FSMA Food Safety Regs Going Local

Starting September 17, 2018, all “very small business“ (roughly defined as business with less than $1 million in annual sales1) manufacturing, processing2 or holding food must be in compliance with applicable federal regulations issued pursuant to the FDA Food Safety Modernization Act (FSMA) that govern “Current Good Manufacturing Practices, Hazard Analysis and Risk-Based Preventive Controls for Human Food.”3 These regulations break down into two different requirements: first, that the food business be in compliance with current good manufacturing practices (CGMPs) and, second, that it develop and implement a food safety plan that effectively performs a hazard analysis and designs risk-based preventive controls for human food (HARPC, Hazard Analysis and Risk-based Preventive Controls).4

The way FDA is interpreting these regulations, many local food producers will be under FDA‘s jurisdiction and subject to inspection by the agency, possibly even including a home kitchen producing cottage foods. The biggest potential problem for local food producers is not going to be the HARPC requirements but rather the CGMP mandate.

HARPC–Who Is Exempt?
HARPC does not apply to any business manufacturing, processing, packing or holding food that is not required to register with FDA as a “food facility.” There are a number of exemptions from the registration requirements; the exemption most applicable to local food producers would be the one for “farms” and “retail food establishments.“5

“Farm” is defined, in part, as “an operation under one management in one general physical location devoted to the growing of crops, the harvesting of crops, the raising of animals (including seafood) or any combination of these activities.6 The term “farm“ also includes “packaging and labeling raw agricultural commodities when these activities do not involve additional manufacturing/processing. Farmers growing/raising and selling raw milk, eggs, raw honey7, whole fruits and vegetables8, meat from amenable species (cattle, hogs, sheep, goats and poultry)9 or any combination of the above foods would qualify as a farm and be exempt from the registration requirement. The farmer/producer selling any processed fruits and vegetables (with one exception)10, any products processed from raw milk, maple syrup11 or any meats from non-amenable species (e.g., rabbit, bison, deer, elk)12 would result in the loss of the “farm“ exemption from registration.

If the farm business doesn’t qualify as a “farm“, it can still be exempt from the registration requirement if it qualifies as a retail food establishment. A business qualifies as a retail food establishment if over half of the “annual monetary value of its sales of food products are direct to consumers.13 This would include sales of all food products sold by the farmer/artisan not just food products that the business produced.

For those not aware of the “farm” or “retail food establishment” exemption who have registered with FDA, it is recommended—if your business qualifies as a farm or retail food establishment—that you contact FDA and request that it cancel your registration. If FDA independently verifies that your business is not required to register, it will cancel your registration.14

Those registering with FDA as a food facility with less than $1 million in annual sales are eligible for a “qualified facility” exemption from the HARPC requirement.15 To obtain the exemption, eligible facilities must submit form FDA 3942a to the agency by December 17, 2018 (those facilities starting up their business after September 17, 2018, must submit the same form before beginning operations).16 According to FDA’s Outreach Info Center, form 3942a will be available September 19; currently, only a draft version of the form is in circulation.

On the form, those seeking the exemption must attest that they are a qualified facility17 (e.g., a “very small business“) and either that they “have identified the potential hazards associated with the food being produced, are implementing preventative controls to address the hazards, and are monitoring the performance of the preventative controls to ensure that such controls are effective“18 or that they are in compliance with state or other applicable non-federal laws and include evidence of regulatory oversight19 (e.g., licenses, permits). Beginning in 2020, those seeking the exemption must submit form 3942a every two years.20 Under certain circumstances, FDA can revoke the qualified facility exemption.21

The CGMP requirements are where FDA will directly regulate local food producers. FDA has been low-key about to whom it will apply the CGMP requirements22, but a read of the regulations indicates that FDA can apply them to local food. Unlike the HARPC requirement, small farms and local artisan producers will have no exemption from the CGMP mandate based on their revenues. Among those exempt from the CGMP are: producers exclusively under USDA jurisdiction (e.g., producing and selling only beef, pork, lamb, goat and poultry products); and farms meeting the “farm” definition discussed above. It appears all, or nearly all, other local food producers will be subject to the CGMPs. According to FDA, the CGMP requirements apply even to businesses operating only in intrastate commerce.23

CGMPs are a one-size-fits-all regulatory scheme–easily subject to varying interpretation by inspectors–that contain requirements for personnel24, plants and grounds25, sanitary operations26, sanitary facilities and controls27, equipment and utensils28, processes and controls29, warehousing and distribution30, holding and distributing distribution of human food by-products for use as animal food31, and the defect action levels32. These are requirements that state legislatures should be determining but FDA wants to regulate as much food and as many food producers as possible. Value-added products are where the money is; FDA wants to have jurisdiction over all of these products, no matter how small the food producer is.

The FDA Bootstrap
As far as is known, Congress never brought up CGMPs when the Food Safety Modernization Act was under consideration but FDA took advantage of the broad power the Act gave it to issue regulations and bootstrapped the CGMP requirements into FSMA. FDA had long contended that FDA could regulate intrastate food commerce under powers granted it by the Public Health Service Act (PHSA) to regulate communicable disease; it wasn’t until FSMA became law that the agency had the traction to do so (the CGMPs had their own Part in the Code of Federal Regulations, 21 CFR 110; FDA used FSMA to insert the CGMPs into Part 117 and 21 CFR 110 will be repealed on September 17, 2018).

The PHSA provides that:

    “The Surgeon General, with the approval of the Secretary [of Health and Human Services] is authorized to make and enforce such regulations as are necessary to prevent the introduction, transmission, or spread of communicable disease from foreign countries into the states or possessions, or from one state or position into any other state or possession. For the purposes of carrying out and enforcing such regulations the Surgeon General may provide for such inspection, fumigation, disinfection, sanitation, pest extermination, distraction of animals or articles found to be so infected or contaminated as to be sources of dangerous infection to human beings, and other measures, as in his judgment may be necessary.”33

That this power authorizes FDA to inspect home kitchens making cottage foods is definitely a reach. There is nothing in the PHSA or in its legislative history indicating FDA has the authority to inspect an intrastate food business when there is no credible evidence that the business is producing food under unsanitary conditions or is responsible for a foodborne illness outbreak. FDA has claimed that “due to the nationwide interrelated structure of the food industry, communicable disease may, without proper intrastate food controls, easily spread interstate.“34 That statement describes the industrial food system, not the local food system. FDA should recognize the difference between the two and leave the latter alone.

In addition to being beyond its power, enforcing the CGMPs against local food is a waste of resources if FSMA is about improving food safety. Instead of spending whatever money FDA intended to budget towards inspections of intrastate food producers, why doesn’t FDA put its resources towards areas of the food sector where there are actually food safety problems, like imported food?

There are built-in incentives for small farmers and local artisans to produce safe food; those producers are feeding the same food to their families, one product recall can put them out of business, one case of foodborne illness can put them out of business. Legislatures in nearly all states have recognized this with the passage of cottage food bills that allow the direct-from-producer-to-consumer sale of a variety of foods with little or no regulation. Four states have passed food freedom bills and other legislation that allow the unregulated sale from producer to consumer of nearly all foods other than meat. There have been few, if any, cases of foodborne illness attributed to producers operating under cottage food or food freedom laws.

Will FDA actually inspect private home kitchens to make sure that the kitchens are in compliance with applicable CGMP requirements? If there were inspections, they would likely be conducted by state agencies pursuant to a cooperative agreement with FDA. So, state legislators who voted on behalf of their constituents who want to deregulate local food transactions between consumers and producers are now being told by FDA that the same state agencies that the legislators didn’t want inspecting local food producers will now be inspecting them; this even though there is little or no evidence that Congress wanted FDA to inspect these same producers for compliance with CGMPs.

FDA might not have the resources to carry out widespread inspections of local food producers, but the threat is that FDA can create a chilling effect on local food production with a small number of inspections of small farms and cottage food operations; convincing some local food producers to get out of business while deterring others from starting up operations.

There are ways to fight against FDA’s attempt to regulate all local food production. For starters, having Congress deny FDA funding to conduct inspections of those in the food business who are not required to register with the agency as a food facility. State legislatures could also require that any FSMA cooperative agreements between state agencies and FDA exclude in the agreement inspections of businesses not required to register as food facilities. Congress could also amend FSMA to clarify that those not required to register as a food facility be exempt from the CGMP requirements. Those processing, manufacturing, packing or holding food for animal consumption not required to register with FDA don’t have to comply with the CGMP mandate35; FDA can apply the same standards to human food.

An immediate move FDA can make is to include additional kinds of manufacturing/processing under the definition of “farm”, enabling farmers to produce more value-added products while still remaining under the “farm” exemption. The agency is currently in the process of amending that definition.36

The more local food producers there are the safer food will be in this country; applying the CGMPs to small farmers and local artisan producers is a big step in the wrong direction.

Those with questions about food facility registration or exemptions from the HARPC and CGMP requirements can email Pete Kennedy at pete@realmilk.com.


[1] The exact definition of “very small business” in 21 CFR 117.3 reads:

    Very small business means, for purposes of this part, a business (including any subsidiaries and affiliates) averaging less than $1,000,000, adjusted for inflation, per year, during the 3-year period preceding the applicable calendar year in sales of human food plus the market value of human food manufactured, processed, packed, or held without sale (e.g., held for a fee). [bolded emphasis added]

[2] The definition of manufacturing/processing is extremely broad; 21 CFR 1.227 and 21 CFR 117.3 state the same definition:

    Manufacturing/processing means making food from one or more ingredients, or synthesizing, preparing, treating, modifying or manipulating food, including food crops or ingredients. Examples of manufacturing/processing activities include: Baking, boiling, bottling, canning, cooking, cooling, cutting, distilling, drying/dehydrating raw agricultural commodities to create a distinct commodity (such as drying/dehydrating grapes to produce raisins), evaporating, eviscerating, extracting juice, formulating, freezing, grinding, homogenizing, irradiating, labeling, milling, mixing, packaging (including modified atmosphere packaging), pasteurizing, peeling, rendering, treating to manipulate ripening, trimming, washing, or waxing. For farms and farm mixed-type facilities, manufacturing/processing does not include activities that are part of harvesting, packing, or holding. [bolded emphasis added]

[3] 21 CFR Part 117
[4] The deadline for compliance with the CGMP and HARPC requirements is September 17, 2018, for those very small businesses that manufacture, process, pack and/or hold animal food. “Very small business”, in the case of animal food, is roughly defined as those businesses with under $2.5 million in annual sales. See 21 CFR 507.3 and 21 CFR 507.5
[5] 21 USC 350d(c)(1), 21 CFR 1.226(b) and (c)
[6] 21 CFR 1.227
[7] FDA, Questions and Answers Regarding Food Facility Registration (Seventh Edition): Guidance for Industry, August 2018, pp. 10-11. Last viewed 8/30/18 at https://www.fda.gov/downloads/Food/GuidanceRegulation/UCM332460.pdf
[8] Farms growing and selling vegetables could be subject to FSMA’s produce safety standards depending on their income levels and whether the vegetables are usually cooked before being consumed. See 21 CFR 112.1-112.5
[9] Meat from amenable species is not considered a raw agricultural commodity but, since it is under USDA’s jurisdiction, a farmer selling meat from amenable species the farmer raised would not cause the loss of “farm” status.
[10] “Drying/dehydrating raw agricultural commodities to create a distinct commodity (such as drying/dehydrating grapes to produce raisins), and packaging and labeling such commodities, without additional manufacturing/processing….” — from definition of “farm”, 21 CFR 1.227
[11] FDA, Questions and Answers Regarding Food Facility Registration (Seventh Edition): Guidance for Industry, August 2018, p. 9. Last viewed 8/30/18 at https://www.fda.gov/downloads/Food/GuidanceRegulation/UCM332460.pdf
[12] Ibid., p. 21
[13] 21 CFR 1.227
[14] 21 CFR 1.241(c)
[15] 21 CFR 117.3 contains definitions and 21 CFR 117.5 gives greater detail about exemptions.

    Qualified facility means (when including the sales by any subsidiary; affiliate; or subsidiaries or affiliates, collectively, of any entity of which the facility is a subsidiary or affiliate) a facility that is a very small business as defined in this part, or a facility to which both of the following apply:

      (1) During the 3-year period preceding the applicable calendar year, the average annual monetary value of the food manufactured, processed, packed or held at such facility that is sold directly to qualified end-users (as defined in this part) during such period exceeded the average annual monetary value of the food sold by such facility to all other purchasers; and
      (2) The average annual monetary value of all food sold during the 3-year period preceding the applicable calendar year was less than $500,000, adjusted for inflation. Qualified facility exemption means an exemption applicable to a qualified facility under § 117.5(a).

    [21 CFR 117.3, bolded emphasis added]

[16] 21 CFR 117.201(c)(2)(i)(A)(b)
[17] Applicants for the exemption must have financial records from 2016-2018 to show that they are a “very small business” as defined in 21 CFR 117.3
[18] 21 CFR 117.201(a)(2)(i)
[19] 21 CFR 117.201(a)(2)(ii)
[20] 21 CFR 117.201(c)(2)(i)(C)(ii)
[21] 21 CFR 117.251
[22] FDA states on its website, “It is important to note that applicability of the CGMPs is not dependent on whether a facility is required to register.” See “FSMA Final Rule for Preventive Controls for Human Food” webpage. Last viewed 8/30/18 at https://www.fda.gov/food/guidanceregulation/fsma/ucm334115.htm
[23] 78 FR 3646, 3651
[24] 21 CFR 117.10 – employee cleanliness and disease control
[25] 21 CFR 117.20 – plant construction, condition of the grounds
[26] 21 CFR 117.35 – general maintenance, cleaning food and non-food contact surfaces, storage of equipment and utensils
[27] 21 CFR 117.37 – water supply, plumbing, sewage disposal, toilet facilities, handwashing facilities, garbage disposal
[28] 21 CFR 117.40 – equipment design requirements
[29] 21 CFR 117.80 – operational requirements for food manufacturing, and food and ingredient storage
[30] 21 CFR 117.93 – sanitary requirements for storage and transportation of food
[31] 21 CFR 117.95 – includes requirements on containers, equipment, and labeling food by-products
[32] 21 CFR 117.110 – Defect action levels. Per 21 CFR 117.3, Defect action level means a level of a non-hazardous, naturally occurring, unavoidable defect at which FDA may regard a food product ‘adulterated’ and subject to enforcement action under section 402(a)(3) of the Federal Food, Drug, and Cosmetic Act.” [bolded emphasis added]
[33] 42 USC 264(a)
[34] 78 FR 3646, 3651 citing 44 FR 23238 at 33239
[35] 21 CFR 507.5(a)
[36] Letter from FDA Commissioner Gottlieb, July 31, 2018. Last viewed 8/30/18 at

Photo source at top of article: Sandrine Perez. Photo source at bottom: FSMA webpage on FDA website

The Planned Destruction of the American Dairy Farmer

A public hearing was held at the Fire Hall in Lairdsville, Pennsylvania, on July 24 to voice concern over the current financial crisis facing dairy farm families throughout America–aptly termed, the economic “Dairy Depression”. Organized by Farm Women United (FWU), the event called for similar hearings to be held across the countryside to gather testimonies that “Congress itself should be gathering but refuses to do so in what is the most outrageous and blatant example of dereliction of duty by federal legislators in modern American agricultural history that is patently undermining the Constitutional rights of American family dairy farmers.” The plea is for Congress and the current Administration to intervene with a “$20 Emergency Floor Price” for milk and mandatory federal hearings to investigate and resolve the crisis.

