Safety Regime for a Small FarmDecember 23, 2006
Don’t Let Your Herdshare Agreement Land You In CourtJanuary 27, 2007
By Tim Wightman
I had the privilege to attend the 93rd annual conference of the International Association for Food Protection (IAFP), August 12th through 16th in Calgary, Alberta, Canada, thanks to sponsorship from the Weston A. Price Foundation and courtesy of an invitation from one of the organizers, Ron Schmidt from the University of Florida. My participation marked an historic first–the first time that a proponent of raw milk was represented at this conclave of conventional food processors and health officials. In fact, I was joined by another advocate of raw milk, Claudia Coles, Food Safety Program Director from Washington State.
Most of the 3000 members of the International Association of Food Protection (IAFP) members were there to discuss and compare new technologies in the detection and surveillance of food-borne pathogens in the world’s food supply. Industry manufacturers of testing supplies and protocols were well represented in the exhibitors hall. University faculty and state and federal government officials were also present.
I was invited to present the consumer-producer side of the raw milk issue in a round table discussion. My invitation to participate grew out of the growing pressure in certain states to pass laws in favor of raw milk sales.
The Conventional View
The IAFP is the premier association that government officials look to in order to set up food safety nets that protect the public from food-borne illness and create safeguards within the processing industry. Representing the conventional view, this group has long advocated pasteurization of milk, as the officials in this organization know that a certain percentage of herds are infected with numerous pathogens that will lead to illness when consumed by humans.
While walking around the exhibit hall I was treated as a regular Joe Attendee and was able to talk with a great many of the premier food safety specialists from around the world. But I was only able to talk to the English-speaking contingent extensively, which I found out was the only group of attendees that had a problem with the general consumption of raw milk.
Members from nations whose language is other than English and with whom I spoke a little, told me that raw milk was not an issue with them. They had other things to gain control over and did little or no testing of raw milk or raw milk products within their countries. Granted some of those countries did not have the volume of consumption as we do in the U.S., nor did they have the size and range of milk processing. Most of their raw milk was still produced on small farms, or by a herder with few animals with local distribution and processing, mostly for cheese making.
But when talking to representatives in the industry, and by industry I mean government, universities and the industry doing tests and developing tests in Canada, the U.S. and Australia, I heard a lot about the dangers of raw milk. But when digging further into the results of those tests, I found a common thread within the information and the results put forth as fact. Most if not all the tests, safety recommendations and contamination percentages of raw milk, as it is currently known to food safety professionals, came from large confinement dairies and large scale processors.
Raw Milk in the Wings
I got little or no information about testing of raw milk from small scale farms until I talked with a graduate student from the University of Vermont (UV). His department is currently studying the infection rates of raw milk cheeses produced within the state over a period of two years. The study has gone on now for six months with a total of eleven small farms, ranging in size from four to fifty cows, including goat and sheep dairies. All these farmers have raw milk cheese permits with the state of Vermont. UV is testing milk from these farms weekly for four pathogens– Listeria monocytogenes, Salmonella spp, E-coli O157H7 and Staph aureus–as well as the general Grade A tests of SCC, plate count, PI and coliform tests.
For the first 24 weeks, no pathogens have been found in any of the tests. That’s eleven samples of raw milk a week times the four pathogen tests for a total of 1056 tests, with no pathogens found.
The farmers whose cheese is being tested are given the results of the Grade A standards tests within the week they are taken and have complimented UV on its promptness of test returns. Any sanitation problems that arise are found much quicker this way, and as a result, maintenance is performed immediately instead of waiting the usual month between tests to monitor the milking equipment, which is standard Grade A practice.
A second common thread emerged as I chatted with attendees: most of them, as many as 80 percent, currently drank raw milk or grew up on it as a child. Most would quickly qualify the statement by saying that it was safe for them to drink raw milk from their own cows because they had done so all their lives, but that they would have a problem drinking raw milk from “somebody down the road.” Most talked reverently about the wonderful taste, delicious cream and what you could do with it, and how they as kids never seemed to be sick. Yet after the glow faded there was always the qualification, “Well I’m sure you do a good job on your milk but I have seen many who do not.”
