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Water Source

Risk Category 4

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



Water is a Critical Control Point in The Raw Milk Institute's Risk Assessment Management Plan. CCP is an essential measurable control point that must always be achieved. If CCP fails, production must stop until it has been investigated and remediated. We are fortunate that we can look to Food Standards Australia New Zealand (FSANZ) documents like this one:  Primary Production and Processing requirements for raw milk cheese page 13. The production of raw milk cheese has been legal in Australia since April 2015. Standards for the production of raw cheese can very easily be adapted for raw drinking milk (RDM). We do not have to reinvent the wheel.

"Potable water is defined in the Code as water acceptable for human consumption. It is essential that water used in the milking shed does not introduce contaminants and result in the contamination of raw milk with microorganisms. The water supply used within the dairy for sanitising and rinsing the milking plant, for washing teats, mixing up of teat dips and hand washing for operators should be potable."

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Water is used in almost every aspect of the raw dairy operation; therefore it is critical that water be free from microbial contamination. If there is contamination at any stage, it can have serious consequences. It can also be challenging to identify the source of the problem.

Some countries have severe problems with the water quality of their natural resources. New Zealand recently had a huge outcry from the public about the pollution of their lakes and waterways and the effect that large-scale industrial dairy is having on the environment. Australia may not have exactly the same problems, or on quite the same scale, but the parallels are there.

It is often industrial agriculture, with its animal waste and antibiotics from livestock operations fed vast amounts of grain, that fouls the waterways. According to this article, the UN reports that American farms discharge large quantities of agrochemicals, organic matter, drug residues, sediments and saline drainage into water bodies, resulting in “demonstrated risks to aquatic ecosystems, human health and productive activities.” The report also states that in the last 20 years, a new class of agricultural pollutants has emerged in the form of veterinary medicines (antibiotics, vaccines and growth promoters [hormones]), which move from farms through the water to ecosystems and drinking-water sources.  

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Healthy organic ecosystems however, rarely have serious problems with water quality. Recently the Rodale Institute, the global leader for regenerative organic agriculture, received a nearly $6 million grant for a project to improve soil health and water quality. They will partner with the Stroud Water Research Center, the global leader in the advancement of knowledge and stewardship of freshwater systems. The project will focus on improving farm productivity and profits while reducing water pollution associated with agricultural runoff. The research will help landowners, policymakers and businesses make better choices so that there is less water pollution in our rivers. This is a project worth following because there is already lots of proof that these systems are effective, more here.

GAP Food Safety Educator Lindsay Gilmore points out that the Wild Farm Alliance has come up with some excellent publications, information and evidence indicating that conservation practices and natural areas can often reduce pathogen risk while providing many benefits, like soil and water conservation. Many argue that the research already exist to fix water problems on farm ecosystems for good. Raw milk dairies often operate on small family farms and the Wild Farm Alliance information demonstrates that farmers can take care of the risks when they can do the appropriate pre-meditated planning.

Some feel the solutions are being ignored in Australia because the government seem to support only 'get big or get out' in agriculture. Many of Australia's largest farms have been bought by overseas owners who seem to be only interested in large-scale industrial agriculture. What sort of farming values do these corporate owners have? Will they be able to embrace organic or regenerative farming practices? Will they be able to respect the land and the communities around the farm? Time will tell...

Risk Exploration

Water source and quality

According to the food safety plans of many RAWMI-listed farmers, it is good practice to test the water supply annually for potability and coliforms. The water used has to be suitable for human consumption. According to this 2018 article costs start from about $25-$50 a sample to test for the presence of blue-green algae, to $100-$150 for more extensive tests for things such as E coli levels.

The quality of the drinking water available to cows are essential. What they ingest affects their internal ecology and their health. If there is organic matter, slime, discolouration or odours in the water trough it can be an indication that they are not being cleaned properly or frequently enough. Make changes to your Standard Operating Procedures to remedy the problem. You should have procedures in place for staff to ensure steps are taken for clean and fresh drinking water. A permanent water trough is better because it eliminates the possibility of animals becoming stressed or dehydrated by lack of water. Be sure to make it stock proof. Some cheeky animals may try to take a dip and in the process cut off their water supply.

Water on the farm has a variety of risks. The farmers need to learn what these are on their own particular farm. Both stagnant and river water can be a risk and access should be restricted. Cows can also develop foot rot from standing in still water, which is something they like to do on a hot day. Movable electric wiring can be used to keep animals out of specific areas of stagnant water where disease may be breeding. The drinking water should be free of contaminants and chemicals. Care should be taken to avoid transmission of water-borne disease. In other words, employees should avoid sticking their hands in contaminated or stagnant water and then proceed to clean the water troughs. Good hygiene applies everywhere on the farm.

