to glyphosate could be hazardous because there is exposure to many different sources of this chemical and its effects are cumulative (source). If you listen to those who encounter these very severe health problems in animals, there does seem to be a level of risk attached. Click here for a more in-depth and separate exploration on this topic and why some say that the chemical glyphosate creates pathogens in the terrain, which is an unacceptable risk for RDM systems. Another new study shows that glyphosate disrupts the microbiome 'at safe levels', see this article.   

According to this article"Tests conducted by the Canadian Food Inspection Agency (CFIA) on thousands of samples of these lentils and moong dal grown by farmers in Canada and Australia found an average 282 parts per billion (PPB) and 1,000 parts per billion of glyphosate respectively, which is extremely high on any standards."

Image:   one teaspoon of soil contains more microbes than there are people on earth.

Image: one teaspoon of soil contains more microbes than there are people on earth.

In a recent Wise Traditions podcast research microbiologist and expert on the human microbiome explains the science behind the damage the agrochemical ingredient glyphosate causes to the human body's microbiome. Kiran Krishnan says that it disrupts the shikimate pathway of microbes and "selectively kills the good bacteria and allows for the growth of a significant amount of bad bacteria". He says it increases and allows problematic pathogens like Clostridia, Klebsiella, Salmonella etc to flourish. Other scientists make similar bold statements like this. There is concern about glyphosate’s ability to create pathogens in the terrain. This is an unacceptable risk for the raw milk dairy and is best avoided.

An Australian study tracking pesticide exposure in farmers show chemicals like pesticides and insecticides can be harmful to farmers, as they can develop long-term health problems. "Organophosphates work by attacking an insect's nervous system — the chemicals attack humans in the same way but on a lesser scale." If it attacks the human nervous system in some way, what does that say about the effect it may have on calves and cows, who are also mammals like us? The food safety of RDM depends on the health of the animals in the system. Raw dairy farmers cannot afford to have health compromised animals...

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Agrochemicals may also disrupt the harmonious balance of essential microbes in the soil. Producing raw milk for human consumption is dependant on a healthy ecosystem of fungi, protozoa, nematodes and bacteria etc. for biological functions and ecosystem services, see this video. Compromising the harmony of this symbiotic system can be potentially disastrous, as discussed in the Farm and Land Conditions risk category. Raw dairy farmers farm for diverse species, beneficial microbes. Some agrochemicals are not compatible with achieving this goal. In this video Ange from Lindsay Farms explains why biological farming is easy all year round. The biology and carbon in the soil protect the pastures from drought and farmers don't have to live in panic. In another video British dairy farmer Ben Mead explains the joys of 'do nothing farming' in the form of plant biodiversity, focus on soil health and chemical-free. To mitigate the risks to food safety, chemical-free and organic practises are best when producing raw drinking milk (RDM).

“Building topsoil is a biological process.” - Dr. Christine Jones

Grain feeding in the raw milk system

It is also important to add that many dairy farmers feel that feeding a small amount of grain is acceptable and they have no issues with doing so. This presentation is an effort to help identify potential risks and level of risk on the farm. It is up to the individual dairy farmer to decide how they want to farm. Keeping pathogens and harmful bacteria away from the farm, from the animals and the dairy is very important. The issue of feeding grain, and how much, can become a mitigating practice if there is difficulty achieving required milk quality standards. 

If the cow's digestive system supports the right kind of microbes, they can eat small amounts of chemical-free grains without problems. Farmers with a close relationship with the herd get to know them very well, and they are skilled at picking up the slightest of changes in their health. They know the manure should not be smelly or attract flies. They know what the consistency of a healthy, pasture-fed cow looks and feels like. This ability to provide attention to detail and to the physical needs of the animals – as in old-fashioned animal husbandry – is risk reduction in action.




