FDA Antibiotic Test Requirement Threatens to Cut Raw Milk Supply in Pennsylvania
December 20, 2017A Wishlist of Just Laws for Those Who Feed Our Families
January 11, 2018RAW MILK DEVOTEES TAKE NOTE!
By Sylvia P. Onusic, PhD, CNS, LDN
The raw milk movement has turned into a revolution. Over the past ten to fifteen years, more and more moms have discovered the nutritional and taste value of buying real milk for their families, and more farmers are realizing that real milk adds value to their business. The raw milk renaissance has been supported by the promotion and education efforts of the Weston A. Price Foundation and its Campaign for Real Milk at realmilk.com.
In the mid-1940s, fictional articles appeared in Coronet magazine (May 1945) and Reader’s Digest (August 1946), describing the non-existent town of Crossroads where many individuals supposedly were dying from undulant fever as a result of drinking raw milk.1 Ever since the publication of these and other fabricated stories, the U.S. Food and Drug Administration (FDA),2 the Centers for Disease Control and Prevention3 and other government agencies have continued to beat the same sorry drum, warning consumers that raw dairy products are hazardous. Consumers, fueled by these government reports, have feared the dangers of raw milk.
This legacy of fear-mongering, combined with the lowfat lipid hypothesis of heart disease and the growth of industrial dairies, has produced a vast array of highly processed, pasteurized, ultrapasteurized and homogenized versions of milk. Containing varying amounts of fat, these products are tasteless and devoid of the rich nutrients that are the hallmark of milk from pastured animals.
In the U.S., only a few states such as Pennsylvania and California allow retail sales of raw milk. The sale of raw milk for human consumption is completely illegal in sixteen states. In other states, consumers who go to some effort can obtain raw milk on the farm, through herdshares or cowshares or as pet food.4
The restriction on food freedoms in North America has been accompanied by increasingly desperate enforcement of government food laws by U.S. and Canadian officials who use police to invade small farms and arrest farmers who produce raw milk. For example, the FDA carried out an early-morning armed raid on the farm of Dan Allgyer, an Amish farmer in Pennsylvania, because he violated the agency’s ban on interstate raw milk sales. The raid put Allgyer out of business. None of Allgyer’s out-of-state customers, who had sought out his dairy products with full awareness that they were unpasteurized, had ever alleged that the milk had made them sick.5
A NEW SALES MODEL
Europeans have long valued raw milk as a traditional food that serves as the basis for many cheeses and other related products.6 Most European countries permit the sale of raw milk. Moreover, European officials have done the opposite of their counterparts in the U.S. by allowing expanded distribution of raw milk through self-service consumer vending machines.7,8 The vending machines give consumers easy access to raw milk at convenient locations in shopping centers and at farmers markets as well as near schools and playgrounds. The machines also provide added value to farmers, who can increase their market and sell their milk safely,hygienically and with confidence. In these countries, pasteurized forms of milk are also available, including sterilized milk sold in cardboard boxes, which do not require refrigeration.
I discovered my first raw milk vending machine (mlekomat) in 2009 at the main farmers market in the capital city of Ljubljana, Slovenia.9 The machine was a marvel—simple and so easy to use that a child could operate it. The design was also flexible, with many built-in features to accommodate the wants of the consumer. The major focus was on safety of the milk and maintenance of hygienic conditions before and after dispensing it. If I had to guess, I would bet that a mom designed it!
After payment, the machine dispenses the milk into a glass or plastic container that the consumer can purchase on site (or into the consumer’s personal container). Once the machine has dispensed the milk, an ultraviolet light sanitizes the surface. There are usually paper towels nearby to wipe up any drips. One liter (about a quart) of fresh raw cow’s milk is available for about one euro ($1.12 US). A consumer can purchase an unlimited amount of milk.
