Dr David Jukes, The University of Reading, UK

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Food Law News - UK - 2019

FSA Consultation Letter, 7 February 2019

OFFICIAL CONTROLS / MILK - FSA Consultation: Review of raw drinking milk official controls

Consultation Document: Review of raw drinking milk official controls

A copy of this document is available on this site (click on image). Consultation closes: 30 April 2019.

Provided uder the Open Government Licence. The original consultation document was accessed from: . The original consultation page, giving access to additional documents, was accessed from:

The following is the introduction to the consultation:


In June 2018, the FSA Board was presented with a decision paper to review current controls for RDM.  The paper provided recommendations of planned improvements that could be made in the delivery of official controls as well as providing the evidence used in reaching these recommendations.

The Board agreed with the conclusion that the risk from RDM is not so unacceptable as to justify removing the right of adult consumers to choose to drink it, provided that certain controls are met.  However, the board did recognise that improvements are required in terms of ensuring more robust controls, accountability and the need for FBO’s to provide assurance to their customers and the regulator that the product that they produce is safe.


There have always been legal requirements for FBO’s to register with the FSA for production of Raw Drinking Milk, have a system in place to identify, monitor and control hazards associated with this production and to verify that the controls measures in place for these hazards are effective.

As part of the review of the official controls the FSA as the regulator are going to be more explicit in how they require FBO’s to demonstrate that they meet these legal requirements.  The new controls will apply to all new producers and existing producers not already meeting the requirements will have a period of 6 months in which to make any changes necessary.

Having a Food Safety Management System in place will allow producers to identify the stages of their production systems that could pose a risk and have control measures in place to eliminate or reduce these risks to an acceptable level.  

Template documents demonstrating the minimum requirements of these systems have been included to aid producers to better understand how this can be set up.  These templates could be used or an alternative that provides the equivalent information.

Valid Food Safety Management Systems have a verification step included which is aimed at testing the effectiveness of the control measures introduced and verify their effectiveness, allowing for corrective action to be taken if needed.  Periodic testing is seen as the most effective way to verify these systems and within the registration guidance document there is a list of the pathogens that can be found in RDM, producers will be asked to test for these to establish and verify the effectiveness of their FSMS.  

The frequency at which testing should take place has not been specified as this will vary dependant on the nature of the business so instead the frequency will be decided by producers using their FSMS and the risks highlighted through this as justification for the frequency applied.

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