Yesterday, I saw this intriguing clipping of a press release-like ad by Nestle in Ghana about its mega-brand, Ideal Milk.

The primary message in the ad can be distilled into three lines:

• Some liquid Ideal Milk cans on the market have coagulated contents (the fluid has become viscous/thick).
• The product will not harm anyone who consumes it.
• Customers who are nevertheless worried about the product should reach out to Nestle directly.

I was fascinated by the ad because:

• I like Ideal Milk;
• I have spent two decades of my life in product safety, consumer protection and supply chain; and
• I have recently developed a fascination for the history of food canning;

The value proposition of Ideal Milk, in the wider universe of “evaporated milk”, is “creaminess”. As far back as the 1920s, Nestle was packaging the goodness of ideal milk as being about the cream. Normal cow milk doesn’t always have the frothy cream when you want it and in the amount you need. But Ideal Milk does. It is always creamy. Of course, creaminess must taper off at a point, hence the recent outcry.

Like much of the rest of the food canning industry, it was war that dramatically catapulted canned evaporated milk onto supermarket shelves. The need to send soldiers around the world and keep them for months on the battlefront called for a modern food logistics system that greatly favoured canning. The balance of necessity and accessible luxury has long been a key brand positioning factor for the canned evaporated milk industry even as a host of health concerns, ranging from lactose intolerance to concerns about weight gain and cholesterol, have chipped away at the product’s place in shoppers’ hearts.

How then does one achieve “consistent creaminess” (luxury) and long shelf life (necessity) together? By adding vegetable fat to fresh cow milk and then applying heat treatment and other techniques, such as homogenisation.

The first person to try and commercialise evaporated milk production was Nicholas Appert, in response to a challenge by Napoleon Bonaparte to French chemists to come up with ways for the Emperor to feed his conquering armies in far-flung battlefields. But it would take about a hundred years more for the likes of Borden, Joseph House, and John Meyenberg to perfect and patent the necessary processes. Mass consumer acceptance was not assured until critical steps like homogenisation, sterilisation, and standardisation could be mastered, balancing creaminess, long shelf-life and taste. In 1923, the Evaporated Milk Association emerged to codify what had been learnt on the way to this point.

This “codification” was given the force of law by the United States government in the same year of 1923. The US continued to be a pacesetter in setting standards, with major updates in 1939 and 1940. Today, its Department of Agriculture frames the standard in terms of minimum solid fat content as follows:

Evaporated milk is the liquid food obtained by partial removal of water only from milk. It contains not less than 6.5 percent by weight of milkfat, not less than 16.5 percent by weight of milk solids not fat, and not less than 23 percent by weight of total milk solids (21 CFR §131.130(a)).

In the course of time, however, global standards have emerged. The Food & Agriculture Organisation, a UN agency, now maintains the Codex Alimentarius, the most authoritative handbook of food standards in the world. The specification for evaporated milk in this code is captured by standards, such as: CODEX STAN 281-1971 and CODEX STAN 250-2006.

Here is the Codex definition:

A blend of evaporated skimmed milk and vegetable fat is a product prepared by recombining milk constituents and potable water, or by the partial removal of water and the addition of edible vegetable oil, edible vegetable fat or a mixture thereof, to meet the compositional requirements in Section 3 of this Standard.

The minimum solid fats content is specified as:

• Minimum total fat: 7.5% m/m
• Minimum milk protein in milk solids-not-fat(a): 34%

It is natural when confronted with a situation, as we have it now, where a product meant to be sold in liquid form presents as a thick pasty, semi-solid, sludge, to focus on the part of the standards that seem most applicable to the physical state of the product. But as should be clear from the above, the standards seem silent on the upper bound of solids in evaporated milk. What this clarifies is the fact that, generally, standards are minimalist when it comes to presentation. But not when it comes to safety.

Which brings us to the heart of the matter (sorry for the longwinding detour, I could not resist throwing in some hobbyist tropes). Nestle admits “coagulation” in some packs of ideal milk in response to widespread reports.

They do not specify which batches. On the basis of “collaboration” with the Ghanaian food regulator, the FDA, they are confident that the coagulated milk is safe.