All too commonly, high-grain diets also produce the low-pH, low-fibre and high-stress stomach environment that can cause abomasal ulcers and other conditions such as liver abscesses. According to this science article on the findings on the health impacts of high-grain cattle feed, “acid buildup can cause ulcers in animals consuming too much grain: "Then what happens is that infectious bacteria come from the rumen through the ulcers, into blood, and finally into the liver, where they cause abscesses," Russell said. Feed additives such as antibiotics can counteract such ailments, but they further alter the ruminal microbial ecosystem, he added.”

Grains can accumulate in an animal's intestines because they lack starch-digesting enzymes. Thus, a high-grain diet can promote an overgrowth of Clostridium perfringens, a bacterium associated with sudden death in feedlot cattle, Russell's article suggests.”

“Finally, grain-based diets can promote Escherichia coli (E. coli) within the digestive tract of cattle, and these E. coli are more likely to survive acid shocks that mimic the human gastric stomach. This discovery, first reported by Russell and colleagues in 1998 (Science, 11 September), has now been confirmed. Other USDA scientists have likewise shown that cattle switched from grain-based diets to hay were less likely to shed harmful E. coli 0157:H7 in feces.”

Mould, bacteria and toxins in the hay

It is essential to keep feed like hay safe from rodents, chickens or pests as their excrement can be a source of contamination. Chickens and their manure is often associated with salmonella and campylobacter. There is nothing wrong with having biodiversity of species on the farm; it is how it is managed to reduce risk. Keep them separate from the milking herd. Read more about keeping multi-species animals on the farm in the Biosecurity category. The feed also need to be protected from getting wet or developing mould, fungi or bacteria because this too can upset the ecology inside the animal, which can affect the milk quality. Hay kept dry and free from common contaminants can be seen as a low-risk feed.

Mixed feeds: to risk or not to risk?

In this article veterinarian, Dr. Catharina Berge explains why it is important to minimise microbial contaminants and other hazards in grain-based feed for animal and human health.

"Microbial contaminants such as Escherichia coli, Salmonella spp., Clostridium spp., Staphylococcus spp and Streptococcus spp, moulds and yeasts may all be present in feed and detrimental for animal health, productivity and health, and ultimately for human health." 

She says that hazards such as bacteria, moulds, yeasts and toxins may be introduced through feed ingredients. Also via contamination during production, handling, storage and transportation. The industrial dairy industry has many intervention strategies for mixed feed to reduce the risks. This milk is raw milk meant for pasteurisation, which eliminates microbial dangers that may be carried to the milk. 

Dr. Cat Berge, who has worked for the National Food Administration, says she endorses raw milk for human consumption for many reasons. She does not believe that the final decontamination of a food commodity is the optimal approach to food safety. The focus should be on hygienic production, harvesting and processing from food to table, read more about her views here.  

It is a good risk reduction strategy to become very educated on the risks of feeds and the modern additives to the diets of cows. After doing some research you may discover that some risks are not worth taking with RDM production.

There is a good reason why many raw dairy farmers are having tremendous success with holistic pasture management and grazing; the microbiology and nutrition in the pastures are restored. Regenerative farming restores soil bacteria, fungi etc. and these enable plants to take up lots of minerals and nutrients again, more here. Farmers report the animals are robust and healthier, with less need for intervention strategies. The veterinarian turned 100% grass-fed raw milk producer in this example shows that it is possible to achieve undetectable bacteria count results in milk tests. Mark Lopez says that it is not difficult to make clean milk that has a long shelf life of three weeks. It is not hard when you know how to do it... He is just one example out of many, see the case studies.  

A raw milk producer from New Zealand recently had a positive campylobacter test. An online search on this farm led to some puzzling discoveries. This 23 August 2016 article said that the cows received supplements like dried distillers grain, maize silage, sugary apple pulp, tapioca, palm oil and even soy. These made up 25% of the cow's diet at the time the article was written, but the farmer hoped to 'crank it up again' because the supplements went down in price. A study of the Animal Products Notice: Raw milk for Sale to Consumers document page 34 reveals that NZ raw milk regulation has little clarification on what cows are not allowed to eat. This is alarming. The rules force all sorts of other compliance on the farmers, but neglect one of the most critical aspects that contribute to the food safety of RDM. 

