How does the AB 1735 coliform standard work?

Under current regulations, which went into effect in January 2008, raw milk end products must test under 10 coliform units/ml on a weekly basis. Because it is the end products that must meet the standard and not the source raw milk, the dairy’s milk may pass the test and the cream may not, as an example. Each product must pass the coliform test 3 out of every 5 times. Thus, a product may have failed the test 2 out of the last 4 times, but will not be put on “degrade” unless it fails the next test. Under this system, a product degrade happens gradually over the course of several weeks, and a dairy can at any point be one test away from receiving a degrade notice.

Because California requires mechanical bottling and capping of all of its raw dairy products, the extent of exposure to coliforms is much greater than in other states that allow bottling and capping by hand, such as Washington and Pennsylvania. The more that raw milk is passed through and exposed to pipes, air, residual clean water in pipes, pumps, etc., the higher the coliform levels will be. Hence, coliform levels are not inherently a measure of safety. Rather, the 10-coliform limit has been used since the 1930s to check that the pasteurization process was effective and most of the bacteria have been killed.

The term ‘coliform’ is just a name for the test, and is not a type of bacteria. The CDFA also tests for pathogens in raw milk products once per month. Some of the pathogens, such as Campylobacter, do not show up on a coliform test at all. So, a raw dairy product with a zero-coliform count may still have high levels of pathogens. This is one way SB 201 would have increased safety -- by increasing the frequency of pathogen-testing.