Gerald Carlin has authorized his written testimony to be published on RealMilk.com (reproduced here by permission with minor formatting and punctuation edits). In his closing, Gerald addresses the many politicians who have failed to respond to the dairy crisis, to whom he says, “Your silence and excuses are deafening and damning.”

Testimony for the Dairy Farm Family Crisis Hearing, Lairdsville, PA

July 18, 2018

I want to thank everyone for taking time out of your busy schedules to attend this important hearing. I also want to thank my wife Tina for all of her hard work in helping to organize this hearing.

My name is Gerald Carlin. My wife Tina and I are former dairy farmers and are now raising beef cattle and vegetables on our century farm in Susquehanna County, PA.

I was asked to speak today on some of the history of events leading to this dreadful state of affairs in the dairy farming business and farming in general. The list of events is too long to cover, but I will mention some of the important ones.

In the period following the Civil War, a number of industries became monopolized including: Railroads by Vanderbilt, Oil by Rockefeller, Steel by Carnegie, and there were efforts by some to take control of agriculture. The Sherman Anti-trust Act of 1890 made monopolizing trade a felony and gave the Attorney General and US Attorneys the responsibility to prosecute those who monopolize, attempt to monopolize, or conspire with others to monopolize trade among the several states. Enforcement of Anti-trust has been lacking at best.

Farm owners are not allowed to unionize but in 1922 Congress passed the Capper-Volstead Act which enabled farmers to form marketing cooperatives to market their products as a group and to bargain for fair prices. The farmer-owned co-ops were granted special protections. As cooperatives have merged and morphed into giant corporations–distant, detached, and unaccountable to their farmer-owner members–these giant co-ops now hide behind their protections granted to them by the Capper-Volstead Act, while they abuse their farmer-owner members with immunity.

In 1937, Congress passed the Agricultural Marketing Agreement Act (AMAA) which established the Federal Milk Marketing Orders (FMMO) that created equal pay for farmers through pooling within the orders to create a uniform price for milk regardless as to how the milk was used. The provision in 7 U.S.C. Section 608 (c) 18 of the 1937 AMAA mandated that the Secretary of Agriculture consider regional production costs in the raw milk pricing formula. FMMOs still exist as a result of the 1937 AMAA but the “cost of production” part has been ignored and scorned for the last 37 years.

In July 1962, the Committee for Economic Development (CED)–made up of some 200 corporate executives, economists and other distinguished experts (not one farmer)–released An Adaptive Program for Agriculture with a stated goal of reducing the farming population by one third within five years. The report complained about wasted resources in farming, particularly labor, as technology increased productivity in agriculture and the large public expenditures for vocational training for young farmers in public schools. They proposed a policy of actively discouraging young people from getting into farming as well as actively trying to coax existing farmers to exit agriculture and even proposed public funds be spent to assist farmers in moving expenses to relocate their families off of the farm.

Kenneth E. Boulding, Ag Economist with the Department of Economics at the University of Michigan and member of the research advisory board for the CED, stated the following:

The only way I know to get toothpaste out of a tube is to squeeze, and the only way to get people out of agriculture is likewise to squeeze agriculture. If the toothpaste is thin, you don’t squeeze very hard, on the other hand, if the toothpaste is thick, you have to put real pressure on it. If you can’t get people out of agriculture easily, you are going to have to do farmers severe injustice in order to solve the problem of allocation.

Although this quote does not appear in the text of An Adaptive Program for Agriculture, the sentiment is still evident. The sentiment expressed by these distinguished experts was that farmers were merely disposable pawns in an economic plan. If the inefficient farmers would just leave farming, the farmers who are left will prosper. Efficient farmers will produce food more cheaply, people will spend less money for food, leaving more disposable income to spend on consumer goods, which will cause economic growth and increase income for all, or so the theory goes. Of course, consumer food prices have continued to rise even as farmers get less and less of the retail dollar. I guess there is a fly in the ointment somewhere.

There were 1.1 million farms with dairy cows in the United States in 1964, 600,000 in 1969, and some 40,000 today; so those who are left are really prospering, right? Oh wait, they are struggling more than ever before. Obviously there are still too many. You get the point.

The official belief that there are too many farmers has grown and become entrenched in public policy evidencing itself in numerous ways, not the least of which are burdensome and senseless regulations on many fronts. Technology, including patented GMO and Terminator seeds, limits farmers’ ability to preserve seeds while increasing the power and control of corporate seed giants. Food additives extend yields of “food” with less raw product. Irradiation and Ultra-pasteurization, along with other questionable practices, ruin the real nutrition of food while extending shelf life. The list could be endless, but the goal is to put food under corporate control, with as few farmers as possible. This, of course, is called “progress”.

The belief that farmers are not important is evidenced in the attitudes and actions of both co-ops and processors as they believe that they are turning worthless raw product into something of value–(Some believe that milk has no value until it is at least pasteurized). Dairy farmers are lucky that the milk truck stops at the farm, takes the hazardous material, and actually pays them for it. No wonder farmers are strapped with paying “make allowances” to insure that the processor can make a profit, and of course, farmers have to pay the hauling charges, advertising fees, and all other appropriate fees, as a co-op or processor sees fit. Countless rural communities that rely on agriculture and provide Ag-related services have been decimated. Social impacts are obvious.

On April 26, 1971, US Secretary of Agriculture Clifford M. Hardin announced the formation of the Young Executives Committee which consisted of 15 members, each of which represented an agency of the Department of Agriculture. They were asked by the Secretary to undertake a review of the farm income question. The following is quoted from their report:

Agriculture should be viewed as an industry which consumes resources, provides employment, and produces goods of value to society. The Committee believes that national agricultural policy should aim at creating an environment which would enable the industry to provide adequate supplies of food and fiber at reasonable prices to meet domestic needs and compete in world markets. The level of farm income earned from the production of agricultural commodities, either per farm or in aggregate, should not be an end in itself. That is, the Department’s objective should not be to assure any particular level of income from farming for the nation’s farmers. Income from farming should be of concern only to the extent that it affects the level of resources attracted to the industry, and, hence, the industry’s ability to produce efficiently, adequate supplies of food and fiber. The industry should not be evaluated on its ability to provide an adequate level of living for all participants regardless of the size of their operation or managerial ability. If adequate supplies of food and fiber are being made available at reasonable prices, we should conclude that the nation has a healthy, viable agricultural industry. . . Agricultural policy should be directed toward maintaining agriculture as a viable industry and not as a way of life . . . Given these conditions, agriculture cannot and should not be expected to provide employment opportunities sufficient to preserve the nation’s rural towns and communities. If these towns and communities are to grow, additional off-farm employment opportunities must be found.

The Committee also called for the elimination of parity pricing.

In April 1973, Agricultural Trade and the Proposed Round of Multilateral Negotiations (aka the Flanigan Report) was published. This document basically sought the elimination of any and all protections and trade barriers for farmers domestically and worldwide. It was their dream and goal that eventually no country on earth would be able to offer any special protections for their farmers. Farmers would be forced to be “efficient” and would no longer be able to be such a pesky, if not powerful, lobbying force in Washington, DC, or any other country in the world. Eventually through a number of trade agreements, negotiated by “esteemed” and unaccountable experts, the farmer has essentially lost all protections and all rights to seek redress of wrongs because international trade agreements supersede farmers’ rights and domestic food policy. Politicians can throw their hands in the air and declare that there is nothing that they can do, or, as most have chosen, just ignore the concerns of farmers, because, after all, there are more important issues to deal with and more important people to talk to.

On April 1, 1981, President Ronald Reagan signed legislation that decoupled farm milk prices from parity and incrementally decreased the support price from $13.60 at that time down to $9.90 and eventually the support price was eliminated in the 2014 Farm Bill.

In 1996, the United States Congress instructed Secretary of Agriculture Dan Glickman to reform the Federal Milk Marketing Orders. In July 1999, USDA put their order reform up for producer referendum. Only Option 1B was offered. Although many did not like 1B, the referendum passed because cooperatives like Dairy Farmers of America (DFA) used the “block voting” option. Several dairy cooperatives sought an injunction against the proposed order reform on the basis that 1B would financially harm milk producers in most of the country. In the St. Albans Cooperative Creamery, Inc., et al., Plaintiffs versus Dan Glickman, Secretary of Agriculture, Defendant case an injunction was granted. U.S. District Judge William Sessions III did not focus on the merits of 1A vs. 1B but rather cited Dan Glickman for failure to consider dairy farmers’ cost of production. Judge Sessions made clear in his “Opinion & Order” that ”. . . this Court looks to the direct language of the statute to determine the sufficiency of the Secretary’s consideration, which makes no mention of indirect consideration being adequate in meeting the requirements of 608c(18). The record shows no direct consideration of regional costs in feed, feed availability, or other region specific economic factors.”

Judge Sessions also stated that “. . . the Court finds the Secretary’s Final Order and Decision violates Congress’ mandate under the 1937 Agricultural Marketing Agreement Act (AMAA) . . . “ and “. . . that Plaintiffs have a likelihood of success in their claim that the Secretary’s Final Order and Decision violates the AMAA by failing adequately to consider economic factors regarding the marketing of milk in the regional orders across the country.” Furthermore, Judge William Sessions found “. . . that the balance of hardship weighs heavily in favor of the Plaintiffs.” Judge William Sessions, III made no fewer than five references to USDA’s failure to act according to the 1937 Agricultural Marketing Agreement Act, section 608c(18). In his “Opinion and Order” statement, one such discussion spans seven pages. In late 1999, Congress instructed USDA to implement Option 1A. This satisfied the Plaintiffs, (were the Plaintiffs following the intent of the Capper-Volstead Act?) and the case was dropped without resolution of the cost of production issue.

In May 2000, USDA held hearings on Class III and IV pricing in which testimony was offered in support of implementing a cost of production factor in these formulas. In December 2000, USDA released the Tentative Decision on Proposed Amendments for Class III and IV pricing. Once again, USDA ignored the mandates of 7 U.S.C. 608 (c) 18 maintaining that the Class III and IV prices “. . . are such prices as will reflect the aforesaid factors. . .” [General Findings (b)]. This is ludicrous in light of the volatility of Class III and IV prices. However, USDA did concede that “if a sound mechanical concept could be advanced that overcomes the objections relative to supply and demand, it should be considered.”

United States Department of Agriculture issued an invitation for proposals on changing Class III and IV pricing in the summer of 2006. Approximately 40+ proposals for cost of production were submitted. National Family Farm Coalition submitted a somewhat detailed proposal to base Class III and IV pricing on a national average cost of production. In the pre-hearing, February 2006, USDA officials insisted that they do look at 608c (18) regularly and implied that they are following it. USDA turned down NFFC’s proposal. As a result, several members of the Dairy Sub-committee, particularly Arden Tewksbury and Gerald Carlin of Pro Ag, drafted legislation using the NFFC proposal as its basis. Senator Arlen Specter’s office put the draft into bill form, and it was introduced in the Senate on June 27, 2007, by Senator Arlen Specter and Senator Robert Casey, Jr. The bill is known as the Federal Milk Marketing Improvement Act of 2007 or S1722. Senator Casey, who is on the Senate Agriculture Committee, was unable to get support for S1722 to become part of the Farm Bill. The Bill was reintroduced in 2009 as S889 and then after a few changes introduced again as S1645. The Bill was introduced again in 2011 as S1640.

Forward Contracting appeared in the 2002 Farm Bill as a pilot program which was to expire on December 31, 2004. The industry and lenders continue to pressure farmers to forward contract in an effort to undermine Federal Orders and secure milk at lower prices.

In late 2004, a massive investigation of DFA and Dean Foods was launched by the United State Department of Justice in conjunction with over 20 state Attorneys General. The investigation focused mostly on abusive, anti-competitive market practices in the Southeast, where farmers were paid less than minimum FMMO prices. Small co-ops were coerced, gobbled up, or controlled by DFA and farmer members were sucked into DFA and its affiliates against their will. Some 200 file boxes of evidence were reportedly collected along with scores of sworn affidavits. The investigation ground to a halt in the fall of 2006. It may have been completed by that time but no action was taken by the Department of Justice in spite of numerous calls to do so from politicians and others.

Another investigation of dairy co-op Anti-trust issues was started during the Obama administration then promptly terminated.

The 2014 Farm Bill eliminated the MILC program and Dairy Price Supports and replaced them with the failed MPP Program and the meaningless Dairy Product Donation Program.

On January 8, 2018, the Report to the President of the United States from the Task Force on Agriculture and Rural Prosperity was released, with five main objectives related to agriculture: (1) increase e-connectivity, (2) improve H-2A visa program to facilitate more H-2A work visas, (3) expand biotechnology and public acceptance of genetically modified products, (4) increase ag exports, (5) increase access to capital. No mention of farm price or consumer choice in the report.

The 2018 Farm Bill continues the globalist agenda with apparently no intention of correcting low farm product prices and bad farm policy.

On the trade front, President Nixon pushed for expanded trade with China. Ag trade surpluses were to offset trade deficits in manufactured products. This never happened.

On January 1, 1994, NAFTA went into effect. US investment went south for cheaper wages and Mexican wages actually decreased as our trade with Mexico went into deficit.

In a 1994 lame duck session of Congress, the massive General Agreement on Tariffs and Trade (GATT) passed, putting more control of our economy in the hands of unelected and unaccountable people.

In 2000, the US Congress approved Permanent Normal Trade Relations (PNTR) with China, and as many predicted, our trade deficit with China exploded as companies invested in China for even cheaper labor. China has become a growing threat to our nation’s security even as we have lost our ability to produce basic necessities for our own people.

In dairy trade the United States imported far more dairy products than we exported from the late 1990s to early 2000s. The USDA has become much less transparent on dairy imports as they tout increased dairy exports. Even so, we are still importing a large amount of dairy products. The “oversupply” in dairy has been created in large part by the use of Milk Protein Concentrate (MPC), Milk Protein Isolate (MPI), and Ultra-filtered Milk (UF). I will talk more about MPC later.

So where does this leave dairy farmers? Dairy farmers have lost their equity, lost their retirement, lost their ability to pay their suppliers in a timely manner, lost their dignity, feel misunderstood, marginalized, and scorned. They have lost their next generation of dairy farmers, lost their hope, in some cases lost their marriages, and some have lost their lives. They have been scoffed at by their cooperatives and experts. They have been ignored by politicians. The list of politicians ignoring farmers is long, but to save time I will just say that not one of the 66 member of the House and Senate Ag Committees had the decency to respond to a thoughtful survey sent to them by Farm Women United (FWU). Also, Governor Wolf and Governor Cuomo have not had the decency to respond to letters sent to them by FWU. Agri-Mark was also sent letters, but they too have failed to respond. It doesn’t matter what a politician may say in private. If they do not openly and publicly declare their support for Dairy Farm Families and offer constructive solutions to this crisis, there is no other choice but to conclude that they simply do not care. If they cared, they would speak out. Further, if dairy cooperatives cared, they too would take constructive steps to solve this crisis. Your silence and excuses are deafening and damning.

We urge support for a $20 Emergency Floor Price and hearings to determine a path forward to create a sustainable future for the dairy farms that remain. Failure to act will result in the near total destruction of traditional family dairy farms as we have known them and the continued decline in access to locally produced wholesome food.

Thank you for your time and patience
Gerald Carlin, Meshoppen, PA
2 Attachments – see posted below

How Much Milk is MPC/Ultra-filtered Milk Displacing

by Gerald Carlin – July 22, 2018

No one really knows how much milk MPC/Ultra-filtered Milk is displacing since the Federal Milk Marketing Orders (FMMO) do not collect data on MPC/Ultra-filtered Milk production and use. This is considered proprietary information. MPC and Ultra-filtered Milk are now being used in all four classes of milk products.