As time neared for the roundtable discussion, I was greeted by the moderators and organizers: Ron Schmidt from the University of Florida, Gainesville, and Allen Sayler, Senior Director, Regulatory Affairs and International Standards for IDFA as well as Director of the International Dairy Food Association, member of the National Cheese Institute and the International Ice Cream Association.
They introduced me to the other panel members, which included Claudia Coles representing Washington state and the U.S. regulatory perspective; Re’jean Brossard of Ag Canada for the Canada regulatory perspective; Carolyn Smith Dewaal of the Center for Science in the Public Interest who gave their perspective on the consumer; and Bill Marler, lawyer of Marler Clark, which specializes in food-borne illness outbreak law suits.
I had time to talk with Ms. Coles at length about many issues regarding raw milk and milk safety and I was pleased to find out we were not very far apart on the issue. Ms. Coles has been dealing with raw milk for fifteen years and has proved that a farmer can, under her state-authorized program, hand milk cows and maintain safe milk. Through the Washington state testing regime, she has proven that raw milk can be produced more safely by hand than raw milk coming from Grade A facilities she oversees.
The main theme that was present in the pre-roundtable discussions was safety for the farmer and the consumer, and protecting the good name milk has “as a cornerstone in a healthy diet.”
In my discussions, they were glad to hear of the testing I endorsed and encouraged to assure a safe product, and the responsibility taken by those I worked with to assure that the milk and environment was clean via a HACCP plan based on common sense and traditional husbandry, backed up with the industry’s own testing protocols. I think that threw them off balance for they were expecting to hear the extremist view point of “leave me alone, this is my right and not any of your business!” They told me several times of instances of that very nature. I was actually surprised to hear from many just how close we were to being on the same page.
Gasps and Shock
The main roundtable discussion began with Allen Sayler presenting what the industry knew of the Weston A. Price Foundation and what consumers are led to believe raw milk can do for them, and “why in the world would the Association take ninety minutes out of its schedule on an issue such as this.” The answer: “We all know the problems, yet a growing number of people want raw milk because they believe. . .”
And then it got a little ugly. Gasps and shock met Sayler’s presentation of WAPF claims that raw milk could reduce asthma, help with weight loss, increase bone density, reduce cholesterol and could safely be fed to infants and old people. The response from the participants was that these claims were being made without their verification standards, leading people to consume a product rife with pathogens and putting them in mortal danger.
Then it was Claudia Coles’ turn. She gave a quick overview of raw milk programs in various states before getting to the heart of the matter. The great state of Washington allows the sale of raw milk and has seen an increase of raw milk permits from 15 to 60 over the last eight months. Gasps and awe again from about 100 or so people in the audience. Claudia went on to say that she could not, from verified experience and industry testing methods, say that all raw milk was bad–she had the documentation and years of experience to prove the safety of raw milk and has overseen the safe production of raw milk for nearly ten years.
Next up, Re’Jean Brossard from Ag Canada in less than three minutes said Health Canada and Ag Canada has not and will not ever allow the sale of raw milk.
Next to speak was Carolyn Smith Dewaal from CSPI. Ms. Dewall outlined consumer trends regarding raw milk but provided no statistics on the numbers of raw milk consumers. Carolyn remarked that the only information she was able to find was the increase in reports of illness due to raw milk consumption over the past six years, although she did point out that people often confuse organic milk with raw milk. She also emphasized that the Center for Science in the Public Interest does not endorse raw milk consumption and presented some charts showing dairy product-related outbreaks over the last 15 years: according to the Centers for Disease Control statistics, 165 people were involved in unpasteurized milk product outbreaks in the U.S. and 5530 people were involved in pasteurized milk product outbreaks.1 Unfortunately, the graph Dewaal presented did not indicate incidents per serving, which would have given a better clue to the risks involved in both kinds of milk.