This incident and a few earlier ones have led to criticism from Professor Nigel French, who is director of the New Zealand Food Safety Science and Research Centre. A few days later the New Zealand Ministry for Primary Industries (MPI) issued a press release reminding consumers to take care when drinking RDM. MPI considers the RDM its system produces to be a high-risk food. The NZ raw milk system has vulnerabilities that some farmers may not be aware of. MPI has not done a good job of clearly identifying risks. 


Australia is possibly the most risk-averse country in the world. Australian raw milk producers will likely be making recommendations that eliminate all of these high-risk feeds. What is normal for the industrial dairy industry cannot automatically be accepted as standard for the RDM operation. 


In this video, Dr. Sylvia Onusic PhD Nutrition and Public Health, explain why grass is the perfect food for cows producing raw drinking milk. She says that "when grass is in the rumen, there is bacteria that naturally ferment it, and turns it into CLA and the different components that make this milk so unique". Fresh pasture is a whole-food and has the right natural proportions. It's an optimal food that doesn't create immune responses because the body of the animals recognises the natural components during digestion. 

In a recent Wise Traditions podcast, Mark McAfee from the Raw Milk Institute explained that raw milk must come from pastured animals, because pasture creates the right kind of food safety environment. Grass is also responsible for the right kind of omega-3 fatty acid ratio and CLA, which are the healthy fats that helps your immune system. The right kind of microbes increase the food safety of the raw milk. Organic Pastures dairy has been producing raw milk for human consumption since 1999, they have had plenty of time to discover these pearls of wisdom.


Total Mixed Rations and Partially Mixed Rations are common feed in intensively farmed milking operations where maximum performance is required. This article says that TMR and PMR are methods of feeding cows that combines all forages, grains, protein feeds, minerals, vitamins and feed additives formulated to a specified nutrient concentration into a single feed mix. When producing RDM the most crucial factor is animal health, not maximum milk production. TMR and PMR are vulnerable to the same risks explored in Dr. Cat Berge's article discussed earlier. As a risk reduction strategy, TMR and PMR are best avoided completely.

Silage: mycotoxins from mould and botulism  

Silage is grass or other green fodder compacted and stored in airtight conditions without first being dried. In Australia, the plastic is used to create an anaerobic atmosphere inside the bale. It is a fermented, high-moisture stored fodder used as animal feed. Silage is very controversial in the raw milk movement. In countries like England and New Zealand, some large-scale dairy farmers (who produce for both the RDM and industrial market) still prepare their own silage and feed it to cows producing for the RDM market, see this example. BUT some of them prepare and store it differently, see this example. It is not exactly certain what the difference in microbial risk are between how we make it here in Australia, and how it is made in the UK. In this video, Dr Paul Brassley, University of Exeter discusses the history of silage in the UK, and why he feels its use is not traditional. It is clear at the 9 minute marker that the use of silage increased significantly due to systems of intensive agriculture practices. In his conclusion, he explains that he remembers hay as a winter feed when he was a youngster, but that people 20 - 30 years younger than he, would remember silage.

Many raw dairy producers, however, have stopped feeding both grass- and corn silage due to the risks they pose and have adopted a variety of other strategies, like growing resilient year-round multi-species forage instead. Thanks to the educational efforts of the Raw Milk Institute and the Weston A. Price Foundation, feeding silage to the RDM herd is not done in North America. 

Veterinarian Dr. Cat Berge wrote this article about how penicillium moulds in grass- and corn silage can affect rumen health. She concludes that the rumen microbial environment can be disrupted by the antibiotic effects of some of these silage moulds, paving the way for other problems. Moulds can produce mycotoxins and can pave the way for other potentially pathogenic organisms. Some organisms increase the heat inside the bale with potentially disastrous consequences. Quick tests for mould can be purchased, however mould can form in patches and can be highly variable. The area that is tested may not be the infected area. Please note that not all moulds that can grow on silage are toxic, some are harmless and their colour can often be indicative.