MPC and Ultra-filtered Milk are not approved ingredients in standardized cheeses, but the Food and Drug Administration (FDA) has “exercised discretionary enforcement” in this area, as reiterated on August 11, 2017. FDA went further and stated, “. . . we do not intend to take action against companies that manufacture standardized cheeses and related cheese products that contain fluid Ultra-filtered Milk or fluid Ultra-filtered Non-fat Milk without declaring them in the ingredient statement, as long as their labels declare milk or non-fat milk in the ingredient statement.”

We can, however, look at cheese production compared to Class III utilization in the FMMOs and California Class 4b (cheese) utilization to gain some insight. The traditional yield factor for cheese is 10.01 lbs. per 100 lbs. of fluid milk containing 3.5% butterfat and 2.99% true protein. Higher average components may yield 11 lbs. of cheese per 100 lbs. of milk. National cheese production last year (2017) for cheese falling under Class III or California Class 4b was approximately 12.4 billion lbs. Class III utilization (weighted average) in all Federal Orders was 41%. If this rate of utilization is true nationally, the average cheese production would be 14.1 lbs. per 100 lbs. of milk. The Class 4b utilization in California for 2017 was 46.2%, making an average cheese yield of 13.66 lbs. per 100 lbs. of milk. Given this information, it seems unlikely that the national average cheese yield is less than 13.5 lbs. per 100 lbs. of milk. This translates into at least 20 billion pounds of farm milk being displaced by the use of MPC/Ultra-filtered Milk in cheese. Low-fat and Non-fat dairy products are being promoted. The fat that traditionally would go into these products is used with MPC/Ultra-filtered milk to produce substandard cheese. Much of this use violates cheese standards. How much milk is being displaced in other dairy products because of MPC/Ultra-filtered Milk? Prices are in the gutter because of a supposed 4 or 5 billion pound surplus.

How much effect does farm milk price have on retail price?

US City Retail Price
Natural Cheese August 2014 — $5.56#
Natural Cheese June 2018 — $5.23#

Ice Cream August 2014 — $4.75 ½ gal.
Ice Cream June 2018 — $4.66 ½ gal.

Whole Milk August 2014 — $3.67 gallon
Whole Milk June 2018 — $2.88 gallon

US Average FMMO Mailbox Milk Price
May 2014 — $24.37
March 2018 — $15.04

California Dairy Statistics Annual 2017
Market Summary and Utilization Report Agricultural Marketing Service
Dairy Products 2017 Summary USDA NASS
Milk cows and production by state and region NASS and ERS
Dairy Market News

The four classes of milk products are: (1) fluid milk, (2) soft dairy products like yogurt and cream, (3) cheeses, and (4) butter and dry milk products like nonfat dry milk.

Thoughts Concerning Free Market in Dairy

By Gerald Carlin – May 6, 2018

In a functional free market system for dairy, dairy farmers form cooperatives to give them both bargaining power and marketing ability. The co-op would be owned by, and controlled by, its farmer-members.

Today, National Milk Producers Federation (NMPF) is the only voice for dairy farmers in Washington, as it claims to represent some 75% of the nation’s dairy farmers. NMPF is made up of “farmer-owned” co-ops and processors who are associate members.

Let’s examine the current “benefits” of being a farmer-owner of a large modern-day co-op. The farmer-owner, hereafter referred to as owner, pays the dairy cooperative management, hereafter referred to as employees, to market the owner’s milk. The employees are not required to pay the owner the Federal minimum milk prices.

  • The owner has no right to know what the employee’s salary is.
  • The owner has no right to know where his milk is going on any given day.
  • The owner has no right to know who all of the other co-owners are.
  • The owner can lose his market if he is critical of, or even questions his employees, therefore, most owners remain silent in fear of retaliation. Employees make examples out of owners who get out of line.
  • The employees vote in Federal Order referendums without the consent of the owner.
  • The employees have been seen at Federal Order hearings trying to get more money out of the owner without the owner’s knowledge.
  • The owner has no ability to call a meeting of fellow owners.
  • The owner has no practical ability to fire an employee.
  • The employees try to dictate how the owner runs his business.
  • The employees have plenty of lobbyists at all levels of government to ensure that their control over the owners continue.

This is the unseen and untold story of “farmer-owned” co-ops.

Farm Women United Mission Statement
Farm Women United seeks to maintain a serious, honest, and open dialogue, giving a voice to farmers who are the real stewards of the earth and the foundation of any free and civilized society. Farmers produce food that sustains life. We are a culture of life. Farm Women United seeks to restore cultural respect for farmers which will result in a just and equitable value being placed on the life sustaining food which we produce and allow farmers to continue to produce food with dignity.

Visit www.farmwomenunited.org

A Tale of Two Food Systems

The International Association of Food Protection (IAFP) held its annual meeting July 8-11 at the Salt Palace Convention Center in Salt Lake City, Utah. The event is the world’s largest food safety conference. The IAFP meeting is where food safety professionals meet to discuss pathogens in food and ways to prevent and respond to the problems those pathogens cause. The meeting is an incubator for the one-size-fits-all food safety laws that make it more difficult for small farmers and artisan food producers to make a living. Most of the crowd at the meeting does not distinguish between the industrial food system and the local food system; the regulations the conference sets in motion are geared for industrial food production and distribution and should apply to all food production and distribution in the eyes of the majority of attendees.

Food safety is a growth industry. Globalization and deteriorating quality in the industrial food system are drivers. Over 3,500 attended this year’s meeting; FDA and USDA both sent dozens of personnel to Salt Lake City. State regulatory agencies, academia (students and faculty) and big business were all well represented at this year’s meeting. Cargill, Merck Animal Health, Smithfield, Kroger, the Grocery Manufacturers Association and Walmart were all sponsors of the event.

Food safety is about the prevention of or response to cases of acute illness; there was little mention at the meeting about nutritious or nutrient-dense food and its role in the prevention of chronic disease.

A point those at the meeting frequently discussed was the complexity of long supply chains starting with the manufacturers of ingredients used by the food producer and continuing through various phases of distribution leading to the purchase of the food by the final consumer. The talk was about difficulties in traceability and ensuring safe food along the supply chain. An antidote to this problem would be to facilitate the local production and distribution of food with its short, direct supply chain, and high level of traceability but that was a solution that was seldom, if at all, brought up at the meeting.

Presentations at the meeting included talks on recent outbreaks, developments in testing for pathogens, and various food safety processes such as HACCP. At the same time the presentations are taking place, there is a trade show where vendors showcase, among other things, the latest products for testing and sanitation measures. Also present in the same location as the trade show are posters (written summaries) of studies related to food safety that are displayed for viewing by meeting attendees. Individuals who worked on the studies are present to answer questions.

Some takeaways from the meeting:

  • The FDA’s longtime plan to extend the aging requirement for raw cheese from 60 days to 90 days is alive and well. Part of the evidence for the latest push on this 90-day requirement is an FDA study on how raw gouda cheese inoculated with listeria still contained listeria after 90 days. The FDA scientists who spoke on the study at the meeting acknowledged that the raw milk used in the experiment was intended for pasteurization not direct consumption–a continuation of the agency’s refusal to recognize that raw milk for the pasteurizer and raw milk for the consumer are two different products. Two food safety professionals contacted at the meetings said privately that listeria was a bigger health threat in pasteurized cheese than it was in raw cheese. Regardless, those at the meeting overwhelmingly favor the “kill step” of pasteurization for all dairy products and for other foods.
  • A high-ranking USDA official disclosed that the Office of Investigation, Enforcement and Audit (OIEA), a division of USDA’s Food Safety Inspection Service (FSIS), has undertaken an initiative to increase inspections of small and very small plants (e.g., slaughterhouses and processing facilities); there is evidence that this initiative includes inspecting small food buyers clubs selling meat to their members. The question is why? As of 2016 there were only 150 OIEA inspectors in the whole country. Few, if any, food safety problems have been attributed to small plants and very small plants much less to small private food buyers clubs. Wouldn’t it be a more productive use of resources to have the OIEA personnel increase oversight for imported meat and large USDA facilities slaughtering 300-400 cattle an hour–where there are many more food safety problems?
  • A high-ranking FDA official spoke about the proposed merger of food regulation between USDA and FDA with the former taking over all food regulation The official said it could be a long process but did not dismiss the merger. The merger would likely be an improvement over the current situation; FDA policies on positive bacteria test results are more strict than either the USDA or European Union countries and lead to more cases of quality, safe food winding up in a landfill.
  • One of the featured speakers at the meeting supported the universal adoption of the FDA Food Code, a burdensome regulatory scheme whose cost of compliance is difficult to afford for many small farmers and local artisans producing nutrient-dense food. The late Sue Wallis, the legislator who initially introduced the Wyoming Food Freedom Act, indicated that the main reason she introduced the legislation was to get local food producers selling direct-to-consumers as far away from the requirements of the Food Code as possible. Since 2015 four states–Wyoming, North Dakota, Utah and Maine–have passed food freedom legislation allowing for the unregulated sale of food direct to consumers. As far as is known not a single foodborne illness outbreak has been attributed to a producer operating under these laws in any of the four states.
  • Bill Marler, regarded by many as the leading foodborne illness personal injury lawyer in the country, acknowledged that in his 25 years of experience he could not recall having a single client sickened by food purchased at a farmers market.
  • There was lots of discussion at the meeting about the recent outbreak attributed to the consumption of romaine lettuce where 5 people died and over 200 others became ill. It turns out that the plant which processed the lettuce was subject to the requirements of the Food Safety Modernization Act (FSMA). Excessive regulation from FSMA doesn’t necessarily mean greater food safety but can mean a decline in food safety with small and midsize producers going out of business due to being unable to afford the cost of compliance.
  • Out of 50 states, 46 have signed cooperative agreements with FDA, receiving federal grant money in return for carrying out inspections to enforce FSMA’s federal produce safety. An attendee at the conference from a state public health department related how her department ran out of the federal money in carrying out a cooperative agreement with FDA and had to tap into a state general fund to get more money to finish carrying out the agreement. This is not uncommon. State agencies signing cooperative agreements with FDA should have a clause in the agreement that they do not have to carry out any further duties under it if the federal money runs out.
  • Most of the presentations and posters at the meeting had to do with industrial food but there were at least a couple exceptions that were favorable to local food. A USDA scientist did a presentation on pastured poultry reporting among other things that poultry fed a soy-free diet had substantially less campylobacter in their systems. There was a poster on the quality of raw milk for retail sale in Maine reporting on the low incidence of illness attributed to raw milk consumption in that state.
  • The atmosphere at the meeting was friendly, a good one for engaging attendees on why locally-produced food should not be regulated the same as industrial food. Most of those attending are trained that there is only one food system. One individual who worked on a poster supporting more regulation of cottage food producers was asked if she was aware of any cases of foodborne illness attributed to the consumption of cottage foods. She said no but then added that it was because cottage foods weren’t traceable. In general there are hardly any foods that are more traceable than cottage foods.

Most cases of foodborne illness are caused by industrial food; this is true even when factoring in the market share industrial food has compared to local food. Unregulated local food producers have plenty of incentive to produce safe food: their families consume the same food they are selling, one recall can put them out of business, and one case of foodborne illness can put them out of business. Food safety regulators like dealing with short supply chains and a high degree of traceability; local food producers–regulated or not–satisfy both of these parameters

When you also factor in the amount of chronic illness the local food and industrial food systems are responsible for, there is no question the local food system is responsible for fewer cases of chronic illness even when the market share of the two systems is accounted for. Take a survey on the demand those who obtain a majority of their food from the local system make for services on the medical system versus those who obtain a majority of their food from the industrial system. Policymakers should take both acute and chronic illness into consideration when crafting food regulations and legislation. The more local food producers there are the less demand there will be on the medical system for services; food freedom laws lead to more local producers.

The IAFP meeting is a place where ideas for food safety legislation are first introduced. It can also be the place where the effort begins to convince regulators that there are two food systems and that one-size-fits-all food safety regulation doesn’t work.

Food safety professionals have done a great job improving safety in areas of the industrial food system; often when dealing with multiple producers/distributors and multiple countries in an investigation–thankless work. Laws and policies contributing to an increase in local food production would make their jobs easier.

The Cost of Corporate Protection in Minnesota

Minnesota is a major power center for Big Food in the U.S.–corporate giants Cargill, General Mills, Hormel and Land O’ Lakes all have their headquarters in the state. If agribusiness had its way, there would be zero competition for the industrial food system from local food; as it is, Big Food’s allies in the state government bureaucracy enforce regulations that are more about preserving the industrial food system’s market share than protecting the public health. A great example of this would be the investigation of dairy farmer David Berglund by the Minnesota Department of Agriculture (MDA).

MDA began investigating Berglund five years ago and, as far as is known, is still continuing its investigation of the farmer. To date, it is estimated that MDA has spent a staggering 1.5 million dollars ($1,500,000) investigating Berglund, someone who has never had anyone file a complaint against him over the food he produces.

Berglund produces raw milk, raw butter, raw yogurt and other nutrient-dense foods at his farm in Grand Marais, up near the Canadian border, and only sells those products at his on-farm store. Dairy farming is more of a calling than a business for Berglund, he keeps the price for raw milk at five dollars ($5) per gallon to ensure that those with limited finances can still get the product.

Berglund and MDA became embroiled in a dispute over whether the department had jurisdiction to inspect his farm. There is a provision in the Minnesota Constitution that states, “Any person may sell or peddle the products of the farm or garden occupied and cultivated by him without obtaining a license therefor.” MDA’s contention was that this provision only exempted Berglund from licensing requirements, not from other mandates (e.g., inspection) in the state food and dairy code. From 2015-2017 Berglund and MDA were in a court battle over the department’s power to inspect Lake View Natural Dairy with the courts ultimately siding with MDA.

Since that time, MDA has inspected the Berglund farm and, as far as is known, has found no violations in the farm operations. No matter–MDA will spend whatever it takes to make an example of Berglund, trying to create a chilling effect to discourage other farmers from standing up to the department over their constitutional right to sell and peddle the products of the farm.

Aside from Berglund’s claim that MDA has no jurisdiction to inspect his farm, the other issue of contention between the farmer and MDA is what products of the farm Berglund can legally sell. MDA’s position is that since Minnesota statute only allows the sale of raw milk and cream then sales of foods like raw butter and raw yogurt are illegal. The statutory ban on raw butter is an example of a law that is not about protecting the public health but rather about economic protectionism–specifically, the profits of the dairy processing industry.

The foodborne illness database of the Centers for Disease Control (CDC) goes back twenty years; during that time, there has not been a single outbreak attributed to the consumption of commercially produced raw butter.

What is needed in Minnesota is for the state Supreme Court to revisit its 2005 ruling in Hartmann v. Minnesota. In that case the court ruled that the constitutional provision on selling and peddling the products of the farm only exempts farmers from licensing, not from other regulatory requirements such as inspection and that farmers could only sell foods whose sale was allowed by statute. The Hartmann ruling ignored the historical context of the constitutional amendment which passed in 1906. At the time the amendment passed, the state did not inspect or otherwise regulate farms; the licensing requirements the amendment prohibited were intended to raise revenue, not to regulate farms. In 1906 all raw dairy products were legal products of the farm; what the Hartmann court did in holding a food like raw butter was illegal to sell was to say that a statute controlled over the constitution–an interpretation of the law that had it backwards.

