Response to the Northern Illinois Public Health Consortium, Inc.

April 10, 2014

Response to the Northern Illinois Public Health Consortium, Inc.
Prepared by the Weston A. Price Foundation

In a letter dated March 24, 2014, the Northern Illinois Public Health Consortium, urged support of HB 4036 HA1, which would ban the thriving raw milk business in the state of Illinois. The Consortium provided the following “Supporting Facts,” followed by our response.

CONSORTIUM ASSERTION: The Centers of Disease Control and Prevention (CDC) and the U.S. Food and Drug Administration claim that raw milk may contain a wide variety of harmful bacteria—including Salmonella, E. Coli O157:H7, Listeria, Campylobacter and Brucella—that may cause illness and possibly death.

WAPF RESPONSE: The fact is, ALL foods may contain these bacteria. Actually, there has never been a case of listeria, the most dangerous of these pathogens, from raw fluid milk. If the state of Illinois banned all foods that could contain these harmful bacteria, there would be no food to eat in the state of Illinois (and that includes pasteurized milk and pasteurized milk products).

Government statistics show us that the rate of illness from raw milk is very low. According to a 2007 CDC survey, about 3 percent of the US population consumes raw milk; in 2014, this is at least 10 million people. CDC data indicated that there are approximately 50 illnesses associated (but not proven) from raw milk every year. (The majority of these are mild, and this number is probably over-reported.) Thus, using government data, we can show that the rate of illness from raw milk is .000005 per year. So there is no reason to single out raw milk as an inherently dangerous food. Many foods allowed on the market have a much greater rate of illness.

Unlike other foods, raw milk contains enzymes and other compounds that kill bad bacteria (and support the growth of good bacteria). No other food contains this protective system; these components are destroyed by pasteurization. Under very dirty conditions, this anti-microbial system can be overwhelmed; but in situations of reasonable cleanliness and good health of the cows, these enzymes ensure that raw milk is a safe food for children and adults.

CONSORTIUM ASSERTION: Because of the potential for serious illness, federal law prohibits dairies from distributing raw milk across states lines in final package form (packaged so that it can be consumed), meaning that raw milk can only be distributed across state lines if it is going to be pasteurized or used to make aged (over 60 days) cheese before being sold to consumers

WAPF RESPONSE: There are two bills in Congress at the moment to overturn this ban; but in fact, raw milk is pouring across state lines because the law is unenforceable. Plenty of raw milk is coming into the state of Illinois from other states. If Illinois were to ban the sale of raw milk, it would merely put a lot of Illinois family farms out of business and enrich raw milk farmers in other states.

CONSORTIUM ASSERTION: Each state makes its own laws about selling raw milk within the borders of the state; in about half of states, sale of raw milk directly to consumers is illegal, and in the remaining states, raw milk may be sold directly to consumers.

WAPF RESPONSE: Forty out of fifty states allow the distribution of raw milk through sales or cow-share programs. Of these, ten allow the sale of raw milk in retail establishments. There are more than two dozen current state bills that would liberalize the distribution of raw milk on the state level. The proposed legislation in Illinois is retrograde, going in the opposite direction of the increased support for raw milk sales. This is a market that is growing at 25 percent per year, and the proposed legislation would take this away from Illinois farmers and give it to farmers in other states.

CONSORTIUM ASSERTION: States that allow the legal sale of raw milk for human consumption have more than twice the rate of raw milk-related outbreaks of illness than states that do not allow the sale of raw milk.

WAPF RESPONSE: This “fact” was arrived at by defining an “outbreak” as two or more people. When people do get sick from raw milk (which is rare), the outbreak is usually limited to a few people. When people get sick from pasteurized milk, it often affects thousands. A recent outbreak in a California prison due to pasteurized milk sickened over fifteen hundred people. Outbreaks from pasteurized milk in the 1980s sickened tens of thousands. What matters is the NUMBER of people getting sick, not the number of outbreaks, and far more people have become sick from pasteurized milk and pasteurized milk products than from raw milk

And what is key is the number of deaths. There have never been any deaths from raw milk, but dozens from pasteurized milk and pasteurized milk products. Three people in Massachusetts died from pasteurized milk in 2007. And since 2007, about one dozen people have died from pasteurized cheese.

CONSORTIUM ASSERTION: The rate of outbreaks caused by raw or unpasteurized milk and products made from it was 150 times greater than outbreaks linked to pasteurized milk, according to a study reviewing dairy product outbreaks from 1993 to 2006 in all 50 states, published by CDC in March 2012.