In risk category Farm and Land Conditions, the farming practices of neighbours and how that may affect your raw dairy business are explored. If your neighbours have a CAFO, manure lagoons or unsustainable farming practises it may change your water source. Make sure you understand the risks and find ways to mitigate them because clean water is critical to the raw dairy operation. Add this to your RAMP food safety plan. Without it there is no business.


It is also important that farmers understand the risk they are taking by feeding other animals on the same farm, like pigs, feed such as brewer’s grain or distillers grain. It enhances the change of pathogenic e.coli in the gut of animals (see the Feed category). These microbes may spill over into the terrain or find their way into water sources. The microbes may spread via boots to the milking parlour or other areas where it can be a contamination problem. There are many seemingly innocent industrial farming practices, that can harm raw dairy’s food safety, and should be avoided on the farm producing RDM. As a risk reduction strategy, RDM farmers must learn how to grown abundant, year-round forage instead, by learning how to grow the right kind of soil microbes that increase nutrient-cycling, and also the use of multi-species cover crops and increasing native grass species diversity. Soil scientists teach that there are another ways to grow abundant and nutrient-dense forage via strategies like compost-tea, that mitigates and even eliminates many potential risks, see the Biosecurity category.

Water Pressure

The pressure of the water coming into the dairy is vital because interruptions in pressure or failure to deliver sufficient force can have a significant impact on the efficiency of the operation. It can mean that tasks cannot be carried out adequately and operation may need to stop. Make sure there is ample water pressure for the daily service from start to finish. The strenght and flow of water to troughs in the paddocks are also significant because should these fail to be detected early, it can have a significant impact on the health of the animals. This hazard must be avoided because we need the animals to be super healthy. A gravity-fed water system to the troughs may be cheaper than paying to pump it around, and it may reduce risk as well.

Water temperature

There should be hot and cold water available in the dairy (for cleaning milking equipment), the bottling room and at the toilet facilities. Spesific cleaning solutions and processes require hot water and cold water. Having only warm water may be a risk to the cleaning of certain equipment and therefore a risk to the operation. Also make sure that you have adequate hot water for the entire daily operation from start to finish.

CIP systems

Larger raw dairy operations make use of CIP systems, and these are great to have for the management of the water supply. We have discussed before that animal health, and soil health is crucial for the RDM system. Another essential element is the safe management of water quality. 

Increasing beneficial bacteria in water to outcompete bacteria that negatively effect cow health

In this video, Aled Davies from Pruex in the UK explains why biofilm has to be removed from the water supply of animals frequently, because it can become a contaminant. His petri-dish experiments shows that pathogens can return even after pressure-washing, detergent and disinfection because farmers have not adequately dealt with biofilm.

In the video, he shows how good soil microbes can be added to various terrains with incredible microbial evidence of colonisation resistance. When the good microbes are in ratios much larger that pathogens (ideally 60%), beneficial microbes form colonies that outcompete, disable and even eliminate pathogens. Aled visits all types of intensively farmed operations, where animals are surrounded with infective bacteria, putrid water and the air they breathe is contaminated. He found the use of disinfectant is maintaining sick animals, as opposed to reducing disease.

At the 8 minute time marker, Aled shows how Pruex works to get clean water to cows. Aled explains how biofilm in terrains like pipes can be a strong source of contamination. This biofilm can contain putrid bacteria releasing enzymes into the cow’s drinking water creating immune problems and other infections. At the 11 minute time marker, Aled shows how he uses soil bacteria with a pump to clean pipelines. He says this significant increases the health of the cows, and also the amount of milk they produce by two litres a day. Water troughs for cows can be a serious infective place of disease for cows unless cleaned properly. Aled says his methods is making it easier for the animals to maintain health and to properly fight off any infections. Aled’s solutions are currently enjoyed and implemented by some UK raw milk cheese and raw drinking milk (RDM) producers.

Fracking of prime agricultural land  

The United Kingdom has several raw dairy farmers who are staring a crisis in the face. Fracking rigs are seen from Pemberton Farm in the Fylde area of Lancashire. Farmers are very angry and opposed to fracking because they say England is too small and too populated for fracking and that the area often floods which will cause pollution. The environment has many pristine interconnecting waterways and underground water that will be contaminated, which will quickly spread to other farms. See the information at the bottom of this article to follow this particular story.

In Australia, large communities in Queensland and NSW are very concerned and angry about coal seam gas mining that is posing unacceptable risks. SBS Insight recently created an episode about the situation. This story explores why the community is so concerned about the Great Artesian Basin. It's a vast water reservoir that is dropping, and there are concerns about it being pumped out, dried up or contaminated. The farmers and farmland also face significant losses if the extracted water from coal seam gas reserves leaked or spilled. According to the article, the CSIRO says hydraulic fracturing, or fracking, is used in up to 40 per cent of coal seam gas wells in Australia. "Fracking involves injecting fluid made up of water, sand and chemical additives under high pressure into the coal seam. The pressure creates a fracture that allows gas to more readily escape."  