Ms. Dewall did expand on the consumer movement towards knowing where our food comes from and the explosion of interest in organics. CSPI believes that the raw milk movement is a part of this greater movement, of consumers needing to know and trust the source of their food. CSPI endorses better production and processing practices to ensure the safe delivery of wholesome food to the consumer.
Next it was my turn. I started out telling the crowd that raw milk was a consumer-led movement, and that people were coming to the farmer for the product. As a farmer, I responded to that demand, and did not start providing raw milk as a way to generate income. I briefly explained the battle with the state of Wisconsin and its resulting farm share agreement where I formed a company with the farm assets to allow purchase of shares in that company. These shares, bought in complete disclosure, allowed share holders to receive milk from the farm and in turn pay a service fee for the work performed to produce the product.
I also mentioned the thousands of farmers I have talked to who are experiencing the same demand and are responding to the needs of the consumer.
I shared the view as a person directly responsible for the very life of those for whom he produces and thanked them for the testing programs I ran on my farm, with no pathogens found over three years of testing. I mentioned how these increasingly sensitive tests have proven what raw milk drinkers have thought and experienced about the safety of raw milk produced on small, grass-based farms.
Although I did not have the knowledge or the time to address the science behind the claims that raw milk helps cure many diseases, I did say that my experience as a farmer, hearing the benefits of raw milk, is not the same as the experience of a food safety professional. All I know is that people’s health improves, vitality is regained, children thrive and are seldom sick, medications are reduced or eliminated altogether–these plus multitudes of other conditions reported by every farmer and raw milk consumer I talk to from around the world.
I explained it was not up to me to determine when people came to me whether they are motivated by religious belief, personal experience, pleading by a friend to give it a try to turn around a condition unrelieved by any other treatment, or because they are sent home to die after a long and extensive cancer treatment.
I also mentioned that I personally have seen my animals’ condition and vitality improve by providing a diet closer to that which they were meant to eat.
As a layman, I would think the same result would happen in humans, yet my only duty as a person who feeds other people is to make sure I do the best job possible to create a safe product.
“There are those who say raw milk can cure all that ails you,” I told them. “Some insist that the state has no right in the business of the home. I can only relate what I know from my experience: from your testing protocols I have proven that raw milk can be produced safely and routinely from a 36-cow herd. I also know it can be produced safely from a 100-cow organic grass-based herd.
“Trust in the product but verify,” I cautioned. “Everything else is up to the individual consumer.”
A Lawyer’s View
Next to speak was Bill Marler. As the prominent lawyer who sued Jack-in-the-Box over contaminated meat, Mr. Marler explained the reasoning behind the chain of responsibility in law suits and who would be responsible for a raw milk outbreak. According to Marler, it would be the parents, the farmer, the creamery the farmer is under contract with, the foundation or association that encouraged the farmer and/or the parent who purchased the product that caused the infection in a family member. The blame would be put on everybody who came in contact with the product, he insisted, rather than on any specific area of breakdown in the handling of the milk or the herd health.
Mr. Marler went on to explain it was only a matter of time before cowshares and or farmers would be brought to court, as well as the foundations or associations that promote the product. Yet, during the past few years, as raw milk has become more popular, no sickened individual and or individuals have come forth to sue anybody in relation to any alleged raw milk-caused outbreaks.
Marler never discussed the chain of safety–why are these pathogens present in milk from some sources and where are they prevalent, at what point do they begin to take prevalence, what is their source?
The question-and-answer portion went very well with most questions directed to me or the lawyer. There were many questions about cow-share agreements and there seems to be a movement by state agriculture agencies to abolish them, based on questions coming from state officials in the audience.
I pointed out that I was one of the first to test the cow-share model in Wisconsin, that cow shares can work, but other forms of ownership allow more involvement of the consumer with the farm–involvement which I felt was needed to assure that small farms stay around when besieged by increasing pressure from many sides. There were also many questions about my testing regime.