The vending machines only allow sale of raw milk over a twenty-four-hour period, at which point a new batch must replace the previous batch. If the temperature of the storage unit changes, the farmers receive a message on their cell phone. In fact, a farmer can check the status of the milk machine at any time through a cell phone app. Inspectors also have easy key card access to the inner workings of the vending machines at any time.8 Farmers own and maintain the machines, cutting out middlemen. Farmers can post information on websites letting the public know about the locations of their vending machines, but consumers also can easily find them in areas where they already shop and consume food. There have been no confirmed reports of illness caused by the raw milk purchased at these machines from government officials or members of the public.10
A WORLDWIDE TREND
As an American who is aware of the restrictions and force applied by the U.S. government to prohibit the sale of raw milk, it was almost unbelievable to observe vending machines dispensing milk for customer after customer in Slovenia. I began to wonder about the extent to which raw milk was permitted elsewhere in Europe. After doing some research, I found that raw milk vending machines are operating safely in many European countries. For example, there are more than one thousand raw milk machines in Italy alone, including in Sardinia and Sicily.11 When blogger Sarah Pope and her family traveled to Italy, she observed that raw milk vending machines were stationed near schools.12
In addition to Italy and Slovenia, consumers can find raw milk machines in Austria, Croatia, the Czech Republic, Denmark, France, Germany, Greece, Ireland, Lithuania, The Netherlands, Poland, Romania, Serbia, Slovakia, the United Kingdom and more. Spain and Norway restrict the sale of raw milk at present, but it looks like they may ease regulations to permit vending machines.8
Since seeing that first mlekomat, sales and use of raw milk vending machines have increased to such an extent that they generate yearly marketing reports and forecasts in the millions of dollars. The popularity of raw milk machines has even spread beyond Europe to India and elsewhere in Asia, Africa, New Zealand and elsewhere.8,13
INCOME FOR FARMERS
The European Union originally imposed raw milk quotas on farmers but recently discontinued them, which prompted an increase in milk production in many countries, accompanied by falling prices. These factors, along with rising consumer awareness of raw milk as a natural food, actually created the conditions that have allowed raw milk vending machine sales to skyrocket.8 In fact, the machines handily offered a solution for what might otherwise have become an unpleasant political situation for European officials. As farmers eagerly embrace this strategy for marketing their milk, governments too have welcomed vending machine sales, sometimes attending events that put new machines into service and even drinking the milk themselves.14-15 Dairy farmers who also produce traditional raw milk cheeses, buttermilk, yogurt and chocolate milk are looking to vending machines as potential sales outlets for those products as well.8
A 2016 marketing research report estimated that the European raw milk vending machine market was worth U.S. $6.45 million in 2015 and will reach U.S. $17.97 million by 2024.8 During the forecast period from 2016 to 2024, the market is expected to surge at a compound annual growth rate of 12.5 percent. The report predicts that sales in Eastern European countries will rise by 9 percent over the same eight-year period. The report also covers market growth in China, Japan, Southeast Asia and India.8 Additionally, the report analyzes factors that are driving growth of raw milk vending machines in each region; assesses market trends, growth opportunities and strategies to increase raw milk popularity; and examines market share and competitive strategies adopted by producers in the European raw milk market.8
There are three leading raw milk vending machine producers (DF Italia, Brunimat GmbH and ProMeteA SRL), which make up 87 percent of the market. As raw milk continues to grow in popularity, however, vending machine manufacturers are joining the game in India, China and other countries.16 This competition among producers has led to topnotch vending machines with improved ergonomics and new designs with even better sanitation and slots for products such as cheese, buttermilk, yogurt, chocolate milk and ice cream. In Slovenia, I witnessed farmers using such machines to sell non-dairy products such as wine and olive oil directly to consumers. The sale of vegetables through vending machines may also prove to be a lucrative business opportunity.8
REACTIONS BACK HOME
When I returned to the U.S. after my first sighting of a raw milk vending machine, I wrote several blog posts about the machines.9 Americans and other readers posted generally positive comments. Interest in the U.S. intensified after I spoke about the vending machines at the Second Annual International Raw Milk Symposium in April 2010.15 Reporters who attended the conference wrote about the machines. Many people asked me the same two questions: “How do we get the machines?” and “Would they work in the US?”
When I returned to Slovenia the following summer, I met with an Italian producer who was willing to change out the electricals in his model of the vending machine to meet the one-hundred-and-ten volt standards needed for operation in the US. He even offered to send a raw milk machine for use at the WAPF conference being hosted in Pennsylvania that year. After more sleuthing, however, I found that the machine definitely would not clear U.S. customs.
As far as trying to obtain approval to sell raw milk via vending machine in my home state of Pennsylvania, where raw milk is legal, officials at the Pennsylvania Department of Agriculture strongly discouraged me from embarking on such an enterprise. A female veterinarian who worked at the Agriculture Department told me it would be a grueling bureaucratic process and said that they would never approve vending machines because there was no way to police them. Even after I explained how farmers could track their machines via a special iPhone app and stated that inspectors could gain access to the machine at any time with an entry key, the idea seemed unfathomable to her.