One farmer looking to have the Minnesota Supreme Court take a second look at the Hartmann decision is Mike Hartmann himself. If MDA has spent $1.5 million investigating Berglund, it has spent at least several times that on the Hartmann case. Since 2000 MDA has at various times raided Hartmann’s farm, his vehicle, his dropsites, harassed his customers, seized food and equipment, brought a court action to destroy Hartmann’s food and had criminal charges brought against him. On two different occasions a court has ruled that MDA seized property and equipment from Hartmann through an illegal search and seizure.

Hartmann is currently suing MDA and individual MDA officials for, among other remedies, return of seized equipment, damages for seized food, damages for violations of Hartmann’s state and federal constitutional rights, and a court order enjoining “the state from interfering with the private transaction between Hartmann and his consumers for the sale and exchange of products of the farm.” The amount of money the state of Minnesota has spent on the Hartmann case will continue to increase.

The corollary of the state constitutional right to sell and peddle the products of the farm is the right of consumers to obtain those products. MDA and the Minnesota Department of Health (MDH) recently spent taxpayer money interfering with that right when they raided the private food buyers club, the Uptown Locavore, on May 3 embargoing thousands of dollars of nutritious food produced by local farmers; MDH still has not made a decision on how it will dispose of the embargoed food. State law requires that a government agency either petition a court to destroy the embargoed food or release the food; unfortunately, the law does not impose a time limit on an agency to make this decision. The lack of a statutory deadline enables the bureaucracy to, in effect, condemn food without a court order, waiting until a food’s “shelf life” has expired before making its decision. Raw milk embargoed by MDH at the Locavore went bad a long time ago.

Raid in Minnesota – Food Police Protecting People from Themselves, Again

MDA’s enforcement actions against the distribution of locally produced nutrient-dense food when there have been no complaints amounts to a form of corporate welfare for agribusiness. Unless there is a legitimate accusation about the distribution of adulterated food, MDA would do better to save the taxpayers money and honor food freedom of choice.

Joel Salatin: Whole Milk Illegal in Schools — Say What?

Posted here by permission from Joel Salatin. Originally published at TheLunaticFarmer.com on June 13, 2018.

After writing about the dairy debacle a few days ago (half of dairy farmers will go out of business if current trends–price and consumption–continue) a reader named Pegi sent me a wonderful email. Here it is:

    One of the factors leading to reduced milk consumption is the USDA. They make the rules for the school lunch program. Children are given skim or 1% milk, which is frequently handled poorly, and told “This is milk. It is good for you. Drink it.” Who on earth would want to drink that crap? Then they add chocolate and sugar to it and complain of its being fattening.

    WIC only allows 1% milk. And the USDA insists that this is healthy!

    I can understand pasteurizing milk that is sold in schools, but at least whole milk would be palatable!

    HR 5640 would allow the sale of unflavored milk in school lunch. Please urge people to support it.

So I checked into HR 5640. It has been introduced by Rep. Tom Marino (R-PA) and is titled The Whole Milk Act. Currently it’s in the House Committee on Education and the Workforce. Right now the Richard B. Russell National School Lunch Act prescribes “unflavored fluid milk” as a legal substance for schools that participate in the school lunch program. Due to Dietary Guidelines interpretations, that can only be 1 percent milk (skim milk).

Marino’s amendment would change the wording in the school lunch program to allow “unflavored whole milk.” By changing the word “fluid” to “whole” it would allow the kidos to drink full fat, brain-feeding, nutrient-dense whole milk.

Thank you, Pegi, for pointing out something I did not know–that it is ILLEGAL for our school lunch program to offer whole milk. How absurd is that? In Europe, they drink RAW (unpasteurized) WHOLE milk. That’s why they’re all dying over there and why everyone is fat. Good grief, Charlie Brown.

Which leads me to say, the best thing you can do for your little one, if he/she is in a school lunch program school, is to send them with their own lunch, including raw whole milk. These issues have two response points. One is to urge passage of this bill. The second is to make the whole thing irrelevant by sending integrity food to school with your little one. Let’s do both.

What do you send in your child’s lunch box?

Popular Tennessee Herd Share Dairy Shuts Down

On June 14 the Knox County Health Department (KCHD) lifted a directive it had given Knoxville dairy French Broad Farm nine days earlier to stop distributing raw milk to its shareholders. In Tennessee the distribution of raw milk through herd share agreements is legal by statute. The department had issued the directive because it suspected the dairy was responsible for seven cases (all children) of illnesses caused by the pathogen E. coli O157:H7. The dairy had complied with KCHD’s request and had stopped distributing raw milk on June 5.

The ordeal of the investigation has led the owners of French Broad Farm, Earl and Cheri Cruze, to shut down their herd share operation, a huge loss for the local food community in the Knoxville area. Earl Cruze, 75 years young, has milked cows for 68 years and has always been the only milker for the herd share. Raw milk drinkers in the metro Knoxville area are now out a source of their sustenance.

The department decided to lift the directive, in part, because according to County Health Director Martha Buchanan, “there is no ongoing transmission” of E. coli; the last illness KCHD connected to the dairy occurred on June 3. Buchanan indicated that the department believed that French Broad Farm was the source of the E. coli O157:H7 bacteria that sickened seven children that drank raw milk the farm produced. Interestingly, at the same time the department was investigating the dairy, it had also determined that at least four children had become ill through E. coli O157:H7 poisoning at a daycare center through direct or indirect contact with farm animals. KCHD’s investigation found no connection between the dairy and the daycare center.

What Buchanan or anyone else with KCHD never did explain was why there were no test results from milk and manure samples the department had collected from the farm over a week earlier. KCHD had gone to the farm to take milk samples on June 5 and manure samples on June 6. In addition, the department also collected an unopened container and opened container of raw milk that were produced on the suspect batch dates of May 24 and May 25.

KCHD originally sent the samples to a Tennessee lab but then on June 11 had them transferred to a more sophisticated laboratory in Iowa.

It only takes lab technicians 48 hours to make a preliminary determination on whether a sample is positive for E. coli O157:H7. Typically, if a sample is positive, a health department or other agency will issue a press release announcing the positive test and will continue with its order prohibiting the producer from distributing the suspect food. The likelihood was that all tests the Tennessee and Iowa labs took of the milk and manure samples were negative for E. coli O157:H7; it’s possible that the department didn’t announce any test results because the Iowa lab was still running tests to find e. coli.

Campylobacter, the pathogen most commonly responsible for outbreaks of foodborne illness attributed to raw milk is rarely found in samples tested in a lab; campylobacter grows and disappears quickly. E.coli, including E. coli O157:H7, is different; e. coli will often continue to grow after a sample is taken to a lab for testing. As a result it would be more likely to have a positive test result for e-coli than campylobacter. While all negative test results wouldn’t necessarily clear French Broad Farm of blame for the illnesses, they are evidence that the dairy is not responsible for the E. coli O157:H7 outbreak. The more negative tests the Tennessee and Iowa labs have the greater the evidence the dairy is not responsible for the illnesses. Buchanan did say the department looked for other commonalities among the sick children such as ground beef consumption and swimming pool usage but there are possibly other common activities among the seven children KCHD is unaware of.

Something to look at would be the multi-state foodborne illness outbreak this spring attributed to romaine lettuce contaminated with E. coli O157:H7. There have been five deaths and nearly 200 illnesses in the U.S. blamed on romaine lettuce consumption, including at least three illnesses in Tennessee. From May 16 to June 1, the Centers for Disease Control (CDC) identified an additional 25 cases of illness it blamed on romaine lettuce. Reports are that there is a high level of secondary transmissions from the outbreak.

Earl Cruze ran a Grade A operation, Cruze Farm Dairy, for over thirty years. Cruze Farm Dairy is a completely separate operation from French Broad Farm and is now run by Cruze’s daughter Colleen Cruze Bhatti and son-in-law Manjit Bhatti.

The Tennessee herd share law went into effect in 2009. Since that time, herd share programs have thrived in the state; hundreds of dairies have operated herd shares at one time or another in Tennessee. The French Broad Farm investigation marks the second time herd share operations have been blamed for a foodborne illness outbreak in the state.

It’s Time To Put Our Federal Meat Inspection Law Out To Pasture

Outdated regulations are hampering the beef meat industry.

Written by Baylen Linniken. Originally published May 19, 2018, by Reason.com online magazine. Baylen Linnekin is a food lawyer, scholar, and adjunct law professor. He’s the author of Biting the Hands that Feed Us: How Fewer, Smarter Laws Would Make Our Food System More Sustainable (Island Press 2016). Linnekin serves on the board of directors of the Farm-to-Consumer Legal Defense Fund.

Last week, Sens. Mike Rounds (R-N.D.), John Thune (R-S.D.), and Angus King (I-Maine) introduced a bill that would allow meat processed in many state-inspected slaughterhouses and other state-inspected facilities to be sold across state lines.

The sensible bill, dubbed the New Markets for State-Inspected Meat and Poultry Act, could be a real boon to livestock farmers who want to sell their meat and meat products in neighboring states, and to the consumers who want their products.

Before you get your hopes up, though, consider that this under-the-radar, bipartisan bill has been around in some form or other for more than fifteen years. Then-Sen. Tom Daschle (D-SD) introduced similar legislation in 2000. Then-U.S. Representative (now Senator) Roy Blunt (R-Mo.) sponsored a version of the bill in 2006. A year later, then-Rep. Earl Pomeroy (D-ND) introduced the bill.

Yet the ban on interstate sales persists. That’s despite the fact it’s got broad support.

“The New Markets for State-Inspected Meat and Poultry Act of 2018 will strengthen local economies by allowing meat and poultry products inspected under State meat inspection programs to be sold across state lines,” said Kenny Graner, president of the United States Cattlemen’s Association, earlier this month. “This opens access to new markets that were previously unavailable due to outdated federal regulations.”

The South Dakota Stockgrowers Association also supports the bill. State agriculture departments have long been on board. The U.S. Department of Agriculture is, too. A 2001 study by the University of Nebraska Public Policy Center, which attempted to identify differences between states that operate their own inspection regimes and those states that do not, noted the USDA “officially endorses legislation to permit interstate commerce for state-inspected meat.”

So just what is the holdup? The status quo appears to be largely the result of a powerful, lousy law colliding with lazy lawmakers in Washington.

Since the late 1960s, as I’ve lamented several times here and in my recent book, Biting the Hands that Feed Us: How Fewer, Smarter Laws Would Make Our Food System More Sustainable, the USDA has required any animals and their meat that will be sold commercially to be slaughtered and processed in USDA-inspected facilities or in state facilities that are “at least equal to” the USDA facilities (a requirement known, artfully, as the “‘equal to’ requirement”).

That requirement is part of the Wholesome Meat Act of 1967, which applies both to interstate and intrastate sales. Practically, it means that if a local farmer wants to sell you (or a local restaurant) a pound of ground beef, he or she must have the beef processed in a facility that complies with the federal law.

The law, as it applies to wholly intrastate sales—as in the burger example—is unconstitutional. As I’ve noted before, by passing the Wholesome Meat Act, Congress delegated to the USDA a power Congress itself does not possess: to regulate wholly intrastate commerce.

On the other hand, as I noted in an op-ed in The Hill last week, Congress clearly has the power under the U.S. Constitution to regulate interstate commerce. But the fact a law is constitutional doesn’t make it smart policy. For example, under the Wholesome Meat Act, a steak from a cow that was inspected in a state facility (operated in more than half of U.S. states) that follows regulations at least as stringent as those required under federal law in, say, South Dakota, can be sold anywhere in the state but can’t be sold just across the border in Minnesota.

A program created under the 2008 Farm Bill, known as Cooperative Interstate Shipment (CIS) Program, was supposed to alleviate the problem. But CIS has been unpopular for a variety of reasons.

First, it took years to implement. And once it was implemented, problems were immediately apparent. “The Cooperative Inspection Program is cumbersome, requires the entire state to apply to participate before individual plants that meet certain conditions can apply, and contains other provisions that appear to have dissuaded both states and plants from signing up,” reads a 2013 article in the Vermont Law Review.

According to Sen. Rounds, the bill co-sponsor, only four states so far have embraced the CIS model.

“It really is past time to just say that people can sell anywhere in the country under state inspection,” says Judith McGeary, executive director of the Farm and Ranch Freedom Alliance, in an email to me this week. “[E]ither that, or stop requiring that state inspection be equal to federal. Either it is equal or it’s not!”

Raid in Minnesota – Food Police Protecting People from Themselves, Again

In the continuation of an eight-year government assault on freedom of food choice, officials from the Minnesota Department of Agriculture (MDA), the Minneapolis Department of Health (MDH) and city police have shut down the physical location for the private buyers club, Uptown Locavore, embargoing thousands of dollars of nutrient-dense food in the process including raw dairy products and grassfed meats. The Locavore connects farmers and club members, enabling consumers to obtain foods they would not be able to purchase at a retail store.

On May 3rd MDA and MDH officials along with a police officer executed an administrative search warrant to inspect the property that served as a distribution point for the buyers club; the official’s visit turned into more than just an inspection. The officials embargoed every food product they came across, including the personal food items of Will Winter, longtime leader in the Twin Cities local food community and owner/manager of the locavore. The embargo notices MDH left at the location stated that the buyers club could not conduct business until “conditions set forth are met and the embargo is lifted.”

City officials also posted an “Unlicensed Business” notice on the property stating that the Uptown Locavore is unlicensed and that “further operation of this business is a criminal act and subject to criminal complaint and/or arrest.” The ‘catch-22’ for the Uptown Locavore was that, if it did get licensed, it would not be able to provide many of the nutritious foods it currently makes available to club members.

Winter responded to the enforcement action by going to the media to get out his side of the story. He pointed out that the search warrant was given by a judge to merely determine whether the buyers club was operating an unlicensed business; nothing was mentioned in the warrant application about confiscating food or shutting down the Locavore. Winter explained to the media that his private club should not have to obtain a business license because it does not sell or distribute any food to the general public; his location is not open to the public but only to club members.

Winter remarked that all transactions were between consenting adults and were done between a farmer/artisan producer and informed consumers. He emphasized that there had been zero complaints about the Locavore. He commented that the government “instead of using their resources to pursue real criminals and real crime….waste their day trying to destroy people they don’t understand and then seem to hate….this unjustified persecution of people doing the right things makes me very unhappy to be American.”

The May 3 raid wasn’t the first time the food police had shut down a private food distribution facility established by Winter. In 2010 state and city officials raided and permanently shut down the Traditional Foods Warehouse in Minneapolis, a devastating loss for the local food community. The Traditional Foods Warehouse had rapidly become an institution in the Twin Cities; at one time it boasted 1,800 members. There has never really been anything like it anywhere in the U.S. before or since its demise.

2010 also was the year MDA stepped up its enforcement campaign against famers distributing to informed consumers nutrient-dense foods that the department claimed were “illegal”, targeting dairy farmer Mike Hartmann and poultry farmer Alvin Schlangen. MDA raided both farmers in 2010 and subsequently had both criminally prosecuted.

MDA went after Hartmann because it suspected dairy products the farmer produced were responsible for eight cases of foodborne illness in the Twin Cities area. The state’s initial testing indicated there was a match between the pathogenic bacteria responsible for the illnesses and bacteria found on the Hartmann farm but the Minnesota Department of Health did many subsequent tests to strengthen its assertion that Hartmann farm dairy products were the cause of the illness; there was no match in any of these tests.