Interestingly enough, there is a very long history of evaporated milk coagulation, dating back to the very early days of the product’s commercialisation. In 1915, a large “outbreak” of incidents involving consumers complaining about coagulated evaporated milk was reported in the US State of Iowa. William Sarles and Bernard Hammer investigated this incident thoroughly and identified a particular bacterium, Bacillus coagulans, as the microorganism responsible.

The primary discovery here was that notwithstanding effective pasteurisation and sterilisation, there exist some bacteria that can evade the controls, infect the can and, during storage, coagulate the liquid milk.

Since these pioneering studies, our understanding of the impact of thermophilic and thermoduric bacteria on evaporated milk has improved greatly. We now know that spores of Bacillus stearothermophilus, for instance, will lie dormant in the can until storage temperature exceeds 40 degrees celsius at which point they will activate and start to attack the milk.

Virtually all the reports of Ideal Milk coagulation I have seen so far do not mention odour, putridity, colour changes or blotches. Curdling and thickening are the only features mentioned. This more or less rules out the worst kinds of fermenting bacteria. But it does not rule out thermophiles like B. coagulans and Bacillus cereus.

Now, for a bit of relief. Bacillus coagulans are today widely believed to act as a probiotic, which means they are generally safe in the human gut.

Same, unfortunately, cannot be said for B. cereus, whose proclivity for contaminating ultra high treated milk is now a growing focus of research.

B. cereus is now routinely implicated in some forms of food poisoning.

In short, so far, no reports have come in to suggest that people are getting sick from consuming Ideal Milk. The most worrying form of coagulation would be that caused by microorganisms. But, as explained above, some microorganisms that cause coagulation are completely harmless. Non-biological causes of coagulation, on the other hand, are mostly related to the persistent challenge of fat separation. Ineffective homogenisation is the most widely cited culprit for this situation. Generally, the process of sterilising milk to increase its shelf-life would itself cause coagulation. To maintain the liquid state of the product, as well as ensure heat stability, delicate calibration of multiple factors is required. Casein content measurement, precise heat regulation, homogenisation, and even salt use must all be carefully modulated.

Thus, the coagulation being witnessed could be the effect of a homogenization failure or related fat regulation issue, such as lecithin use and concentration. Whilst this may raise Good Manufacturing Practice (GMP) questions, not all quality variability issues are automatic GMP breaches, and not all GMP breaches are automatic health and safety issues. There are varied thresholds and caveats, and everything depends on how exactly the variability occurred.

That is why a matter such as this cannot be left to the brand communications strategy of the manufacturing entity involved. The ambiguity and multiplicity of potential causes and effects require that someone other than the manufacturer be involved in communicating with the public. Whilst Nestle has involved the FDA in its investigations, and appropriately so, the press release does not rise to the appropriate level of public assurance. It does not explain why this is not a health and safety issue. There is no independent corroboration that the remedial measures taken to address the root cause are adequate. This is not about protecting the brand of a giant multinational; it is about safeguarding the health of millions, or at least securing their peace of mind.

Talking to people affected by this incident, however, I get the sense that there is a fundamental philosophical conundrum at play here. Some people say that they trust Nestle more than they trust the Ghanaian FDA. It is hard to blame such people. Senior officials of the Ghanaian FDA have in recent times been caught taking bribes in connection with similar GMP, health and safety matters. Some argue that Nestle, despite its occasional run-ins with activists, and not fully atoned for history with baby milk formula, has additional oversight at a global level that may be more stringent than what the local regulator has in place.

So, it is a brand issue after all: it all boils down to the level of trust among the general public. One cannot milk a brand one has not built.

Nonetheless, my personal view is that the regulator has more to do to earn and hold the trust of the general public than Nestle. The latter after all is, first and foremost, in business to make money. If it genuinely believes that its products are not contaminated, it is not difficult to see why it will be reluctant to take steps, like a mass recall, that will not only cost it lots of money but potentially also damage one of its most lucrative brands. A regulator, on the other hand, must balance multiple considerations and strive to be candid and transparent in all its dealings regardless of financial considerations.

The fact that the FDA has so far refused to share its own findings for nearly six months is a serious abdication of its duty to the public. Even if public cynicism and distrust of such vital institutions are sometimes unfair, the FDA has every opportunity to redeem its own brand.