After the question-and-answer session, attendees mulled around the commons and most greeted me with thanks and handshakes, acknowledging my bravery for being at a conference of food safety professionals. Some offered advice of additional insurance, and others just wished me well.
As I spent more time in the exhibition hall, I posed more questions to a few academics and industry personnel. Just where do these bugs come from? Who is looking for the source of these pathogens? At what point do pathogens get out of hand? At what size does the facility or the group of animals lose the ability to suppress the bugs that cause 76 million cases of food-borne illness each year in the U.S. alone?
The answers I got were: “We only look where we are paid to look;” “Small farms are an insignificant number to do valid tests on and usually not close to testing facilities;” “There are too many variables to understand the cause;” “We only perfect the ability to keep it out of our food source, that’s why I like irradiation so much;” and “We knew years ago that raw milk is unsafe so why look at it again?”
The graduate student from Vermont, being the young turk and as yet unjaded, said it best: “Research follows money and companies need protection from lawsuits. We try to provide that by studying that which puts them at risk. We now are trying to find out where milk gets contaminated to reduce the risk of contamination in raw cheese. Eleven farms, six months of weekly testing and I haven’t found anything yet.”
It is extremely important that we continue the discussion among both sides of the raw milk issue, to alleviate extremist viewpoints that both sides have of each other. They need to hear our arguments and testimonials so that slowly the conventional view of raw milk can change. My participation in the conference was an important first step in making this happen.
1. Almost certainly, the figure of 165 includes the 75 or so said to have come down with campylobacter infection, blamed on raw milk produced by my farm Clearview Acres in 2002. Although these statistics dwell on the CDC website, lab tests found no pathogens in my milk. Actually, as many as 800 people became sick during the outbreak, only a few of whom consumed raw milk. The source of infection was likely underdone hamburger for sale in restaurants and grocery stores in the northwest Wisconsin area. See 14 JUL 2002 press release, Wisconsin Campylobacter Outbreak Falsely Blamed On Raw Milk.
What They Test for in Raw Milk
- Specific Pathogens: Testing requirements vary by state. Listeria monocytogenes, Salmonella spp, E. coli O157H7 and Staph aureus are considered the most dangerous.
- Somatic cell count or SCC: White blood cell count present in the milk. This indicates the general health condition of the udder and levels of mastitis infection, as well as indications of overall cow health and environmental pressures affecting the animal.
- Plate count: Indicates the overall cleanliness of milking equipment and the bacteria levels within milking equipment.
- Preliminary Incubation (PI): This is a test of a family of equipment bacteria that grow in cold temperatures. They are non harmful to humans but they shorten the shelf life of the milk.
- Coliforms: A test for general air and ground-borne Coliform bacteria (E. coli), which gives a good indication of the cow prep prior to milking and the quality of the environment the animals in question are exposed to.
My Safety Regime for a Small Farm
- Somatic cell count less than 300,000 on yearly average. My levels are under 200,000.
- Plate count less than 10,000 p/mL. Mine routinely ran 1000 or less.
- Coliform count less than 10 p/mL. Mine was always less than ten.
- PI count less than 50,000 p/mL.
- Johnes-free herdwith 100 percent of herd tested.
- TB-free herd.
- Brucellosis vaccination for heifers between four to eight months. All purchased cows meet same requirements before brought on farm.
- Pathogen tests monthly of E-coli O157H7, Salmonella, Listeria monocytogynes, and Campylobacter for a period of six months then drop to quarterly tests.
- Monthy bulk tank cultures that identify mastitis types, equipment bacteria, as well as environmental contamination the cows are exposed to.
- Mastitis type testing on questionable quarters; cull all Staph. aureus-positive cows.
- Milking system checked by professionals every six months.
In my opinion, all tests for pathogens should be done at state-certified labs. On-farm testing is a few years away as the culture of the tests can be spread and infect animals if not handled properly and destroyed with an autoclave.
This article appeared in the Fall 2006 edition of Wise Traditions, the quarterly journal of the Weston A. Price Foundation.