Hartmann pled guilty to two charges of violating the Minnesota food and dairy code but only to stop MDA from criminally prosecuting his wife as well as a 68-year-old woman on disability who was helping his farm. The lowest point in MDA’s enforcement tactics came when two MDA officials, three plainclothes policemen and two Bloomfield city officials executed a search warrant at the private residence of Rae Lynn Sandvig whose driveway served as a dropsite for Hartmann. The policemen met Sandvig at her bedroom door shortly after 8 a.m. telling her to go downstairs to her kitchen. Policemen went into the bedroom of Sandvig’s children ordering them to do the same. When Sandvig arrived in her kitchen she found the two MDA officials and the two city employees peering into the family’s refrigerator; the family kept no foods from Hartmann’s farm in their refrigerator or freezer other than those for personal consumption. MDA considered prosecuting Sandvig but subsequently dropped her case.

MDA had prosecuted Schlangen twice for criminal violations of the state food and dairy code; in the prosecution putting his livelihood at stake, a jury acquitted him of all charges. Hartmann and Schlangen remain in business continuing to provide nutritious food to informed consumers.

Hartmann is suing MDA over an illegal search and seizure the department conducted on his delivery truck during a 2013 stop on a Minneapolis highway; the department confiscated dairy products and equipment during the raid.

For the past five years MDA has been investigating Dave Berglund, a dairy farmer in northern Minnesota who sells raw milk and other dairy products to his loyal customers on his farm in Grand Marais. Berglund concluded a long court battle against MDA last year, with the courts ruling that the department had jurisdiction to inspect his farm. Berglund is contending he has a right under the state and federal constitutions to sell a product like raw butter direct to consumers while the department is claiming those sales are illegal. MDA’s investigation of Berglund appears to be continuing.

The Minnesota state constitution has a provision allowing farmers to “sell and peddle the products of the farm” without licensing. The constitutional provision should include the distribution of farm products through a private buyers club like the Uptown Locavore that facilitates farmer-to-consumer commerce. Regardless of how MDA interprets the law, what it and other government agencies cannot escape is the fact that eight years of heavy handed enforcement hasn’t deterred consumers from seeking healthy food that the state declares is illegal. People continue to demand food from farmers like Hartmann, Schlangen and Berglund; they continue to join buyers clubs like Winter’s Uptown Locavore to have access to quality food they cannot find in retail stores.

Increasingly greater numbers of consumers want to opt out of the industrial food-vaccine-pharmaceutical drug paradigm. If these enforcement actions against real food are all about protecting the public health, here’s a challenge to the state and local government agencies in Minnesota who are harassing Winter: do a survey of Uptown Locavore members and then do a survey of other random people to determine what each group demands in terms of medical services (e.g., doctor visits, prescription drug use, etc.). Government officials would find that the buyers club members demand much less in the way of medical services, saving the taxpayers and insurance companies money. The state of Minnesota could be sending the savings on expanding farm-to-school programs but instead spends millions persecuting those who are making people healthier.

The government should be honoring Winter instead of dumping food confiscated at the Uptown Locavore into a landfill. It should recognize farmers like Berglund, Hartmann and Schlangen as frontline healers instead of trying to shut them down. This is about control and preserving industrial Ag’s market share by denying freedom of choice. MDA can recognize this freedom by exercising its enforcement discretion not to take action against people like Winter who are actually helping to make others well. One day there will be a court ruling affirming that there is a legal distinction between the public and private distribution of food. Until that time MDA and the other agencies can best protect and promote the public health by allowing people to obtain the food of their choice from the source of their choice regardless of whether that source is regulated by the government.

A good way to begin the departure from the failed policies of the past would be for the Minneapolis Health Department to lift the embargo on the food at the Uptown Locavore and allow the buyers club to resume operations. Unfortunately, Daniel Huff, an official for the department has indicated the city will seek a condemnation order to destroy the dairy products embargoed at the Locavore. Short of a legitimate accusation against the club of the food being responsible for foodborne illness, Winter and its members should have the right to be left alone.

High Stakes for Raw Milk in Wisconsin

This article is a collaboration between the Weston A. Price Foundation (WAPF) and the Farm-to-Consumer Legal Defense Fund (FTCLDF).

Wisconsin organic dairy farmer Chaz Self is a face of the crisis confronting milk producers across the country. Self’s cooperative recently dropped him as a member, leaving him scrambling to find another buyer for the milk his farm, Grassway Organics, produces. Self could be making up for some of the lost sales by selling raw milk; Wisconsin law allows the sale of raw milk on an “incidental basis.” The Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) could be helping farmers like Self by using its enforcement discretion to let him sell raw milk. DATCP, however, recently served the farmer with a summary special order threatening the loss of his Grade A Milk Permit if he sold any raw milk for human consumption.

The farmer is currently dumping hundreds of gallons of high quality raw milk. Self’s case provides a great look at the unprecedented emergency dairy farmers are facing and how selling raw milk is a potential way to help keep thousands of them in business.

Self maintains a herd of around 100 cows on a 400-acre farm where he lives with his wife Megan and their three young children. His Jersey herd is 100% A2. The Selfs sell poultry, eggs, pork and beef to their customers on the farm and at farmers markets.

Last year Self appeared in the Netflix documentary, Rotten, a series of episodes uncovering fraud and corruption in the industrial food system. Self appeared in the episode “Milk Money” which discussed the production and sale of raw milk. Self never stated that he sold raw milk but the narrator of the episode implied that he did. Shortly after the episode aired, DATCP started investigating Self; the investigation wound up with the department issuing an order allowing him to keep his Grade A permit on the condition that he stop selling raw milk. This was an unjustified move, given that DATCP based its decision solely on what the narrator said he was doing; there was no other evidence mentioned in the order about Self selling raw milk.

To compound matters, on April 1 Self’s cooperative, Westby Creamery, terminated his membership; on April 18 DATCP sent Self a “notice of deadline to change assigned dairy plant”, stating the farmer has until April 30 to find a processor to pick up his milk. If he fails to do so, DATCP will revoke his Grade A permit; with the current state of the dairy industry, that is not an easy task.

The American dairy sector has been in a decades-long decline that is currently accelerating. In 1992 there were 131,535 licensed dairies in the U.S., at the end of 2017 there were 40,219.1 The number of dairies closing shop has increased substantially since the beginning of the year. In 1992 the average herd size for farms was 74 cows; by 2017 it had risen to 2342, showing the consolidation in the dairy industry and the exit of small farms from the commodity milk system.

Wisconsin went from about 29,000 dairy farms in 1995 to a little over 9,000 at the end of last year.1 Two particular recent developments have accelerated the decline of conventional and organic dairies in Wisconsin. First, more conventional milk is being shipped into Wisconsin from other states. In 2017 more than 100 trailer loads of milk per day3 was coming into Wisconsin from states such as Michigan, Indiana and Ohio; frequently this milk was being sold more cheaply than the price sellers of conventional fluid milk would normally get.

Secondly, this year certified organic CAFO dairies in Texas have increased shipments of milk to Wisconsin. According to a USA Today March 24 story by a Milwaukee Journal Sentinel writer, six certified organic dairy farms in Texas produced about 23% more milk than all of Wisconsin’s 453 organic dairy farms combined in 2016.4 The greater supply of organic milk has led to more quotas for producers and co-ops cutting back on members; in addition to Self, Westby Creamery recently terminated the contracts of seven other members.

The commodity milk system is becoming more untenable than ever for small farms. Recent prices around the country for conventional milk have been as low as $1.11 per gallon; while there are some organic producers that are still doing well, prices overall have declined substantially for organic milk. Farmers wanting to sell cows are finding little or no market. Oversupply and lower pay prices mean a race to the bottom for commodity milk.

One way for producers to escape or survive the commodity milk system is to sell raw milk for direct consumption; prices farmers can get for raw milk sales to the consumer are much higher than what they can receive for either conventional or organic milk intended for pasteurization. In Wisconsin the law is there for dairies to sell raw milk and improve their bottom line; the problem has been DATCP and its interpretation of what an “incidental sale” is.

The legislature passed the incidental sale law in 1957. The original intent of the law was that any sale of raw milk for human consumption was an incidental sale. At the time the law went into effect, there were over 100,000 dairies selling raw milk intended for pasteurization in the state 5; for all of them, sales of raw milk for direct human consumption were likely a very small percentage of total sales.

At one time DATCP interpreted the incidental sales law as meaning only one sale of raw milk per customer ever. In 2008 the department changed that, issuing a regulation that stated, “a sale is not incidental if it is made in the regular course of business, or is preceded by any advertising, or solicitation made to the general public through any communications media.” There is nothing in the statute legalizing incidental sales that prohibits advertising or solicitation.

DATCP’s interpretation of “not in the regular course of business” has been unfavorable to raw milk producers and consumers. It’s time for that to change; America’s Dairy Land is in an emergency situation. Dairies are going out of business every day in the state. DATCP can help Wisconsin dairy farms by either adopting a more liberal interpretation of what constitutes “not in the regular course of business” or by waiving enforcement against dairies selling raw milk direct to consumers in the regular course of business. For precedent on the latter step, DATCP only needs to look at the bordering state of Michigan.

Michigan law prohibits the sale or distribution of raw milk for human consumption; nevertheless in 2013 the Michigan Department of Agriculture and Rural Development (MDARD) adopted a written policy in which it would not take action against dairy farms distributing raw milk through herdshare agreements. MDARD set parameters that had to be in place, such as a written contract between the farmer and consumer for it to waive enforcement; DATCP could take a similar tact in Wisconsin.

DATCP is charged with promoting Wisconsin agriculture; one way it can do that with the current dairy crisis is to change its enforcement or interpretation of the law to one that benefits raw milk producers and consumers. Producers like Chaz Self have the quality raw milk and the potential demand to succeed. DATCP shouldn’t be preventing Self from selling raw milk. DATCP has an opportunity to help dairy farms stay in business. Ultimately, it would be great to pass a bill taking the word “incidental” out of the Wisconsin raw milk statute; but with the accelerated decline dairy is going through, there is no time to waste. The department should either adopt a new interpretation of the raw milk law or exercise its enforcement discretion now.

[1] Dennis Halladay, “Here it comes: less than 40,000 dairies”, Hoard’s Dairyman, March 19, 2018. Last viewed 4/25/2018 at https://hoards.com/article-22818-here-it-comes-less-than-40000-dairies.html

[2] Corey Geiger, “Dairy farm numbers hover near 40,000”, Hoard’s Dairyman, February 26, 2018. Last viewed 4/25/18 at

[3] Pete Hardin, “March Dairy Meetings Somber in Wisconsin…”, Milkweed, Issue No. 465, April 2018; p. 5. [Wisconsin Farmers Union, “How Does It Work, and Would it Work Here?”, Dairy Supply Mgmt. in Canada, meeting 15 March 2018 at Dodger Bowl Banquet Center, Dodgerville, WI, recorded by www.wiseye.org; last viewed 4/25/2018 at http://www.wiseye.org/Video-Archive/Event-Detail/evhdid/12277]

[4] Rick Barrett, “Wisconsin’s small organic dairies squeezed by Texas mega-farms”, USA Today, March 24, 2018. Last viewed 4/25/2018 at https://www.usatoday.com/story/money/business/2018/03/24/wisconsins-small-organic-dairies-squeezed-texas-mega-farms/455330002/

[5] U.S. Department of Commerce, “County Table 10 – Dairy products and poultry and poultry products sold from farms: Censuses of 1959 and 1954”, U.S. Census of Agriculture: 1959, Volume 1, Part 14: Wisconsin (Chapter B – Statistics for Counties), p. 163. Last viewed 4/25/2018 at http://usda.mannlib.cornell.edu/usda/AgCensusImages/1959/01/14/866/Table-10.pdf

Photo courtesy of Grassway Organics LLC facebook page

Local Food Challenges: Securing fresh food from fertile soil

Posted by permission of author, Joseph R. Heckman, originally published online 29 November 2017 by Cambridge University Press as “Securing fresh food from fertile soil, challenges to the organic and raw milk movements” in Renewable Agriculture and Food Systems. See Facebook synopsis by RAWMI

Securing fresh food from fertile soil, challenges to the organic and raw milk movements

In recent decades, a diverse community of dairy farmers, consumers and nutrition advocates has campaigned amidst considerable government opposition, to secure and expand the right of individuals to produce, sell and consume fresh unprocessed milk, commonly referred to as ‘raw milk’. This advocacy shares important parallels with battles fought in the organic food movement over the past century. Both the raw milk and organic food movements originated with farmers and consumers who sought to replace industrialized food production and processing practices with more traditional ones. Both movements equate the preservation of natural integrity in farming and food handling with more wholesome, nutritious food and environmental conservation. Both movements have had to work diligently to overcome a false perception that their practices are anachronistic, notably with regard to productive output of organic agriculture and the safety of fresh unprocessed milk. There is also the failure of opponents to acknowledge a growing body of scientific evidence for health benefits associated with drinking of fresh unprocessed milk. The raw milk movement has the potential to economically benefit family farmers, much as organic agriculture has done. Building soil fertility, a foundational principle of organic farming, would benefit from having numerous small pasture-based dairies spread across the land providing fresh unprocessed milk. Agricultural universities and the Cooperative Extension System could seize a real leadership opportunity by promoting and participating in this reinvention of dairy farming, and restoring the ecology of this traditional food and farming system.

Click links to jump to sections; references listed at end
1-Method | 2-Context | 3-Milk | 4-Quality | 5-Mainstream | 6-Health | 7-Policy | Summary


In the early years of the organic agriculture movement, Albert Howard declared ‘fresh food from fertile soil’ the ‘birth right of humanity’ (Howard, 1946). In recent decades, diverse consumer movements interested in organic and other traditional food systems have been organizing for the right of dairy farmers to produce, and consumers to have access to fresh unprocessed milk. In spite of a rapidly growing market place for organic foods, many organic dairy farmers who want to produce and sell fresh unprocessed milk are challenged by policy or discouraged by educational programs dictating food choice.

The social, political and legal challenges to this movement have been the subject of several recent books and articles (Enticott, 2003; Salatin, 2007; Gumpert, 20092013; Schmid, 2009; Mincyte, 2014) and several reviews on the history of the organic agricultural movement have been published (Heckman, 2006; Youngberg and DeMuth, 2013; Saucier and Parsons, 2014). However, the broader story of the interconnections between the raw milk and organic food movements remains untold.

In the forward of The Untold Story of Milk (Schmid, 2009) Sally Fallon Morell briefly described the parallel between the organic and raw milk movements: ‘Twenty years ago organic agriculture was a fringe movement, barely on the mainstream radar scope, a subject commentators treated with derision and politicians with scorn. Today organics is the fastest growing sector of the agricultural economy, a paradigm that garners tremendous public support, one that has proven a boon to many farmers. Raw milk today is a fringe movement, a crusade of underdogs, a pesky mouse against the entrenched lions of medicine and industry. Who would be foolish enough to propose reinstating raw milk into the American diet? Or suggest that the agricultural model of the future will be the small farm with the dairy cow as its centerpiece?’.

The similarities between the raw milk and organic food movements are numerous. One reason people have chosen to buy organic milk is their concern for the method of food production. Being a staple in many diets, and especially for children, parents are naturally particular about their source of milk. For dairy, research has shown superior nutritive food composition in organic production over conventional (Benbrook et al., 2013), a difference that can be attributed, at least in part, to the requirement that organic dairy systems must obtain a minimum 30% of dry matter intake from pasture across a grazing season lasting a minimum of 120 days.