Image: this is how silage is typically made in Australia.

Recently Shoalhaven Dairy Farm in NSW lost 250 cows (half the herd) in one of the biggest cases of botulism in recent years. According to a vet in this article, there is a lack of awareness amongst dairy farmers about the risks of botulism. Botulism is a rapid onset, usually fatal disease caused by the toxin produced by the bacterium Clostridium botulinum. A rotten carcass of a rodent, snake, lizard or other rotting organic material in poorly prepared silage is often the cause. The toxin travels through the bloodstream and attacks the nerve endings causing paralysis. Veterinarian Helen Schaefer said that with high doses this could lead to sudden death or in low doses it can present as muscle weakness.

Feeding silage is also linked to an increased risk of Listeria monocytogenes. Page 12 of this FSANZ document recommends that farmers not feed silage to cows producing milk for raw cheese production. There is a subclause that provides for its use only if the business can show that it will not affect the health of the cows or the suitability of the milk. The management to ensure the dangers of silage are appropriately mitigated, requires a lot of monitoring and is time-consuming. Food Standards Australia New Zealand's Guide to the requirements for raw milk cheese Standard 4.2.4. Proposal P1022 page 13 makes reference to NSW Department of Primary Industries' "Top Fodder, Successful Silage" Manual (2004) for guidance on safe silage production.

In addition, Dairy Food Safety Victoria's farmers checklist states that: "Silage must not be fed to animals milked for milk for raw milk cheese" and "alternative compliance is possible but needs to be approved".

Silage is a recognised risk. It can be hard to control or predict what microorganisms grow and ferments in the silage during its storage period, which is often in the field in direct sunlight. When the wrong kind of organisms grows in large numbers, it can result in animal fatalities or some harmful effect on the milk quality. This is a risk best avoided when producing raw drinking milk (RDM) in a risk-averse country like Australia.

There is a need for further research to identify if haylage, which is more commonly used on small farms in Australia, poses the same risk as silage. Haylage typically has a much lower moisture content.

Brewers grain and distillers grain

These are both byproducts from making other products, and both can come in wet and dry forms. Brewers grains are the solid residue after processing grains like barley, wheat, corn, sorghum etc. for the production of beer and other malt products. Distillers grains are a cereal byproduct of the distillation process. Distillers grain is a convenient, cheap feed in the global industrial dairy industry. Feeding distillers grain to cows however has a high risk of the dangerous E.coli 0157:H7 developing in the gut and then showing in the manure of the animals. Farmers producing raw milk meant for pasteurisation may get away with it because the milk is heat treated to kill any potential dangers in the milk, but it can be a very costly mistake for the RDM producer.

Mark McAfee from the Raw Milk Institute says that the data, history and literature on this are very clear from the late 1800's when cows were first fed these 'unnatural feeds'. Their immune systems suffered, and they shed horrible pathogens in their manure, listen to this video for more information. Mark also said in these comments that "according to researchers, distillers grains change the cow's gut microbial balance. The distillers grain fed cow's gut begins to favour and encourage E.coli pathogens when pasture or dry forage based diet does not. This has been confirmed by many peer-reviewed studies." Mark says that the Raw Milk Institute strongly advises against this high-risk feeding practice because evidence shows that E.coli pathogens are very likely to appear in high numbers in the manure of the animals fed these spent grains. He advises farmers who don't believe him, to start testing their manure, because they will find the pathogens. Science backs it up.


Dairies that produce raw milk for human consumption have to encourage good gut conditions that favour good bacteria, not bad ones.

As a matter of comparison Mark also shared the following: "the California Department of Health Services tested OPDC (a raw milk dairy) fresh cows manure several times over three years during high stress high heat periods of the year. Only three tests came back positive in over 1200 tests. All of those were in one summer. The other summers were all negative… The tests from the micro dairy in question (who fed distillers grain) showed pathogens in 90% of their cows manure and they were persistent. This mid western micro dairy is being studied by a respected university researcher."

