An outbreak of E. coli O157 infections, linked by CDC and FDA investigators to cheddar cheese sold by a California company called RAW FARM, has produced two findings worth thinking about together. The first is epidemiological: across three states, every patient interviewed reported eating raw dairy, and every patient who remembered the brand named the same one. The second is institutional: the company refused two FDA requests to voluntarily recall its cheese, the FDA took weeks longer than it would have in any previous administration to compel action, and when the recall finally came on April 2, the company issued it “under protest” while continuing to deny the investigation’s findings. The cheese was the proximate cause of the illnesses. The political environment in which a company felt free to defy federal investigators is the deeper story.

How outbreak investigations actually work

The public imagination of an outbreak investigation tends to involve a single, decisive piece of evidence: a contaminated batch identified, a culture grown, a smoking gun produced in time for the evening news. Real outbreak investigations almost never look like that, and the reason is worth understanding, because the gap between expectation and reality is exactly where bad actors find room to operate.

When people are exposed to a contaminated food at a single event, a wedding, a banquet, a church potluck, the investigation is comparatively straightforward. Epidemiologists call this a point-source outbreak, and the shared meal makes the link between exposure and illness easy to establish. The RAW FARM outbreak is the opposite case. The exposure occurred across a wide geographic area, over a period of weeks, through a product sold in many different stores to many different households. To connect the dots, epidemiologists have to interview every patient about every food they ate before they became sick, relying on a combination of human memory and electronic records, neither of which is fully reliable. Microbiologists have to obtain specimens from patients and link them together using genomic sequencing. Ideally, they would also obtain specimens from the food itself, but by the time an outbreak is identified, the contaminated batch has often been eaten, discarded, or replaced on store shelves with new product. Contamination is frequently intermittent, which means the absence of bacteria in a tested sample does not mean the food was never contaminated.

Because a single decisive piece of evidence is rarely available, public health officials have to act on the preponderance of evidence. This is the same standard that operates in most domains where scientific reasoning meets practical decisions, including questions about how antibiotics affect long-term health, whether vaccines work in real-world conditions, and what we can responsibly say about the origins of any given outbreak. The point is not that certainty is unavailable; the point is that certainty is rarely the standard by which good public health decisions are made. The standard is whether the weight of the evidence, taken as a whole, supports action.

What the evidence actually shows in this outbreak

In the RAW FARM outbreak, the epidemiological case is about as strong as a case of this type ever gets. As of early April, nine people had been infected with the outbreak strain across three states. Eight of the nine were interviewed, and every one of them reported eating raw dairy products. Of the seven who remembered the brand, every one of them named RAW FARM. Genomic sequencing confirmed that all the infections were genetically identical, which means the bacteria came from a single source. The probability that nine people in three states, all reporting the same brand of raw dairy, all infected with a genetically identical strain of E. coli O157, are linked by chance rather than by a shared exposure is essentially zero.

RAW FARM nonetheless twice refused FDA requests to voluntarily recall its cheese. The company posted on social media that the outbreak was unrelated to its products. It reshared testimonials from customers who continued to buy the cheese and feed it to their children. When the recall finally came, it came under protest. This is the response of a company that does not believe the federal government will hold it accountable, and the company is not wrong to think so.

The political environment that made this possible

Food safety in the United States works because regulators have the authority to act on a preponderance of evidence and because companies broadly accept that authority. When a company defies a recall request, the cost has historically been swift and visible: enforcement action, reputational damage, public health communications that name the brand and warn consumers directly. Those tools still exist on paper. What has changed is the political environment that determines whether they are used, and how quickly.

The Washington Post reported that the FDA took weeks longer than it would have previously to compel action, and that the company’s defiance was likely emboldened by the current political moment. The head of the federal department overseeing food safety has publicly celebrated raw dairy as a health food and framed food safety regulations as an assault on consumer freedom. When the political leadership of a regulatory agency signals that the rules have changed, producers will test that signal. Some will conclude, correctly, that the cost of defiance has gone down. The people who pay for that recalculation are not the producers or the political officials. The people who pay are the consumers, often children, who develop bloody diarrhea, kidney failure, or worse from a pathogen that pasteurization would have eliminated.

The pattern is not new. Whenever the political class signals that public health enforcement is optional, some portion of the regulated industry treats it as optional. This is the same logic that operates when budget cuts shift costs from public health agencies to the people who get sick, and when Medicaid cuts shift costs to the sickest and poorest. The savings show up on a balance sheet. The costs show up in hospital beds.

What raw dairy actually is

Pasteurization is one of the most successful public health interventions in the history of the modern world. Before it became standard, milk-borne illnesses, tuberculosis, brucellosis, typhoid, scarlet fever, killed children at scale and accounted for a substantial portion of childhood mortality in cities. Pasteurization is not a corporate plot to strip dairy of its nutrients. It is a heat treatment that kills the pathogens that turn dairy products into a regular cause of serious illness, with no meaningful effect on the nutritional profile of the milk. Raw dairy is not a health food. It is dairy with the safety step removed, and the pathogens that the safety step was designed to eliminate are the pathogens that have now infected nine people across three states.

The political fashion for raw dairy is not a return to some imagined natural state of human nutrition. It is a marketing position that uses the language of freedom and authenticity to sell a product with a documented risk profile, and it is being amplified by political officials who should know better. When those officials signal that food safety regulations are optional, the message reaches every producer in the country. Some of them will take that message as permission. The cheese was the proximate cause. The political environment is the deeper one. Both are worth naming.

Related FAQs

These related FAQs give more background on outbreak response, prevention, and the public health systems involved in foodborne disease investigations.

About the Author: Dr. Jay Varma

Dr. Jay Varma is a physician and public health expert with extensive experience in infectious diseases, outbreak response, and health policy.