In addition to the method of food production, the most discriminating consumers are concerned with how the pathway from farm to table may influence nutrition, safety and quality of organic foods. The concept behind ‘Know Your Farmer, Know Your Food’ (USDA Program, 2012) would fit consumer interest in finding fresh unprocessed milk of the highest possible quality.

For example, the modern dairy industry requires that certified organic milk be handled separately from conventional milk, but collection and processing systems are essentially the same. It typically begins with tanker trucks collecting and commingling organic milks from individual farm bulk tanks. The organic milks obtained from many different farms are delivered to a processing plant where the milk undergoes pasteurization or often ultra-pasteurization and usually also homogenization. Typically the cream is separated from the milk and the remaining product is sold as reduced fat or skim milk. Before this milk is placed on a shelf in a grocery store, it has lost its farm identity and has been altered in many ways that would no longer qualify as a fresh whole food in the traditional sense of the word ‘organic’. Yet such milk does qualify as organic under the USDA National Organic Program standards (Code of Federal Regulations, 2015).

Organic standards prohibit treatment of organic food with irradiation, but there are no other provisions to prevent organic milk from being treated differently after it leaves the farm than the conventional food system. Although there has been hope that the organic milk market would offer an economically viable alternative to the conventional food system, recent market trends with processed organic milk as a commodity is beginning to resemble the conventional dairy sector (Guptill, 2009; Whoriskey, 2017).

Once a dairy farm transitions from a confinement model to a pasture-based feeding system, a smaller further step (Heckman, 2015) is to convert the farm to organic following the required 3-yr period for transition. Often after a dairy farm becomes certified organic, consumers begin showing up at the farm gate seeking to purchase raw milk before it gets shipped for processing. This has occurred so frequently that Organic Valley Cooperative, the largest organic dairy cooperative in the United States, now prohibits its members from selling milk off the farm to any other buyer (2010).

The actual growth in demand and consumption of raw milk is, however, difficult to measure for political reasons. The legal status of raw milk sales varies greatly within the United States (Farm-to-Consumer Legal Defense Fund, 2016) and around the world. The hostility of the public health community and government enforcement action has frequently pushed raw milk into an underground market (Gumpert, 2013).

A 2006–2007 survey of food consumption patterns conducted by the Centers for Disease Control (2006–2007) in several states suggested that about 3% of the US population consume raw milk. Another indication of demand is that more dairy farmers are exhibiting interest in producing raw milk for this market. For example, in Pennsylvania where raw milk sales are legal, the number of permits increased from about 25 dairies in 2003 to over 150 in 2014 (Kaylegian, 2014). A high percentage of these farms is either certified organic (about 23%) or practice organic farming on pastures without certification.

Raw milk is very often purchased directly from a farmer rather than from a grocery store. This direct contact between a farmer and the families eating the food fosters a living trusting ‘organic’ relationship. When people visit the farm, they often come to appreciate the nature of the operation (Hassanein, 2011). People who drink fresh milk tend to place great emphasis on organic feeding practices, especially pasture, and quality of the milk (Katafiasz and Bartlett, 2012). Organizations dedicated to teaching people about fresh milk strongly urge that the milk should be produced from pasture-raised animals and not from concentrated animal feeding operations (Gumpert, 2015). Large-scale industrial or confinement operations that emphasize high levels of production per animal unit are not a recommended source for fresh milk (Shetreat-Klein, 2016). These fresh milk guidelines are aligned with USDA-NOP standards that require pasture feeding of animals. Fresh milk consumers are often satisfied with farmers following organic practices without actually attaining certification (Baars et al., 2015).

The lack of attention to the raw milk debate by historians may seem surprising given that dairy was by far the most valuable commodity produced on the US organic farms in 2014 (USDA Agricultural Census, 2015). While demand for fluid conventional milk has been steadily declining for several decades (Berry and Gee, 2012), and virtually all of the organic milk is thermally processed prior to sale, the growth in demand for permits to sell raw milk in some states has been described as ‘explosive’ (Beecher, 2016). This despite the fact that drinking of raw milk remains highly controversial among conventional milk producers and policy makers (Gumpert, 2015). Considering that the organic farming and food movement has a history of challenging authority and conventional wisdom (Heckman, 2006; Obach, 2015), it should not be surprising that some members of this community accept drinking raw milk as natural and normal (Organic Valley Cooperative, 2010).

The main objective of this review is to provide an historical account of the raw milk movement and its long association with the organic farming movement. A second is to provide a survey of the literature pertaining to the question of health and nutrition benefits associated with drinking fresh unprocessed milk. A third objective is to examine how food policy governing access to fresh unprocessed milk may impact soil fertility in the context of agroecosystem sustainability. Taken together, this paper will show a need for involvement by agricultural universities, the Cooperative Extension System and public health institutions. They will need to reconsider their long-standing near-universal opposition to drinking fresh unprocessed milk to one of supportive research and education.


Personal and professional work experience in an academic setting was garnered as a result of being involved in organizing and hosting various educational programs (Table 1), and in 2008, a seminar series specifically focused on raw milk and informed consumer choice (Rutgers New Jersey Agricultural Experiment Station, News Release, 2008). Besides the four invited seminars that took place in 2007, several other speakers with differing views were invited but declined to participate in the seminar series. To manage the surrounding storm of controversy and numerous questions, an extensive search for literature was conducted. All found literature concerning scientific, historical, political and legal aspects of the raw milk issue was collected and made available for colleagues and students at the Rutgers University through electronic file sharing. Professors were invited to add any related documents to this collection that they deemed to be important for inclusion. Funds for the literature search and seminar series were provided by the Rutgers New Jersey Agricultural Experiment Station.

Table 1. In 2008, Rutgers New Jersey Agricultural Experiment Station sponsored a seminar series to help people understand the issues and provide science-based information about raw milk. Other related educational programs included additional speakers and screenings of documentary films about raw milk. Event year, speaker and program titles are listed. [view original posting of Table 1]

The (2008) seminar series and accompanying lectures and events along with the electronic sharing of raw milk files stimulated a lively and sometimes heated scholarly discussion (Alexander, 2011). Most recently, this author was invited by a USDA scientist to participate as a member of a scientific debate panel concerning raw milk risks and benefits. This debate was sponsored by the International Association of Food Protection and was held in St. Louis, Missouri on August 3, 2016 (Fallon Morell, 2016).

This review draws upon observations, experiences and an extensive collection of literature concerning milk and places it in the context of the organic farming and food movement. Previous scholarly activity on exploring the history of the organic movement (Heckman, 2006) along with service to the Organic Management Systems Community within the American Society of Agronomy (Heckman et al., 2013) and as a board member of the Northeast Organic Farming Association of New Jersey provided further background.

The whole story: fresh milk in context

A common philosophy of the early organic farming and food movement was a central focus on the concept of ‘wholeness’. An organic farm functioned in its ‘wholeness’ as an integrated system of living organisms. Sir Walter Northbourne captured this philosophy of an organic farm saying it ‘must have a biological completeness: it must be a living entity’ where every ‘branch of the work is interlocked with all others’ (Northbourne, 1940).

Eve Balfour, founder of The Soil Association (Brander, 2003) became known as the ‘Voice of the Organic Movement’. In her bestselling book The Living Soil, she elaborated on the wholeness philosophy by extending the concept to food as in ‘whole diets’ (Balfour, 1976). She wrote: ‘The theory which I have endeavored to expound in this book is that the only true conception of health is one of wholeness, dependent upon both the continuity and the completeness of the cycle of life.’ She further argued that, ‘the health-giving property of food is dependent on the way it is grown, prepared and consumed.’ In her chapter on ‘whole diets’ she provides a review of how ancient peoples ‘preserved the wholeness of their health and that of their crops and livestock’ by summarizing the observations of medical pioneers in nutrition. She draws from the works Sir Robert McCarrison (McCarrison, 1953), Weston A. Price (Price, 1950) and many others as examples of where healthy communities existed with virtually no physical or mental defects until their food culture was displaced by modern industrialized foods. While building the case for fresh whole foods sourced from fertile soils, she advocates for a ‘complete and continuous transference of health from fertile soil, through plant and/or animal to man and back to the soil again’. As a leading voice in the organic farming movement, Balfour was also a vigorous opponent of compulsory pasteurization (Tinker, 2000).

In an article in Organic Gardening magazine Sir Albert Howard (Howard, 1946) wrote about ‘a famine of quality’ and the ‘murder of our daily bread’ as a result of growing food with artificial fertilizers and the use of modern processing to manufacture and denature foods. He refers to the work of Dr Weston Price as confirmation for his analysis of the problem and urges widespread distribution of Price’s book Nutrition and Physical Degeneration. Howard recommends that schools provide nourishment to children as: ‘The produce including bread and the milk should come from humus-filled soil and should be consumed fresh.’

When Walter Northbourne outlined seminal concepts of organic farming in his 1940 book Look to the Land, he also accurately and insightfully characterized the current situation as it pertains to milk: ‘So long as people go on being fooled by advertisement (blatant or concealed) of processed foods, so long will they and the farmers be at the mercy of vast distributing concerns, whose every interest seems to be opposed to the people’s real nutritional necessities. How can it be otherwise in a world of specialization and urbanization? Effective distribution seems to necessitate sterilization, which means killing, for failure to sterilize may mean infection in bulk. Hence the outcry for the pasteurizing of milk. But sterilization reduces the resistance to infection and the power of assimilation of the consumer of that which is sterilized. So yet more sterilizing seems to be necessary. A vicious circle again, of a type which should by now be familiar.’

In the United States where J.I. Rodale first popularized organic farming, he similarly drew connections between healthy soils, healthy food and healthy people. Following in the same vein as other organic pioneers, his publications frequently discussed how commercial and industrial food processing reduced its nutritional value. Similarly, Rodale’s thinking was influenced by observations on traditional farming and food systems as described by Sir Robert McCarrison and Weston Price (Rodale, 1948). Ten years later (Rodale, 1958) in an Organic Gardening and Farming magazine article entitled ‘What Does Organic Mean’, he explicitly staked out the organic position against pasteurization: ‘It is not organic to produce milk organically, and then to pasteurize it.’

A recent report (Michigan Fresh Unprocessed Whole Milk Workgroup, 2012) states: ‘Milk fresh from the cow is a complete, living, functional food…the full benefits…are only realized when all of these components function as a complex interdependent and balanced process.’ This contemporary view on wholeness of food systems from a panel of experts is consistent with the philosophy of the early pioneers of organic farming. The list of ‘consumer preferences on production and management practices of fresh whole milk’ outlined in the Workgroup report is also consistent with the cultural practices associated with organic farming.

Milk problems and solutions

Among the parallels that exist between the fresh milk and organic farming movements are responses of a concerned farming and food community to the destructive forces of a modernizing and increasingly industrialized agriculture.

One of the myths about organic farming (Heckman, 2010) is that before the widespread use of synthetic chemical fertilizers and synthetic pesticides, the farming that was being practiced was organic without the banner of the name. While this was partly true in some places in the world, such as that described by F. H. King (1911) in Farmers of Forty Centuries or Permanent Agriculture in China, Korea, and Japan, it was clearly not so in many places where soils were being destroyed on a massive scale by erosion. Along with the soil erosion, there was also concern over loss of native soil fertility and soil organic matter content (Heckman, 2013). These problems were described in detail in the opening chapters of The Living Soil (Balfour, 1976) and in Look to the Land (Northbourne, 1940). In these and other pioneering works, organic farming systems were proposed as a viable ecological solution to the crisis of soil destruction. In contrast, modern conventional agriculture chooses technological approaches to address soil erosion by promoting genetic engineering and chemical herbicide-no-till farming systems.

In the case of dairy farming, a serious health crisis was created in the late 1800s as a result of moving cows into crowded city feed lots and feeding them an unnatural diet (Schmid, 2009). In cities, the need for milk and the demand for whisky led to an unhealthy partnership for the mass production of both commodities. Urban centers have little pasture or forage available to feed cows. Swill, a by-product from the fermentation of grains to produce whisky, was a waste material commonly available from inner city distilleries. The feeding of swill to cows housed in deplorable and unsanitary conditions led to the production of unhealthy milk for infants and children, which in turn contributed to sickness and death.

The horrible conditions at a New York City dairy in 1842 were described by Robert Hartley (1842): ‘Here, in a stagnant and empoisoned atmosphere that is saturated with the hot steam of whiskey slop, and loaded with carbonic acid gas, and other impurities arising from the excrements of hundreds of sickly cattle, they are condemned to live, or rather die on rum-slush. For the space of nine months, they are usually tied to the same spot, from which, if they live so long, they are not permitted to stir, excepting, indeed, they become so diseased as to be utterly useless for the dairy.’

In some respects, the filthy inner city dairies of the 1800s were like an early version of the modern concentrated animal feeding operation or CAFO (Imhoff, 2010). Livestock raised in CAFOs are exposed to an abundance of manure, an absence of sunny pastures and in general conditions where pathogens may flourish. The abundance of manures produced by CAFO operations are often linked to cases of food-borne illness (Erickson and Doyle, 2012). Chemical treatments, irradiation or high-pressure processing are proposed as technical solutions (National Advisory Committee on Microbiological Criteria for Foods, 2004) to food safety problems that might be avoided by changing to ecological methods of farming.

Similarly, pasteurization of milk, often described as a major public health victory, became a technological solution to a man-made problem. A century of pasteurizing milk is a relatively short history compared with the thousands of years during which humans evolved in association with consuming animal milk without pasteurization (Curry, 2013). Although not all peoples of the world became consumers of dairy, the archeology of milk suggests Europeans that did were apparently advantaged both in terms of fertility rate and a more secure food supply. In 1935, Weston A. Price, while traveling through parts of Africa, observed that the herders of cattle and goats, living primarily on dairy products, were similarly advantaged relative to non-herders (Price, 1950).

Mark McAfee refers to the modern era of dairy and the introduction of pasteurization with the phrase: ‘Pasteurization was an 18th century solution to an 18th century problem’ (McAfee, 2013). Out in the countryside where cows were kept on pasture, fresh milk was generally a wholesome food when consumed fresh or fermented (Schmid, 2009). The movement toward milk pasteurization did not begin in the countryside but rather in the cities where cows were housed in deplorable conditions and fed an unnatural diet. Compounding the milk problem was a lack of refrigeration and a food distribution system based on limited scientific knowledge and without standards for sanitation and hygiene (DuPuis, 2002).

This set of circumstances, where milk could be easily contaminated with pathogenic bacteria, suggested the need for a kill step such as heating to a specific temperature and time period to make the milk safe. Pasteurization, a process originally invented for preserving wine, was initially promoted by a wealthy businessman, Nathan Strauss, and eventually became widely adopted by the dairy industry (Schmid, 2009).

A completely different approach to securing clean fresh milk for infants and children was pursued by Dr Henry Coit, MD, a pediatrician from Newark, New Jersey (Rogers, 1955). A commemorative poster (Heckman, 2011) in the hallway at Beth Israel Hospital (Originally known as Babies Hospital) describes the medical and pioneering accomplishments of Dr Coit: ‘A Pioneer in American Pediatrics, Henry L. Coit, MD, begins his lifelong crusade for better infant feeding and cleaner milk, following the death of his first son at age two from intestinal disease. In 1892, Dr Coit outlines a program for purification. Two years later, the world’s first bottle of certified milk, handled entirely under medical supervision, is delivered. Soon Babies Hospital delivers pure certified milk to families throughout Newark. At its peak, the program distributes 150,000 bottles per year.’