WAPF RESPONSE: As stated above, by looking at “outbreaks” rather than absolute numbers, CDC was able to generate a large comparative number. Also, this study compared “raw milk AND raw milk products” to just “pasteurized milk” and not pasteurized milk products. Most of the problems with raw milk come from unregulated soft Mexican-style cheeses. And there have been many outbreaks and a few deaths from pasteurized cheese.

CONSORTIUM ASSERTION: Among dairy product-associated outbreaks reported to CDC between 1998 and 2011 in which investigators reported whether the product was pasteurized or raw, 79% were due to raw milk or cheese; from 1998 through 2011, 128 outbreaks due to consumption of raw milk or raw milk products were reported to CDC, which resulted in 2,384 illnesses, 284 hospitalizations and 2 deaths.

WAPF RESPONSE: Again, by reporting outbreaks rather than actual numbers, CDC can create the impression that raw milk is causing a disproportionate number of illnesses. The two deaths were from unregulated soft Mexican-style cheese; there has never been a death from raw milk.

Note that this study only involved “outbreaks. . . in which investigators reported whether the product was pasteurized or raw.” In most outbreaks involving pasteurized dairy, investigators do NOT report that the milk is pasteurized; they just say “milk” or “cheese.”

Also, when a person goes to the hospital with a food-borne illness, the first question asked is “Did you drink raw milk?” If the person answers yes, he or she is immediately admitted and no further questions are asked. Thus, many illnesses attributed to raw milk are likely coming from other sources.

CONSORTIUM ASSERTION:  It is important to note that a substantial proportion of the raw milk-associated disease burden falls on children; among the 104 outbreaks from 1998-2011 with information on patients’ ages available, 82% involved at least one person younger than 20 years old.

WAPF RESPONSE: This statement does not give us absolute numbers of young people and adults. We do not know the numbers involved in the “outbreaks” and we do not know the percentage of young and adults that were afflicted.

CONSORTIUM ASSERTION:  The number of reported cases determined to be outbreak-related likely represents a small proportion of the actual number of illnesses associated with raw or unpasteurized milk consumption

WAPF RESPONSE:  On the contrary, the number of raw milk illnesses is likely OVER reported. If any person drinking raw milk gets sick, that illness is blamed on raw milk without further investigation.

CONSORTIUM ASSERTION: The American Academy of Pediatrics approves a ban on the sale of raw or unpasteurized milk and milk products throughout the United States.

WAPF RESPONSE:  The American Academy of Pediatrics also recommends a low-fat diet for growing children, a policy that has had disastrous results, causing an epidemic of disease in our children. The AAP also promotes overuse of antibiotics for childhood illnesses. The AAP approves a vaccination policy that gives 36 shots to a child before the age of 5, starting at 2 days old. Why should we trust the AAP when they are recommending such dangerous health policies for our children?

CONSORTIUM ASSERTION: Illinois law prohibits the retail sale of raw milk, but allows on-farm sales with untracked distribution

WAPF RESPONSE: This policy has worked very well to date, allowing access to raw milk for those who want it, good income for Illinois family farms, and little burden on the state bureaucracy.

CONSORTIUM ASSERTION:  Unpasteurized dairy products may currently be obtained in Illinois through private food clubs, co-ops or under a communal program to purchase shares in dairy cows (i.e. cow shares, a scheme used to circumvent state restrictions on commercial sales of non-pasteurized dairy products).

WAPF RESPONSE: If Illinois bans raw milk sales, all the raw milk that the citizens of Illinois consume will come from private food clubs, co-ops or cow share programs from neighboring states. All the ban will do is hurt Illinois farmers.

CONSORTIUM ASSERTION:  Human consumption of non-pasteurized dairy products cannot be considered safe under any circumstances.

WAPF RESPONSE: Humans have been consuming raw dairy products to great advantage for thousands of years; raw cheese is legal and available in every state and throughout Europe. Is the state of Illinois seriously considering banning raw cheese sales also?

The state of Illinois needs to ask why more and more people in the state are consuming raw milk. The answer is the superior taste; better digestibility and numerous proven health benefits including protection against asthma, allergies and eczema, improved growth in children, strong bones and teeth, and improvement of serious conditions such as IBS, Crohn’s disease, attention deficit disorder and autism. Very often raw milk is the ONLY solution to failure to thrive in children.

For more information:

The Weston A. Price Foundation is a 501c3 nonprofit based in Washington, D.C.


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