An indication of the pro pasteurization position at that time comes Mr. Claus Heggum of the Danish National Committee of the International Dairy Federation who reported that the health risk from milk products in Denmark was negligible.  He stated that, "this was mainly due to practically no consumption of raw milk, to extensive preventive measures for minimizing the presence of pathogens in raw milk used for manufacturing, and to mandatory pasteurization of milk prior to processing." ^[1]   

            In the same report, Dr. Hans Asperger, from the Institut for Milcherzeuzung in Austria, pointed out that a major problem in raw milk cheese seems to be Staphylococcus aureus. [2]   In Austria, where more than 10% of the milk produced is consumed as raw milk and raw milk products with out any heat treatment,  Dr. Asperger recommended a different strategy to mandatory pasteurization,

 

   "to ensure the hygienic production of raw milk products, the need for appropriate education programs for the producers must be addressed.  This is managed by learning, training, and motivation conducted in seminars for raw milk product manufacturers with teaching aids provided.  A quality management system concerning the improvement of hygiene in the milk production will also be introduced comprising checklists, producing instructions and production protocols." [3]  

 

            Researchers at the Institut National de la Recherche Agronomique (I.N.R.A.), Station de Recherches en Technologie et Analyses Laitieres in Pouligny, France have been studying the properties of traditional cheeses made from raw milk for many years.  Around the same time as the WHO report was published, Remy Grappin and Eric Beuvier were finishing a review of the effects of pasteurization on the quality of traditional raw milk cheese.  They felt that raw milk cheeses represented a significant proportion of ripened cheeses produced in Europe, particularly in Italy, France and Switzerland, and were concerned about the economic impact from changes in quality due to pasteurization. [4]

            They wrote, "in the context of international trade and regulation, where hygienic aspects are predominant, it was important to know the consequences and possible implications of pasteurization on the ripening process, and ultimately on the sensory characteristics of cheese."  They found that the interaction between indigenous raw milk microflora and starter bacteria appeared to be extremely important in the ripening process and subsequent flavor and texture of the cheese.  Raw milk cheeses (Swiss, Cheddar, Manchego, Raclette and St. Paulin) developed characteristic flavor sooner and the flavor was stronger, richer and more diverse (less uniform)  than the same cheeses made from pasteurized milk.  After comparing the same cheeses made from raw and pasteurized milk, they concluded that, "pasteurization modifies the biochemistry and microbiology of ripening, and the flavor and texture of cheese.^" [5]

            They stressed the fact that the approach used in making traditional raw milk cheese has limited or no standardization of the milk, thereby keeping the natural characteristics of the milk that originated from the specific area of production.  The cheese is usually made in small to medium sized operations and the make process is adjusted according to the characteristics of the milk.  Even with this, the cheese will have variation in quality.  This diversity in sensory properties is a direct consequence of variation in the conditions of milk harvesting and transformation.  Furthermore, "this diversity is sought by both the producers and the consumers, because it is a special feature of traditional cheeses." [6]

            Patrick Rance, one of the great champions of raw milk cheese, was hard at work in England during the late 1980's investigating the relationship between Listeriosis (and Salmonellosis) and raw and pasteurized milk cheeses.  He spearheaded the campaign to save raw milk cheese in Great Britain and used the findings of careful research to refute the argument that raw milk cheese was responsible for cases of Listeriosis.  Mr. Rance felt that the evidence clearly showed that pasteurized milk cheese is most at risk. [7]   He stated that, "pasteurization, far from being the remedy, leaves an open field for Listeria monocytogenes to invade and conquer.  In all international investigations, no raw milk cheese has been impugned." [8]   Mr. Rance was in  agreement with Dr. Asperger that risk management strategies were needed to safeguard the quality of the raw milk production: (1) animals should be fed on hay and not silage or root crops, (2) milk parlors should have uncompromising standards of hygienic dairy practice, (3) water supplies should be pure, and (4) the introduction of soil into the milk processing environment should be avoided at all costs.  He also alluded to the concept of "competitive exclusion" of pathogens in raw milk by using techniques to bolster the activity of bacteria which can discourage the growth of Listeria. [9] This is currently thought of as an effective means to reduce the health risk from pathogens in raw milk.  

            In Germany, farms were able to produce certified raw milk (Vorzugsmilch).  This certified raw milk could be traded on larger scale and consumption was permitted.  Since the government was involved in the certification, it was also responsible for the product.  The German Milk Ordinance requires that certified raw milk be regulated by strict hygienic standards on the farm and strict surveillance by officials.  At least one farm is ISO 9000 certified. [10]   Philipp Hammer, a researcher at the Federal Dairy Research Centre, noted that, while the hazard of yersiniosis and campylobacteriosis was present in Germany, the risk for healthy individuals to come in contact with the disease was very low.  Persons at risk (mainly school children visiting farms) were advised not to consume non certified raw milk without heat treatment (pasteurization).  The practice of certifying farms to produce Vorzugsmilch continues today, with a system of hazard-reducing control points and strict microbiological standards. [11]

            These examples of different positions on the public health issue of raw milk and raw milk products indicate the extent of the debate in the EU at the time when the production of  raw milk cheese was in jeopardy.  No matter how well the proponents of mandatory pasteurization stated their position with regard to public health, there was still the issue of trade to deal with.  Statistics from the Direction General de l'Alimentation (Agency of Foods of the Republic of France) showed that 700 million kilos of raw milk cheese were produced in the European Union in 1995; Italy with 240 million kilos, France with 210 million kilos, and Switzerland with 100 million kilos were the largest producers.  In France, where raw milk cheese amounted to one quarter of their total cheese production, and in other countries, particularly Southern European ones, raw milk cheese represented a significant and important contribution to the agricultural economy. 

Given the importance of raw milk cheese products to the economies of these countries and the difficulty for cheese makers in these countries and others, like Spain and Portugal, to convert to pasteurization, it was inevitable that a compromise was reached.  The approach taken by the Austrian and German dairy industries to implement safety controls and stricter standards demonstrated an effective strategy that the EU countries could use to improve the safety record of raw milk cheese and other raw milk products.  In framing a different approach from mandating pasteurization as a safety net for milk products, the traditional raw milk cheese making countries proposed to guarantee the safety of the cheeses instead.  To do this, they worked to create a new system for regulating the production and trade of dairy products in the EU, which was based on microbiological risk assessment.

The first step was to develop a new set of regulations for the production and trade of milk and dairy products in the EU.  Two "Directives," which contain the regulations were composed with mutual agreement of all member states; these came fully into force on January 1, 1998.    "The health rules for the production and placing on the market of raw milk, heat-treated milk and milk-based products intended for human consumption," are contained in Council Directive 92/46/EEC. [12]    A second text, Council Directive 93/43/EEC of June 14, 1993, governs "the hygiene of foodstuffs," and refers to the use of HACCP protocols, developing guides for member states based on the Codex Alimentarius, and other measures for protecting public health. 

These Directives are important because they lay the foundation for the regulatory systems, which member states developed to safeguard the production and sale of dairy products, including raw milk cheese.  The concept of HACCP (Hazard Analysis and Critical Control Points) is a dominant part of the regulations and competent authorities are instructed to carry out controls to assess whether the necessary monitoring and verification procedures are being used by producers at critical control points in their processes.  The Directives instructed the EU member states to develop their own laws, regulations, and administrative provisions to comply with the new regulations.  For EU trade, the EEC Directives are the rule books of reference.  Each measure adopted by the member states to fulfill the requirements of a Directive must contain a reference to that Directive and these must also be noted  in official publications.