Rather than implement a kill step like pasteurization to make poorly produced milk safe, Dr Coit instituted a set of practices for better dairy stewardship. Dr Coit found that many dairy farmers of the time lacked knowledge of hygiene to produce clean milk. Being well aware of the challenges involved, Dr Coit ‘devised a plan for a professional body composed of physicians, which should first educate, then encourage and finally endorse, the work of dairymen who would bring to us milk designed for the most exacting needs of physicians’. His plans also specified production practices, inspections and certification under a legal contract with the dairy farmer (Rogers, 1955). Under the leadership of Dr Coit, the first Medical Milk Commission was established in Essex Country, New Jersey in 1893. By 1896, over 60 Medical Milk Commissions were operating around the world.

In 1909, the New Jersey State Department of Health adopted the definition of certified milk that originated (Rogers, 1955) from Dr Coit: ‘Certified milk is a product of dairies operated under the direction of a medical milk commission, which body is appointed for voluntary service by a medical society. The milk is designed to fulfill standards of quality, purity and safety to ensure its adaptability for clinical purposes and the feeding of infants.’

Certified milk continued to be available as a choice in New Jersey at least up until 1971 when the Walker–Gordon Farm in Plainsboro, New Jersey closed. Milk certified by the Medical Milk Commission bottled at Walker–Gordon Farm was shipped by rail to Philadelphia and New York. The dairy began its operation in Plainsboro in 1897 and provided fresh unpasteurized milk to the surrounding communities for many decades and even after 1964 when New Jersey legislation made raw milk distribution illegal.

The loss of this special fresh milk is described in an excerpt from a book entitled Walker-Gordon, One of a Kind (Tindall and Clark, 1998): ‘For those of us who grew up with the taste of fresh, really fresh, whole milk, unadulterated in any manner except to chill it ice cold, today’s milk is a sad replacement.’

In the early 1900s, many medical doctors recommended pure raw milk over pasteurized milk (Anonymous, 2010). ‘Certified milk’ was the way Dr Coit envisioned providing infants and children with fresh pure milk without pasteurization. For several decades, people were allowed a choice to buy either certified milk or pasteurized milk. Historically, food protection associations generally agreed and allowed for an exception to mandatory pasteurization in the case of certified milk (International Association of Food Protection, 2014).

Certified milk was at a disadvantage in a market place due to the added expense of producing clean fresh milk. In some instances, the production of pasteurized milk was subsidized. Eventually pasteurization became the dominant process as it allowed dairy farming and milk processing to industrialize on a massive scale (Schmid, 2009).

Like certified organic farming, certified milk production adhered to a set of standards to guide food production even if for different reasons. In the case of organic farming, certification directs ecological stewardship of soils, crops and livestock without the use of most conventional chemical inputs of questionable safety. With certified milk, the emphasis was on better dairy farming practices and careful milk handling to produce clean milk. Inspections are part of both certification systems. The good hygiene required to produce certified milk played a part in raising the standards for the entire dairy industry including that of raw milk intended for pasteurization (Rogers, 1955).

The sanitary handling procedures and standards for milk production intended for processing are codified in the US Food and Drug Administration (FDA) regulations as outlined in the Pasteurized Milk Ordinance (PMO). The PMO standards do not apply nor are they appropriate for dairy farms producing raw milk that will be consumed as fresh unprocessed milk. Individual states that permit raw milk sales or distribution vary widely in standards and regulation.

The absence of national standards for production of unpasteurized milk for direct human consumption inspired the founding of the Raw Milk Institute (RAWMI) by an organic dairy farmer (McAfee, 2011). Established in 2011, RAWMI mentors and trains producers of fresh unpasteurized milk. As described on its website, it ‘facilitates best practices in the raw milk industry through the evaluation of research findings’ and farm experience to create individualized food safety plans. Dairy farms that work with RAWMI adopt a set of standards; develop a risk assessment and management plan and safe operating procedures that are customized to the unique environment of the farm.

In some respects, the writing of this plan for an individual farm is analogous to writing an organic farm plan for organic certification. As with certified milk, the RAWMI emphasizes training and carefulness of the production. Producing a clean high-quality fresh unprocessed food within a system of farming and verifying the integrity of that system is not unlike goals for organic certification (Johnston, 2014).

The economic disadvantage of regulated and permitted raw milk arises from the special procedures for minimizing risk, which results in a food with higher production costs than pasteurized milk. Producing certified organic foods may be economically disadvantaged for similar reasons. However, premiums that consumers are willing to pay for organic food tend to improve the profitability of organic farming (Kantor, 2015).

Quality, hygiene and food safety

The legacy of Dr Coit serves to draw a distinction between the health impacts of carefully produced legitimate food-quality fresh milk intended for direct human consumption and processor-quality raw milk, which is produced knowing that pasteurization will follow. Dr Coit and the Medical Milk Commission were very concerned about both the benefits of the milk for their patients and the public health effects of dirty milk. This crucial distinction is often ignored in public discourse. Thus, when public health officials issue warnings about raw milk consumption or cite illness or outbreak statistics, they typically make no distinction or give little consideration to how milk is produced. It is simply labeled ‘raw’.

For example, it is useful to examine statements issued by the Centers for Disease Control (CDC) and other food safety officials:

‘Raw milk is milk from cows, goats, sheep, or other animals that has not been pasteurized.’

‘No matter what precautions farmers take, and even if their raw milk tests come back negative, they cannot guarantee that their milk, or the products made from their milk, are free of harmful germs.’

‘Dairying methods have improved over the years but are still no substitute for pasteurization in ensuring that milk is safe to drink. Raw milk supplied by “certified,” “organic,” or “local” dairies has no guarantee of being safe.’

While these statements from the CDC may be partly true, they seem to imply that not only is pasteurization the only safe option, but that it ‘guarantees’ safety. They also set up an impossible standard for any food to achieve.

The CDC is not alone. Some food scientists (Lally, 2011) accept the fact that ‘there is no way to guarantee the safety of any food’. However, other scientists (Claeys et al., 2013) write about how milk is ‘heat treated’ to ‘guarantee its microbial safety’.

A careful look in the historical record for pasteurization shows that it does not guarantee food safety. Any food, including raw or pasteurized milk, can be associated with food-borne illness (Real Raw Milk Facts, 2005–2017). Although dairy in general is among the safest of foods, a few notable examples of well-documented illness and deaths linked to pasteurized milk show that pasteurization does not guarantee safety. Very rarely do news stories that highlight the risks associated with raw milk drinking ever acknowledge the reality of illnesses or deaths linked to pasteurized milk. Thus, it is essential for a balanced discussion to at least present some of the food-borne illness data linked to pasteurized milk. In 1985, it was estimated that more than 168,000 people were sickened with Salmonella from pasteurized milk (Ryan et al., 1987). In 2007, Listeria from pasteurized milk was linked to three deaths. Furthermore, according to this report on these deaths linked to Listeria, ‘records indicate that pasteurization methods at the dairy were adequate’ (CDC, 2008). A more recent analysis (Stasiewicz et al., 2014) indicated that on average 18 deaths occur annually from consuming pasteurized milk and that increased risk is related to increasing temperatures used for pasteurization.

Consumption of fresh milk, as with any food, is associated with some level of risk. People unwisely sometimes drink commodity raw milk intended for pasteurization or they may drink raw milk from a black market source. Amateurs can get involved in raw milk production without adequate training and provide an unsafe product; but without drawing a distinction between legitimate food-quality fresh milk carefully produced from healthy cows and commodity raw milk produced under PMO standards (which do not require testing for pathogens, and allows commingling of milks from many farm bulk tanks intended for pasteurization), the level of actual risk of drinking carefully produced fresh milk remains impossible to accurately quantify.

The three main pathogens of public health concern with unpasteurized milk are Campylobacter jejuni, the shiga-producing strains of Escherichia coli and Salmonella. These pathogens are commonly found in bulk tank commodity raw milk intended for pasteurization; but in carefully produced fresh unprocessed milk, they are found only on rare occasion (Baars et al., 2015). The Real Raw Milk Facts website, which reports illnesses and deaths attributed to either raw milk or pasteurized milk, makes no distinction between commodity raw milk intended for pasteurization and carefully produced clean raw milk produced for fresh consumption.

Several recent studies conclude that raw milk is a high-risk food, which poses a risk for outbreaks 150 times greater than pasteurized milk (Langer et al., 2012). Critics have challenged these studies’ underlying assumptions, the confusion between outbreaks vs number of illnesses per outbreak, the estimated population size of raw milk consumers and the time frame for data inclusion or exclusion (Kresser, 2012; Weston A. Price Foundation, 2012).

When outbreaks attributed to raw milk occur, they are generally associated with a small number of illnesses per outbreak. The illnesses are generally traceable back to or linked to a single dairy farm that serves a small community of customers from a relatively small herd of dairy animals.

In contrast, pasteurized milk is usually obtained by pooling milk from numerous farm bulk tanks, and when outbreaks do occur, they can be very large. For example, the earlier cited outbreak from salmonellosis traced to pasteurized milk was described as ‘massive’ and made it the largest ever identified outbreak in the United States (Ryan et al., 1987).

Proponents argue that where raw milk sales are legal, regulated and widely available, the number of illnesses associated with raw milk drinking is self-limited and manageable, as much as it can be with other foods (Weston A. Price Foundation, 2012). Cooperation from public health agencies and training of fresh milk producers in best practices could conceivably further improve its safety.

The current situation also raises questions: Why is less than perfectly safe a manageable risk for every kind of food except in the case of fresh unpasteurized milk? Why are no other foods held to the impossible standard of a perfect safety record?

Proponents argue that when compared with many other foods, the number of illnesses associated with fresh milk consumption is comparatively small. For example, at the International Association of Food Protection, Raw Milk Debate in 2016, it was shown that leafy greens are at the top of the list for most risky food. Even when compared at the same level of consumption, leafy greens are several times more risky than raw milk. Some further argue that there are health implications from prohibiting access to raw milk because doing so removes the potential for people to receive the health benefits (discussed below) uniquely associated with drinking fresh milk.

For the last several decades public health officials and food safety scientists have almost exclusively focused on warning and educating people against consuming fresh milk by highlighting safety concerns. Documentary films FarmageddonOrganic Hero or Bioterrorist and Milk War have provided graphic illustration of clashes over raw milk between government agencies on one side and dairy farmers and consumers on the other.

A psychiatric physician attending one of the raw milk seminars at the Rutgers University (Schwartzman, 2010) and well-versed in the dynamics of mass psychology spoke up about how the battle over legal access to raw milk was about much more than just food safety. In his blog (Government vs Raw Milk) he defines and explains a social phenomenon called the emotional plague as originally outlined by Dr Wilhelm Reich. Schwartzman explained: ‘I contend no matter how much proof of safety is presented or what additional information is provided, the government authorities will never relent in their efforts to end sales of unpasteurized milk…The safety of unpasteurized milk and the best interest of the public are not the sole or even primary reason for the government’s attack… In their minds they must stop ‘dangerous’ activities and behaviors, never realizing their prohibitive actions are not really for good of others but rather to make themselves feel better by putting an end to the behavior that makes them intensely anxious. Controlling others makes plague-ridden individuals feel better, at least temporarily.’

Antagonistic campaigns against a farming system are another parallel between the raw milk and organic farming and food movements. When the USDA Secretary of Agriculture, Earl Butz declared ‘Before we go back to organic agriculture, somebody is going to have to decide what 50 million people are we going to let starve’, he dismissed organic as a viable system of farming. Similarly, John F. Sheehan (2005) of the FDA declares that, ‘Raw milk is inherently dangerous’ and that, ‘Drinking raw milk or eating raw milk products is like playing Russian roulette with your health.’ Such statements appear intended to frighten people away from consuming unpasteurized dairy regardless of the carefulness of production.

In spite of such pronouncements from public officials and the interests of agricultural industries and food manufactures, as with certified organic production, farmers and consumers are making personal choices toward a new food movement. Educational campaigns against access to raw milk may be seen as a failure given that demand for pasteurized fluid milk has been steadily declining (Berry and Gee, 2012), whereas the growth in demand for permits to sell raw milk has been described as ‘explosive’. Research and support from the Cooperative Extension System for careful production of raw milk needs to catch up with the educational resources available for the organic system of farming. Publication of the book on Producing Fresh Milk, The Cow Edition(Baars et al., 2015) and Producing Fresh Milk, The Goat Edition (Baars et al., 2017) are examples of educational efforts in this direction.

Policy toward raw milk availability varies widely among countries. In the United States, there are as many different policies and different levels of availability of raw milk to consumers as there are states (Farm-to-Consumer Legal Defense Fund, 2016). In spite of the FDA policy prohibiting transport of raw milk across state borders by farmers, consumers frequently cross borders to procure raw milk. In Canada, raw milk is completely prohibited with the exception of the unsettled gray area of the law where consumers buy into ownership of the dairy farm. In India, Bangladesh and Pakistan, fluid milk is widely available for consumption without processing. Australia strongly prohibits raw milk distribution, while New Zealand permits raw milk sales at the farm. In many European countries, raw milk is widely available as retail sales or directly from dairy farms with the help of raw milk vending machines (Brasch, 2014). What these different levels of restriction or access appear to illustrate is that consuming regulated raw milk does not lead to an overwhelming number of food-related illnesses.

Mainstream attention, policy changes and the role of leadership

Organizations dedicated to teaching people about fresh milk strongly urge that the milk should be produced from pasture-fed animals and not raised in continuous confinement (Gumpert, 2015; Shetreat-Klein, 2016). Large-scale industrial or confinement operations that emphasize high levels of production per animal unit are not perceived to be a good source for fresh milk due to concerns over animal welfare and sustainability. These guidelines are aligned with the USDA-NOP standards that require pasture feeding of animals (Code of Federal Regulations, 2015) and the traditional philosophy of organic dairy farmers to accept less intensive inputs described as a ‘refusing to push the cows’ (Saucier and Parsons, 2014). That fresh milk be produced by a certified organic operation is not necessarily the point, but rather that the dairy uses many organic production practices that serve to enhance milk quality and ensure animal welfare (Baars et al., 2015). Such production practices are assumed to reduce risk but their value and effectiveness need research for validation or further improvement.

Until recently, and after several decades of hostility, agricultural universities and the Cooperative Extension System gave little research support to the organic system of farming (Lipson, 1997). Currently virtually every agricultural university exhibits some level of support for organic farming. In some cases, there are now professors at major agricultural universities dedicated full time to research and educational programs on organic farming.

Yet in more than 100  yr of the Cooperative Extension System, there has been very little effort dedicated to research or training of dairy farmers in the careful production of fresh milk to be consumed without pasteurization. Despite the fact that fresh milk is a legal beverage in all states (at least from a family cow or goat) and can be legally sold from the farm or retail in many states, the Cooperative Extension System has not met its responsibility to be truly transformational in its educational programing by serving fresh milk dairy producers and consumers (Heckman, 2007). Contrary to helping fresh milk dairy farms produce a safer product, with few exceptions (Hoenig, 2014), the focus of the Cooperative Extension System has been warning people of the dangers of drinking unpasteurized milk and driving people away from their personal food choice (Schutz and Ferree, 2012).

Recently, Raw Milk Workshops (20142015) were held at the Penn State University and at the State University of New York–Cobleskill. These notable exceptions may be a sign of some specialists within the Cooperative Extension System accepting a role in the training of raw milk dairy farmers. The workshops objectives were designed to teach science-based food safety principles to help create a secure foundation for the growing raw milk movement. Speakers included veterinarians and experienced raw milk dairy farmers.