Breweries or distilleries sometimes give the spent grains away for free because they have to pay to dispose of them if they cannot find a market for them. This article explains how sorghum in Australia can be turned into both fuel ethanol and "wet and dry-cake for stock feed". This is a far cry from the sorghum in its natural form that cows would typically access as part of pasture. 

This study concluded that “the odds of E. coli O157 positive fecal samples from cattle fed brewers grains were six times that for cattle not fed brewers grains.” Another study found “fecal prevalence for E. coli O157:H7 in steers fed a diet with WDGS (wet distilled grains) was twice that of the prevalence in control steers…” Australia started a program feeding brewers grain to dairy cows in the industrial milk system in 2016, more here. It is a good risk reduction strategy not to feed these to the RDM herd. 


Below is an Australian example of how a solution for the industrial dairy industry, is not a suitable solution for the RDM operation because RDM is not heat treated to kill potential pathogens in the milk.


It is risky business when a regulated RDM system don't restrict the use of, or stipulate the risks of feeds common to the industrial dairy industry. Feeding silage or brewers grain to the RDM herd can be like sending in a trojan horse, and waiting for the right moment of complacency, to erupt into chaos. As risk mitigation, it is better to focus on growing better forage, cover crops and biological restoration, than feeding risky feeds to the RDM herd.  

Mouldy grains as an endocrine disrupter

Mycoestrogen (fungal estrogen) is a hormone-disruptor that is produced by fungus and includes mould and mould contaminations. It grows on grains, silage, coffee, chocolate and other products that are stored and processed in damp and dark places such as grain storage containers like those found on mono-crop farms. Sixteen countries worldwide recognise its toxic effects and have set legal limits, more here.

In this video, Dr. Anthony Jay explains why spoilt grains and mould estrogen can create sickness, disrupt hormones, create depression and increase growth. It makes animals fat quickly and can breed inherited fat. It is an endocrine disruptor and can alter the immune system, which is even more reason to be very careful where you source grains and how much you feed to animals.

A 2017 review in the Food and Toxicology Journal shows mould estrogen is also called "zearalenone" and is a mycotoxin. All of the typical mass produced grains fed to cows (corn, barley, oats, wheat, sorghum, millet and rice) are at risk of this problem, as Dr. Anthony explains in the video. It is also detected in cereal products like flour, malt, soybeans and beer. The review says that although the fungus naturally occurs in the field, numerous experiments show high levels of zearalenone usually result from improper storage, rather than development in the field. It says that there is now overwhelming evidence of global contamination of cereal. How many undiagnosed health issues are caused by mouldy grains? What are these grains doing to the mental health of animals? The review says that zearalenone is of 'relatively low, acute toxicity' which means it doesn't immediately cause symptoms or problems. It may take years to develop the visible and harmful effects.

We need the milking herd to be in excellent health. If you find mouldy grains, throw them away because it is not worth the risk. If you feed grain, ensure the feed kept in containers have a high turnaround. Don't let it sit for extended periods of time and keep it in a cool area, away from sunlight. You may need to wash containers frequently to minimise cross-contamination. Let them dry completely before filling them up. According to the farmer in this video "the grain-fed cow is a naturally obese creature that would never exist in nature".

Cut possible contamination from high grain feeding

An article on The Bovine asks why the government, the dairy industry and the beef industry are not telling people about two distinct groups of E.coli: one acid sensitive and the other acid resistant. A 1998 article on the Cornell University website explains that grain-based cattle diets promote the growth of the acid resistant form of E.coli, because the gastrointestinal tract of cattle digests grain poorly. This is a risk to the raw milk operation because acid resistant E.coli may shed in the faeces. It may contaminate the environment around the dairy or the milk.

The practice of feeding high grain diets to both dairy and beef cows, and the animals then producing the acid resistant E.coli, have far-reaching consequences. If you consume an acid resistant E. Coli it can pass through your stomach acid into your intestines where it can cause disease, whereas, if you consume an acid sensitive E. Coli it is destroyed by your gastric barrier.