A new Australian documentary Sacrifice Zone explores the factors that led to the Narrabri Gas Project, which is supported by politicians despite the weight of community opposition and scientific evidence against it. Turn the volume up to watch the video below, or watch the complete documentary here.


Another new documentary call Pipe Dreams Fractured Lives also looks at the cost to the local communities in Queensland, as well as in the USA where is problem has progressed to a far worse stage, see this video.


Ultraviolet disinfection of drinking water

Protect your water from microbial contamination by investing in equipment such as ultraviolet light. This is a good risk reduction strategy for the raw milk dairy in a risk-averse country like Australia.

An ultraviolet light may set you back around two thousand dollars or more, but the benefits can far outweigh the cost. Many potential problems can be averted by making this investment. According to this Australian government website, a UV light will damage the microorganism's cellular function so that it will not be able to grow. The site says that "UV light is normally effective against all viruses, bacteria and protozoa. However, some microorganisms such as Cryptosporidium and Giardia have protective or thick cell walls that some low power UV light systems are not able to penetrate. (It is important to make sure the UV light disinfection systems are specifically designed to kill these microorganisms if necessary.)" According to the website, there are some UV light systems from the treatment class IIc that will remove or inactivate Cryptosporidium and Giardia. This website is a great resource to help the farmer select the appropriate UV light disinfectant system. UV has now become a treatment process for municipal water as well. For some cities it is an effective backup treatment process.

Please also remember that both the filter and the light bulb on the UV light system needs replacement with some frequency. If bacteria, dirt, debris builds up, or the light fails, it can become a huge risk to the operation. Read the instructions to determine the lifespan or the replacement cycle (of the filter and the bulb) and set reminders in your maintenance calendar (if you keep one). These tasks can be added to the Standard Operating Procedure document, adding the date of each replacement for the record in the latest SOP version. The use of a UV light disinfectant system on your water source can also be added to the RAMP food safety plan as a risk mitigation protocol. If the UV light system allows it, the entire water supply can run from it. It may also be a good risk reduction strategy to not only rely only on the UV light with its filter for protection. Another water filter or another risk reduction strategy can be implemented on the water source for additional security.

0.5 Micron water filter

As discussed in the section above, microorganisms like Cryptosporidium and Giardia has a protective or thick cell wall that some UV light systems may not be able to deal with effectively. Moo View Dairy in South Australia had been supplying raw cow's milk for up to 600 families for 17 years but was banned from providing in July 2017. The Health Department claimed that in June there were higher than expected numbers of cryptosporidiosis (a form of gastroenteritis).  According to Raw Milk Advocacy Association SA no trace of Cryptosporidium was found in the milk, read more here.

It can be seen as a risk reduction strategy to invest in a 0.5 micron filter that can deal with the possibility of coming across this tiny parasite. It may spare some other farmer the emotional and financial stress that the Tyler family went through due to being accused of making people sick. An Australian water filter business made some recommendations in this article.

This CDC website recommends that filters designed to remove Crypto must have an absolute pore size of 1 micron or smaller. Other sites say the 1 micron is not 100% effective for Crypto and that smaller is better.


In the last two decades, our perception of what is harmful and what is not has changed significantly. A small number of people now understand that most bacteria in the E.coli and Listeria family are harmless. Many of the harmless microbes in the E.coli family are actually beneficial or essential for the health of the human intestinal tract.

Some parasites like hookworm, who were previously considered harmful, now show to be harmless and beneficial for humans. Research show bacteria, viruses, protozoa, small worms and fungi make up the human micro-biome anyway (source). Research show that 80% of our immunity lies in the gut and that having a gut packed with beneficial, diverse species bacteria can protect the intestinal tract from the bad bugs. Research also show that most Australians don't have good gut health. What will we discover in the future about the role of parasites like Crypto and Giardia? Perhaps if Aussies had a protective buffer of good gut bugs, they would be less susceptible to experiencing adverse side effects from exposure to bad bugs. It’s called colonisation resistance. If we had more sustainable farms providing ecosystem services like clean water, the risks in water could be considerably less.

According to Peter Pollard, an Australian microbial ecologist in this TEDx video, 99% of all microbes on this planet are "essential for our very existence. We would not be here if it wasn't for these microbes." He says only a few of the disease causing bacteria and viruses gives microbes a bad name. Many of the most significant health problems we have is because we do not have plenty good, diverse species microbes in our gut to protect us. Turn up the volume and watch the video below.