As with success in organic farming, innovations with fresh milk production and safety have been associated with working farms, which historically received little to no assistance from agricultural universities and the Cooperative Extension System. One might assume that people will never stop a 10,000-year-old tradition of producing and drinking fresh milk. If anything the number of people choosing fresh whole unprocessed milk appears to be rising in spite of public health agencies discouraging fresh milk drinking.

Other organizations have stepped in to serve farmers and consumers when the Cooperative Extension System fails to provide a necessary service. The historic guidance for the production of Certified Milk by Medical Milk Commissions, the more recent establishment of the RAWMI and educational efforts of the Farm-To-Consumer Foundation, were initiated by actors almost entirely outside of universities and the Cooperative Extension System. In the case of the RAWMI, it was established by Mark McAfee, the owner of the largest organic raw milk dairy in North America.

Agricultural universities and the Cooperative Extension System typically follow the lead of federal authorities. Federal agencies strongly opposed to allowing people to choose fresh milk could potentially reverse direction under new leadership. Such was the case when the Secretary of USDA Bob Bergland decided to take a look at organic agriculture in the 1970s. It was an ‘across the fence conversation’ with a neighboring organic farmer that sparked the talks and surveys between USDA and the organic community (Youngberg and DeMuth, 2013). In 1980, the USDA published its Report and Recommendations on Organic Farming (USDA, 1980).

In the forward of that USDA document, Bob Bergland writes about gaining an understanding of organic farming systems and the need for research, education and communication.

What would happen to the fresh/raw milk movement with a similar change in attitude of government officials?

Several years after passage of the Federal Organic Food Production Act of 1990, the Organic Farming Research Foundation surveyed the USDA’s Current Research Information System for pertinence to organic farming. The findings from that survey were summarized in ‘Searching for the O-Word’ (Lipson, 1997). By revealing a lack of USDA commitment to organic farming research, the report became a catalyst for increasing levels of financial and institutional investment in such work.

The uneven legal status of fresh milk sales within the states and FDA policy may be an even greater hurdle to getting USDA support for research and the Cooperative Extension System teaching on production and safety. Recent trends toward legalization or administrative policies among numerous states are allowing increased access to fresh/raw milk (Kennedy, 2016). Currently there also appears to be a relaxing of restrictions against dairy farmers providing fresh milk. Even more important than research support is the desire among raw milk dairy farmers and the people who want access to fresh milk to simply be left alone and to have their food choice respected (Gumpert, 2013).

Health outcomes, subjective experience and the ‘great subject’

The holistic view of health and nourishment concerning soils, plants, animals and people sets the traditional organic system of farming apart from conventional agriculture. This broad ecological perspective was expressed by Albert Howard (1943) when he wrote about ‘the whole problem of health in soil, plant, animal and man as one great subject’.

Eating food serves numerous health functions, not the least of which is pleasure and satisfaction. In the case of full fat unprocessed fresh milk many people claim to have a different drinking experience (Katafiasz and Bartlett, 2012). Commodity pasteurized and homogenized milk is usually comingled with many farms and processed for consistent flavor throughout the year. In contrast, people consuming fresh milk directly from specific farms can experience the flavors as they vary with the quality of pasture or feed, growing season, geography, animal breed and carefulness of the milking operation (Gumpert, 2015). People who drink and appreciate the flavors and mouth feel of quality fresh milks are every bit as much connoisseurs as those who consume fine wine. The satisfying value and pleasurable experience with artisanal foods such as fresh milk are too often undervalued or ignored by the proponents of industrialized agriculture (Mincyte, 2014). Health benefits are also similarly dismissed and ignored.

When a food is deconstructed and its chemical constituents measured in an analytical laboratory, the nutrient concentrations are itemized but not functionally understood. Studies comparing nutritional composition of organically grown food and conventional food usually stop short of investigating how the food objectively functions in a living organism (Carr et al., 2012), let alone how it subjectively functions. In the case of fresh vs pasteurized milk, nutrient content reports usually acknowledge that pasteurized milk results in some loss of a few nutritional components, such as vitamin C. They may go further and say that milk is not a significant source of such nutrients anyway.

Although nutrient content data can be useful, it does not tell the full story. For example, it does not tell us much of anything about the eating experience and the role that qualitative factors play in health and satisfaction. Surveys have shown that the number one motivation for drinking fresh unprocessed milk is taste (Katafiasz and Bartlett, 2012). This is very important because dietary health benefits can only come from foods people are willing to eat.

Often the personal experiences of health outcomes expressed by people switching from drinking pasteurized milk to fresh milk are not taken seriously. Rather than viewed as preliminary lines of evidence for formulation of hypothesis and follow-up research, the potential health benefits of drinking fresh milk are too quickly dismissed as anecdotal and not worthy of further investigation.

The values of the numerous biologically active factors in fresh milk that are diminished or inactivated by the heating process of pasteurization are reviewed in the report by Michigan Fresh Unprocessed Whole Milk Workgroup (2012). Besides nutrient bioavailability, this report recognizes the valuable role of bacteria in providing prebiotic and probiotic functions, and active enzyme systems that assist digestion. The report also cites studies indicating that drinking fresh milk protects against allergies and asthma. It further notes some people who are not able to drink pasteurized milk have tolerance for drinking fresh milk. Unlike most reviews, this report is unusual in that it acknowledges these special attributes of fresh milk.

Any evidence for health outcomes uniquely associated with consuming fresh unpasteurized milk is typically dismissed with blanket pronouncements. For example, the CDC (Raw Milk Question and Answers, 2017): ‘There are no health benefits from drinking raw milk that cannot be obtained from drinking pasteurized milk that is free of disease-causing bacteria.’

The US FDA similarly plays up the risks and dismisses the benefits. How some public health organizations, community of health professionals and food scientists can ignore the accumulated published evidence on health benefits appears biased or a willful failure of scholarship.

However, it appears that as the scientific literature (showing that raw milk offers unique protection from allergies, asthma and respiratory infections) is made easily available, it can no longer be so blatantly ignored. As an example, in response to political pressure from the state of Maryland, the legislature called upon public health professionals at the Johns Hopkins University for an opinion on raw milk. A published report entitled: A Literature Review of the Risks and Benefits of Consuming Raw and Pasteurized Cow’s Milk (Davis et al., 2014) concluded that ‘there is no scientific evidence supporting the claim that the benefits of raw milk outweigh any health risk.’ While this review did not entirely please the proponents for legalizing access to fresh milk in Maryland, it did review and acknowledge some evidence for health benefits from fresh milk consumption at least for its association with reduced allergies. As may be expected from mainstream sources, the report also strongly discouraged the drinking of fresh milk.

There are many other examples of this narrative that magnifies risks while ignoring, downplaying or dismissing the benefits. While it is extremely difficult to change an establishment position, one approach to shifting the debate is to study a subject in depth and to challenge the experts by exposing the contradictions of their words (Martin, 1996). A few well-informed and vocal critics can spur a movement and sometimes make an enormous difference.

People concerned with making food choices have several options: (1) place their trust in the pronouncements of the ‘experts’, (2) ask a trusted health care professional, (3) read and review published literature and arrive at their own interpretation and assessment, or (4) become knowledgeable about their food choices from real-world experience.

The fourth option is not unlike what farmers and gardeners experience when they decide to implement organic practices on their land. When a farmer transitions away from commercial chemicals to the organic system, they observe the unique qualitative changes in soil properties that result from switching to a biologically based soil fertility system. The special soil properties achieved and the benefits to plants of feeding the soil with complex organic nutrient sources are now well documented and cannot be dismissed as simply anecdotal (Rodale Farming System Trial, 2016). The increases in soil organic matter content, ease of tillage, water infiltration, biological activity, drought tolerance and disease suppression are expressions of soil health typically observed when organic farming is compared with conventional chemical farming (Carr et al., 2012).

The analogy of feeding soil or feeding people with naturally occurring whole biologically active substances is a concept very much in tune with the philosophy of the organic farming movement. The observations on soil health or human health that follow from it may be considered subjective and therefore subject to criticism from the scientific establishment; but for individuals with positive experiences with organic systems nothing matters more or is more convincing than these personal experiences (Padel, 2001). Nevertheless, the organic community also welcomes scientific studies that can provide objective validation for their subjective experiences.

When considering food choice, the third option is the most difficult and time consuming and therefore the least likely path taken. Nevertheless, in service to the stated goal of informed consumer choice, Table 2 outlines the newer as well as the older published literature on health properties and nutritive values associated with fresh unprocessed milk in contrast to pasteurized milk. This listing includes studies and literature references (drawn from the extensive collection described in the Methods section) that include both human milk as well as that of other lactating animals.

Table 2. Literature summary on health and nutritional responses associated with raw or heat treatment of animal milk and human milk. The listed studies generally refer to bovine milk unless indicated to be human milk. [reformatted for legibility, posted in three parts – see original Table 2]

The body of scientific literature comparing fresh milk vs heat-processed milk suggests that health outcomes are often different (Table 2). The evidence is based on animal as well as human feeding trials using cow milk or human breast milk. It generally shows that when milk is heated, some of the nutritive qualities are diminished; weight gains and growth are often less with heat-treated milk. The more recent studies indicate that consuming fresh milk helps protect children from allergies, asthma and respiratory infections (Waser et al., 2007; Braum-Fahrlander and von Mutius, 2010; Loss et al., 2011). The literature also notes that unpasteurized milk has immunologic factors and anti-microbial properties that decrease when heat treated (Loss et al., 2015; McCarthy et al., 2015).

There are also some studies reporting no meaningful differences when comparing raw vs pasteurized milk for lactose tolerance (Mummah et al., 2014), protein quality or mineral availability (Weeks and King, 1985, and Zurera-Cosano et al., 1994). On balance, however, many studies provide evidence of health benefits associated with milk consumed fresh.

In spite of the acknowledged evidence for improved health outcomes from consuming raw milk, authors of such studies apparently feel compelled to incorporate a personal opinion against drinking fresh milk due to the potential presence of pathogens (Waser et al., 2007; Loss et al., 2015). They also call for further research on finding, isolating or preserving the protective components of fresh milk (Perkin, 2007; Waser et al., 2007). This approach would seem to be at odds with the whole natural foods philosophy of traditional organic food systems. What is missing from their recommendations is a pursuit of research and education for dairy farmers on how to improve the quality of fresh milk and its production practices.

Until recently, the organic farming systems received only very limited research and educational support from agricultural universities. The increasing abundance of organic food in the market place shows that organic farming can function as a viable system of food production with or without the help of institutional support. In a similar fashion, researching ways to reduce risks and improving production practices may enable more people to consume wholesome fresh milk without pasteurization and receive accompanying health benefits.

Published scientific literature is always open to interpretation and continuous reinterpretation in the context of current science. From the summary (Table 2) and reference list, ‘citizen scientists’ willing to make the effort can more quickly find pertinent literature and read and interpret it for themselves for the purpose of making an informed food choice.

Policy impacts on soil fertility, sustainability and health

The pioneers of the organic farming movement placed great emphasis on health in connection with soil fertility. Howard (1943), for example, wrote of a ‘great linkage between the soil, the plant and the animal.’ and furthermore declared that ‘Soil fertility is the basis of the public health system of the future’ (Howard, 1972). The authors (Baars et al., 2015) of the book on Producing Fresh Milk, The Cow Edition would agree with the organic farming concept that mineral-rich fertile soils are one of a large number of factors promoting healthy dairy animals and enhanced quality fresh unprocessed whole milk.

Albert Howard (1972) was also very much cognizant of the function of livestock on soil fertility when he wrote that ‘Mother nature never farms without live stock….’ Cows as part of the farm ecosystem are effective transformers of relatively low nutrient density forages into nutrient-rich foods with fat-soluble vitamins, proteins and energy-dense fats (Heckman, 2015). On dairy farms, there is a flow of soil fertility through the cow (Bear, et al., 1946). Although cows do extract a fraction of the minerals from their feed to make milk, the larger fraction of the minerals contained in feeds and forages are recycled back to the land through manure application.

Pasture-based dairy farming systems are one of the most effective ways to build soil organic matter content and soil fertility in general (Heckman, 2015). This organic fraction of the soil is a valuable storehouse for carbon, nitrogen, phosphorus, sulfur and other plant nutrients. Pastures under organic management are ideally a mixed stand of legumes and grasses. This diverse mix enables a farm to be self-sufficient in nitrogen. This biologically captured nitrogen as part of a well-designed crop rotation is supportive of an entire organic farming operation. In this way, pasture and perennial forage crops are foundational attributes of an effective organic farm plan.

Whether organic milk from a dairy farm is provided directly to consumers as fresh milk or as pasteurized milk makes little difference in terms of how soil fertility functions on the farm. However, milk policy can have a huge influence on the number, size and distribution of dairy farms and thereby sustainable soil fertility.

Dairy farms in the business of providing fresh milk directly to consumers are typically smaller operations with a local community of patrons. These dairy operations employ many organic farming practices. This is in large part due to the preferences of fresh milk consumers for organic production systems, especially pasture feeding. A recent study (van Asselt et al., 2015) on dairy farming in the Netherlands concluded that ‘raw organic milk is more sustainable than pasteurized organic milk’ and furthermore that ‘it is also more sustainable than pasteurized conventional milk due to a higher revenue’. Where policy supports production and trade in fresh milk, more farmers are likely to enter the business of producing fresh milk. Thus, more pasture-based dairy farms would contribute to more land area under sustainable soil fertility management.

As a case study, the state of New Jersey illustrates the impact of food policy on soil fertility. By law New Jersey currently prohibits distribution of raw milk by dairy farmers. However, there is no law against sales of raw vegetables directly from farms. Consequently, New Jersey has numerous small vegetable farms; but for dairy farming, there is no practical legal avenue for direct marketing of fresh milk. Consequently, fresh milk drinkers source this special food choice from neighboring states where sales are permitted. An estimated $95 million in revenue leaves New Jersey annually, which goes to support out-of-state fresh milk dairy farms (Heckman, 2014) rather than local farms.

Where New Jersey once had thousands of small dairy farms spread across the Garden State, less than 70 remain. Among states in the Northeast USA, New Jersey obtains a relatively small (12%) percentage of its agricultural revenue from livestock. Thus, looking at New Jersey as an example, it may be argued that the legal status of milk policy nearly precludes the viability of small dairy operations and the sustainability of local well-distributed soil fertility ecosystems that would naturally follow the dairy cow.


The raw milk movement has been associated with the organic farming movement since its inception. Walter Northbourne, the first person to write about organic as a system of farming, correctly characterized the emerging problems not only of agriculture, but of fresh food systems. He explained that just as industrialization of farming lead to erosion and destruction of soil on a massive scale, the ‘vast distributing concerns’, ‘specialization’ and the phenomenon of ‘infection in bulk’ created the need for milk pasteurization, and that this heat process degraded the quality of a fresh whole food.

The organic dairy farming community in ‘refusing to push the cows’ is pursuing natural alternatives to industrial confinement production by emphasizing the feeding of dairy animals outside, in sunshine and on pastures grown on fertile soils. In this system, organic farmers are willing to accept lower productivity for healthier cows, higher quality milk, economic sustainability and happy feedback from fresh milk consumers. Agricultural universities and the Cooperative Extension System reluctantly joined in with research and teaching of organic food and farming systems as they slowly became accepted and moved into the mainstream. These same institutions have an opportunity to become a positive force in reinventing dairy farming and restoring the ecology of this traditional food and farming system.


The research reported in this publication was supported by the Rutgers New Jersey Agricultural Experiment Station. The author thanks Mark Keating for valuable suggestions and Theresa Lam for organizing the literature search.


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