The researchers found that cattle fed hay or grass had only acid sensitive E.coli. Dairy cattle always fed grass or hay have no chance of shedding acid resistant E. Coli in their faeces. If it’s not in the faeces, it can’t be in the milk even if the milk was contaminated by faeces. For more about the potential consequences around this, see this article.


Soya as feed

We need the milking herd to be in excellent health. Some see feeding soya beans to cows as problematic. The Weston A. Price Foundation has identified a myriad of issues with soy:  it contains anti-nutrients/enzyme inhibitors/phytic acid, it interferes with mineral absorption, it is goitrogenic (it interferes with the functioning of the thyroid) and is estrogenic (it interferes with the functioning of hormones) etc. They have identified that soy needs to be appropriately fermented with traditional methods before it is fit for human consumption, and then only eaten in small amounts. This video explains why soy is an estrogenic food to avoid. The estrogens can be carried over to the milk. Soy is also one of the top eight most allergenic foods in the modern human diet. Soy can cause immediate hypersensitivity reactions such as coughing, sneezing, runny nose, hives, diarrhea, difficulty swallowing, and anaphylactic shock and death. Soy allergies are on the rise because it is now a common ingredient in many processed foods. The Weston A. Price Foundation reports that many consumers ask that raw dairy producers not feed soy to the animals. 

Dr. Kaayla Daniel wrote an entire book called The Whole Soy Story and said that the soybean contains many anti-nutrients and toxins. She says scientists who have studied the use of soy protein in animal feeds over the years have discovered many components in soy that cause poor growth, digestive distress, fertility issues and other health problems. To list just a few of these: Protease inhibitors interfere with protein digestion and have caused malnutrition, poor growth, digestive distress, and pancreatitis. Phytates block mineral absorption, causing zinc, iron, and calcium deficiencies. She says that the soy industry has tried to improve the quality of animal feeds by finding better ways to get rid of these undesirable anti-nutrients but they continue to fail, read more here. To watch a lecture on soy by Dr. Kaayla see this video.

Swedish veterinarian Dr. Cat Berge also identifies alfalfa and legumes as risk factors for mastitis due to estrogenic substances. Soy is a legume with a known reputation.

In this video, Dr. Anthony Jay, who has a PhD in Biochemistry and works at the Mayo Clinic in Rochester, Minnesota, looks at scientific research and explains why soy is a risk to human health.  He is the author of Estrogeneration: How Estrogenics Are Making You Fat, Sick, and Infertile. Soy is now also a crop frequently sprayed with agrochemicals. It can also be a GMO. According to reports, up to 80% of the global soybean crop is genetically modified. In today's global food system transparency, accountability and traceability can become lost. It can be challenging to determine the level of risk. For these many reasons, soy is best avoided as part of a risk reduction strategy.

Fats in grains can be inflammatory and rancid, the Omega 3 to Omega 6 ratio and Anti-nutrients like Phytic Acid

Some seeds like cottonseed, canola, corn, soybean and sunflower are very high in Omega-6 fatty acids. Research now shows that a diet high in Omega-6 can have harmful and inflammatory effects on human health, more here. What effect will a diet high in Omega-6 have on the health of cows? Ponder the following two facts:


Grains are high in Omega-6. Grass is high in Omega-3.

According to this article the University of Alberta adds strength to the growing body of research that shows dietary fatty acids like omega 3 enhance reproductive performance in cattle. The industrial dairy industry is very concerned about decreasing fertility in dairy cows. According to the article it is estimated that the fertilisation rate in dairy cows is only 75 percent to 80 percent. In heifers and beef cows, this number is closer to 100 percent. 

