Numerous Errors and Misstatements Demonstrate Agency’s Rush to Judgment Against Nature’s Perfect Food
June 17, 2008
WASHINGTON — A Center for Disease Control and Prevention (CDC) report [www.cdc.gov/mmwr/preview/mmwrhtml/mm5723a2.htm] issued June 13, 2008 has been carefully crafted to implicate raw milk from Organic Pastures Dairy in California (“Dairy A,” OPDC) with six cases of E. coli O157:H7 illness. The illnesses occurred at the height of the California E. coli outbreak associated with contaminated Dole brand baby spinach, which resulted in over 200 cases and three deaths.
According to the CDC report, raw dairy products from the dairy were allegedly associated with two hospitalizations and four additional illnesses yet the report itself contradicts this conclusion. To begin, the report noted that the alleged outbreak strain of E. coli O157:H7 that was found in the children was not found in any of OPDC’s samples. Also, the report admits that no E. coli was found in any of the environmental samples collected at the milk plant. Moreover, the report states that samples from three heifers yielded a different strain of E.coli O157:H7 yet the report fails to state that those three heifers were not even producing milk at the time. Nevertheless, the CDC sought to place blame on the dairy products because some of the product samples contained somewhat elevated counts of beneficial bacteria, which are destroyed by pasteurization..
“This is another in a long line of examples of raw milk serving as the whipping boy for other foods known to cause disease,” says Sally Fallon, President of the Weston A. Price Foundation, a non-profit nutrition education foundation that promotes the consumption of raw milk from pasture-fed cows. “There is no credible proof that raw milk caused illness in these children. Government officials should be focusing on the known vectors of the rare form of virulent E. coli, such as leafy greens and hamburger from cows kept in filthy confinement operations.”
“The CDC official Report and the accompanying editorial were very carefully crafted to shed the worse possible light on raw milk,” says Taaron Meikle, president of the Farm-to-Consumer Legal Defense Fund. “CDC, either deliberately or out of ignorance, omitted several important facts and made a number of unsupported assumptions. For example, many of the samples were taken from products approaching their expiration dates on retail shelves and therefore would be expected to have higher bacteria results. Raw milk beneficial bacteria counts grow over time because raw milk is a live food containing bacteria similar to the bacteria in yoghurt. The CDC and HHS [US Department of Health and Human Services] say this is evidence of contamination. However, these agencies do not consider the presence of beneficial bacteria in yoghurt as evidence of contamination.”
The CDC report noted that one of the children ill with the rare virulent strain of E. coli did not consume raw milk products. No information is given on other likely vectors of disease in the children, such as contaminated water or spinach. In fact, both children had consumed spinach prior to the illness. By omitting data on other possible vectors of infection, the CDC was able to impute cause and effect based on a mere association of raw milk with illness. As a California health official admitted at recent raw milk hearings, an association is not the same as a proven cause.
As an example of governmental rush-to-judgment mentality, the CDC report mis-identifies the gender of one of the hospitalized children. “Government anti-raw milk forces have an ideological preference for conclusions rather than facts,” says Fallon.
The two children who became gravely ill with HUS (Hemolytic-uremic syndrome) and were subsequently hospitalized had been treated with antibiotics, even though they had armbands warning against such treatment, another fact omitted in the CDC report. Antibiotics are expressly contraindicated in cases of E. coli O157:H7 as they cause an overload of shiga toxin, which can result in kidney damage.
There were no other reports of illness in Organic Pasture’s 40,000 raw milk customers. If raw milk from the dairy had contained the pathogen, many consumers would have become sick.
Shortly after the reported illnesses, the State of California quarantined Organic Pastures raw milk products. Recognizing their error, they lifted the quarantine one day later but waited another eight days to release the products. Organic Pastures subsequently received a settlement from the State of $11,700 for loss of product as the state had no proof that raw milk had caused the illnesses.
In 2007, the FDA posted similar claims about Organic Pastures raw milk causing this outbreak, but the agency later removed the statements after a representative of the dairy pointed out the false nature of the allegations.
The CDC report makes no mention of the many other foods that have caused over 30 serious outbreaks of E. coli O157:H7 since 1982, including beef, sausage, orange juice, lettuce, spinach, tomatoes and water, outbreaks that sickened large numbers of people. The agency makes no categorical recommendation to avoid all such products for all time as it does with raw milk. “This double standard against raw milk has a long history,” says Fallon. “We find this bias in virtually all the published reports of illness reputedly caused by raw milk.” (For additional examples, see Response to the FDA: A Point-by-Point Rebuttal to the Anti-Raw Milk PowerPoint Presentation by John F. Sheehan)
The most serious unwarranted CDC allegation is the claim that stricter coliform limits could have prevented the outbreak. Such a claim is simply not true. There is no relationship between the presence of a coliform and the presence of a pathogen. In recent California courtroom testimony, highly qualified experts in microbiology and disease testified that low coliform standards are not an effective way to control pathogens in raw milk and that a much better standard of safety is direct testing for pathogens. Moreover, experts from the State of California even admitted that milk which is low in coliforms could be high in pathogens, or high in coliforms with no pathogens present. Finally, all the experts agreed that if coliforms are present in raw milk, they will double at room temperature in only 20 minutes. In fact, in raw milk, the absence of coliforms can make the product more vulnerable to pathogens. Thus, CDC findings do not support the conclusion “that if raw milk had been subject to the same coliform standard as pasteurized milk in California, milk from dairy A (OPDC) might have been excluded from sale and this outbreak might have been averted.”
Even though pasteurized milk must meet the 10-coliform standard, there have been many outbreaks of illness caused by pasteurized milk, including an outbreak of Listeria monocytogenes from pasteurized milk in 2007, resulting in three deaths in the state of Massachusetts. “A strict coliform limit does not guarantee protection against pathogens,” says Meikle.
In 2007, without hearings or debate, California passed AB 1735 mandating a 10-coliform limit for raw market milk, the same standard used in pasteurized milk as a test for successful pasteurization. This impossibly low standard will have the effect of putting California’s two raw milk dairies out of business.
On June 9, California State Senator Dean Florez, together with Senator Perata and Assemblymember Berryhill introduced Senate Bill 201, “The Fresh Raw Milk Act of 2008,” which would replace AB1735 with a more rational standard for raw milk safety. The emergency bill mandates a HAACP plan for raw milk dairies and frequent testing for pathogens. A hearing before the Assembly Health Committee is scheduled for June 24 at 1:30 pm in Room 4204 at the State Capitol.
The Weston A. Price Foundation is a 501(c)3 nutrition education non-profit, dedicated to fostering a return to nutrient dense foods and traditional farming methods, such as raising livestock on pasture. The Weston A. Price Foundation is based in Washington DC and has 400 chapters and 10,000 members worldwide, the state of California is its largest base of support with 25 chapters and 1,185 members statewide.
The Weston A. Price Foundation
California Real Milk Association (CREMA)