In some industrial dairy operations cows are given flaxseed because it is high in omega 3, but when this is given to cows as part of the processed mixed feed, it can mean that the seed itself may have been 'damaged' in the process. Flaxseed - like many other seeds and grains - can go rancid once its protective hull is breached. When some grains are cut or milled at high temperatures, the fatty acids in the grains can also go rancid. Rancidity can increase when stored for long periods of time. Phytic acid is one of many anti-nutrients that is part of a seed's system of self-preservation. It can protect seeds for months or years until the conditions are right for it to sprout or germinate. Phytic acid, for example, is mostly  

found in the bran or outer hull of seeds and grains. According to Sally Fallon Morell phytic acid can cause serious health problems when ingested by humans. Her book Nourishing Traditions explains: "Untreated phytic acid can combine with calcium, magnesium, copper, iron and especially zinc in the intestinal tract and block their absorption. This is why a diet high in improperly prepared whole grains may lead to serious mineral deficiencies and bone loss." Followers of the Weston A Price foundation are familiar with the practice of soaking and fermenting grains and seed before human consumption.

Healthy ruminants such as cows, sheep and goats usually don't have trouble with phytic acid because phytase - the enzyme that neutralises phytic acid and liberates the phosphorus - is produced by rumen microorganisms. However, consider what can potentially occur if the natural balance of microflora inside a cow is compromised for some time. Will phytase enzyme production be inhibited if bad microbes take over in the rumen? Will the animal still be able to neutralise the effects of phytic acid, and absorb and utilise the minerals? 


It can be a useful risk reduction strategy to feed organic or biodynamic whole grains that are soaked overnight to the animals while they are being milked. Many raw dairies in the USA have been doing this for many years. It was popularised by followers of the Weston A. Price Foundation who was instrumental in making raw milk popular by providing education. The whole grains can be prepared the previous day by soaking them in water with the help of a little bit of apple cider vinegar, which is then rinsed out in the morning and given to the cows during milking. Whole grains can be sprouted too because they are high in nutritional value in that form.

Many overseas consumers also ask their producers for 100% grass-fed raw milk because of the nutritional benefits, more here:  The Grass-fed Raw Milk Movement. Educated consumers want to mitigate the risks to their health. When raw milk from cows are legalised in Australia consumers are going to ask for it as well.

Food waste

Animals in the industrial dairy system receive all sorts of unsaleable products from the food manufacturing industry, like broken biscuits, commercial bread & pastries, brewer's grain, citrus pulp, soy pulp, sweepings from breakfast cereal processing, and green waste from supermarkets and restaurants.

The latest waste product to be turned into animal feed is sugar cane. Australian scientists are working to convert sugar cane bagasse (leftover fibres from cane crushing) and trash into animal feed. "What we want to do is add the probiotics or the enzyme supplements into that so that they start to grow at a faster rate, so that means they're more productive animals for the farmer and more profitable," said Queensland University of Technology's Brisbane labs Dr. Robert Speight to the ABC. He also said: "Everyone wants to make as much profit and as much money as a business as you can so any opportunity to take something coming out as a waste — either as a cost, or low value co-product — if we can turn that into something of high value with an economic process — that's more money for the business." None of these are suitable as feed for the milking herd producing RDM. Real value lies in learning how to grow abundant, drought tolerant, healthy forage in the paddocks. 

Breeds and feed requirements

Different cow breeds have different requirements. The traditional breeds like the Jerseys, Guernseys, Milking Shorthorn etc. can happily thrive on a 100% pasture-fed diet from high quality, healthy pasture when this is what they were raised on. The more modern white and black Holsteins are sometimes a different story. Crossbreeding led to a high milk-producing animal that produces less butterfat and protein based on percentage in the milk, compared to the other breeds. Some experts say this breed needs the addition of grain in the diet.

Video:  World-famous scientist Dr. Elaine Ingham endorse Holistic Management and praise Allan Savory for his work and perseverance to Regenerative Agriculture and Sustainable Land Management. In this video she talks about how to create an environment for the beneficial bacteria, not the detrimentals.

Organic labelling & farming methods standards

Good food is based in healthy, microbe-rich organic soil but the United States has produced a good number of examples showing that the organic label is being hijacked, enabling other farming operations to profit from it as well. This video explains that even imported grain into the U.S. suffers heavily under fraudulent certification. Farmers are angry because "when a consumer loses confidence in a brand, sales go down." Organic certification in Australia is currently under review. What policies are we going to end up with?

We too may need a new certifying body if we cannot trust in the supply chain due to the lack of accountability global free trade may create. After years of a slow build, the regenerative agriculture movement is finally taking off. The Savory Institute has created a solution for regenerative sourcing called Land to Market. It deals with issues like soil health, biodiversity and ecosystem function, more here.

Organic .jpg

A recent research article is pretty persuasive evidence about the power of biology and healthy soils.

The research shows that regenerative farming systems provided greater ecosystem services and profitability for farmers than an input-intense model of corn production.

"Pests were 10-fold more abundant in insecticide-treated corn fields than on insecticide-free regenerative farms, indicating that farmers who proactively design pest-resilient food systems outperform farmers that react to pests chemically. Regenerative fields had 29% lower grain production but 78% higher profits over traditional corn production systems." Despite the lower grain yield, the regenerative system was nearly twice as profitable as the conventional corn farms. The organic model has benefits, but as a risk reduction strategy, it should be a system with integrity because without it we run the risk of pathogens.

Traceability of feed and food security

Traceability of feed can be a headache in regulated systems, as all sources of feed (paddocks grazed, feed conserved and feed purchased) may be required to be listed as part of the food safety program. See this FSANZ document page 12 for the production of raw milk cheese. The microbial contamination of feeds is also challenging to avoid when many inputs are introduced from various outside sources. As the previous section shows, traceability and accountability are disappearing in a now global food system. As a risk reduction strategy, it may be best for farmers to focus on building their soil fertility and diverse pastures, instead of relying on inputs coming from outside the farm. It may be better for the raw dairy operation to focus on self-reliance, resilience and building the integrity on the farm.

Below is a video recently posted by Janette of Jannei Goat Dairy in NSW. Raw goat milk is legal to produce in four Australian states. Below is a bucket of rolled oats and lucerne chaff locally grown just down the road from the farm. When the farmer knows the producer of the grain in a local food system, the two parties can negotiate how the grain has to be produced. They can build a relationship of trust and accountability that reduces risk and enhance food safety.

An August 2018 A Current Affair story showed that Australia now both import and export huge amounts of grain. Some parts of Australia have had no rain in six years and are now run out of water. Part two shows a large ship docked containing 33,000 tons of imported grain (wheat and barley) from WA. It says there were 5 ships scheduled to dock in a row at Brisbane at the time and it took four to five days to unload. Most of the load was going to Darling Downs, a famed wheat growing region of Australia, now drought stricken. 80 Trucks a day loaded the haul and took it west where feedlots awaited it.

In part 3, Tracy Grimshaw asked National Farmers Federation CEO Tony Mahar, why are Australia exporting so much feed when we desperately need it ourselves? Tony replied that export feed is a good market for farmers. Australia exports because it is supposedly financially viable for farmers at times and Australia imports because of the drought and there is not enough feed for the animals. Watch the story via the links below.

  1. Country in Crisis - Part One

  2. Country in Crisis - Part Two

  3. Country in Crisis - Part Three


Australia will have to learn to farm regeneratively and grow local resilience. Research show that monocultures, tilling and modern agrochemical use will continue to deteriorate the fertility of our soil. Here are some of the myths that stand in the way:  3 Big Myths about Modern Agriculture.

Images:  Old fashioned animal husbandry wisdom. This 1949 edition book used to be in many Victorian dairy farming homes. It was compiled by the Department of Commerce and Agriculture under direction of the Minister Hon. R.T. Pollard, MP.  Today they are found in op-shops for a dollar or two. Click to enlarge the images. In 1949 most cattle in Australia were eating fresh pastures as their main food source because pastures supported it. We have a crisis today because many dairy farmers have overstocked and exhausted their best grass and pastures. Regenerative farming and holistic pasture management seems to be the only solutions for restoration.