As a result, no American farmers thus far have been successful in bringing vending machines to America. It would be a Herculean task to surmount all the obstacles and barriers that are in place. On the other hand, it is currently possible in the U.S. marketplace to purchase milk machines that dispense pasteurized milk or milk powder products in sugar-laden chocolate and strawberry flavors.17
VENDING MACHINES IN THE UK
Farmers in the UK and Ireland have had better luck importing raw milk vending machines, and the major vending machine producers have made rapid inroads there. Starting in 2011, officials have allowed farmers to use raw milk machines on the farm.14 In all, almost one hundred and fifty farms are selling raw milk in the UK and Ireland.18
The placement of a vending machine at a local Selfridges store (part of a department store chain) has been more controversial, because the UK’s Food Standards Agency (FSA) views it as technically breaking a law that bans the sale of raw milk from mainstream retail outlets in England, Scotland and Wales. Selfridges personnel say that their local government gave permission for the machine to be operational on the premises. Selfridges stopped selling the milk, but the FSA persisted and is prosecuting Selfridges as well as Steve Hook, the farmer from Longley’s Farm in East Sussex who was in charge of filling the machine.19,20
Fen Farm Dairy raw milk vending machine in the UK
Jonny Crickmore of Fen Farm Dairy in Suffolk has been farming for over eighty years. Jonny was the first farmer in the UK to install a farm-based raw milk vending machine in 2011. He and his brother George milk three hundred French Montbéliarde cows, run a beef herd and make raw cheese, butter and cream. His “Baron Bigod” is Britain’s only raw brie and is described as “creamy, smooth and nutty.” Jonny’s neighbor, Julie Cheyney at White Wood Dairy, uses his milk to make her celebrated St. Jude cheese.21,22 Jonny likes the fact that he, rather than a processor or supermarket, is in control of the milk. He uses the DF Italia machines and sells them to other farmers.14 On Saturdays he sells about one hundred and ten liters of raw milk and is confident that he will sell up to two hundred liters eventually because people are just learning about the vending machines. He says that the machine improved his cash flow “instantly.”7,14,21,22
Jeremy Holmes is another dairy farmer who owns a machine from DF Italia. The machine cost him nine thousand pounds ($11,400). He milks a mix of Holstein-Friesians crossed with rown Swiss. He thinks the vending machine is “absolutely brilliant” and has probably saved his business. He notes that he pays the utmost attention to hygiene to ensure that the lab test results are “easily met.”7,14
Elwick dairy farmer Andrew Sturrock, athird-generation farmer of Home Farm, has launched a new vending machine that allows villagers to serve themselves with a “pinta” or two of the white stuff that has been freshly milked that day. It is the first of its kind in the North East. Sturrock bought the machine after seeing an item about it on the BBC Countryfile television program. Sturrock said that he “installed the vending machine as a way of adding value to our products,” noting that “people love the taste and keep coming back.” Every morning, Sturrock pours one hundred and twenty liters of raw milk from his one-hundred-and-eighty-head herd into the machine after it has been filtered and chilled. The Home Farm website shows a video of seven-year-old Louis Richmond purchasing milk from the machine on his tippy toes and, after the bottle is filled, taking a long slug and then giving the camera a million-dollar smile.23
In the UK, raw milk is not only the choice of smiling seven-year-olds and many Britons but also of the royal family. A recent report states: “Queen Elizabeth drinks her milk raw. She reportedly thinks so highly of unpasteurized milk that when her grandsons Princes William and Harry were students at Eton, she instructed herdsman Adrian Tomlinson to bottle up raw milk from her Windsor herd and deliver it to them at school.”24 Prince Philip also supports the consumption of raw milk.
RAW MILK SAFETY
What is the safety record for raw milk vending machines that have now dispensed thousands of liters of milk? In Slovenia, health officials confirm that there have been no outbreaks of illness.9 In fact use of the milk machines may limit the potential for introduction of pathogenic bacteria because the milk goes straight from the cow to the dispenser without undergoing any intermediate processing,25 and the milk is kept at a constant temperature.8
With its large network of vending machines, there have been no reports of illness in Italy. Nonetheless researchers in northern Italy decided to examine milk samples from sixty machines on thirty-three farms that sell about three thousand five hundred liters of raw milk daily.26 When they used the method of testing (called an ISO test) that the region’s regulators rely on to check milk safety, the researchers found no pathogens. When they decided to use two additional testing methods—polymerase chain reaction (PCR) and modified bacteriological analytical manual (mBAM)—they detected the presence, in extremely small numbers, of Salmonella, Campylobacter jejuni, E. coli O:157 and Mycobacterium avium subsp. paratuberculosis (Map), leading the researchers to conclude that the standard ISO test is “not sensitive enough.” The researchers also found that “in comparison with milk samples collected from bulk tanks, the milk samples collected from vending machines showed a significant increase of total bacterial count ‘meaning that raw milk was mishandled during distribution and sale,’ perhaps due to lack of consistent temperature control.”26 However, they failed to disclose their methods for protecting the milk from contamination during collection of the samples.
Another Italian study conducted from 2009-2011 assessed six hundred and eighteen milk samples from one hundred and thirty-one vending machines for the presence of pathogens.27 They found that 0.3 percent of the samples were positive for Salmonella spp., 0.2 percent for E. coli O:157, 1.5 percent for Campylobacter spp. and 1.6 percent for Listeria monocytogenes. The researchers did not compare pathogen levels in raw versus pasteurized milk samples, nor did they consider the possibility that they themselves may have mishandled the milk. A study comparing the detection rates for these bacteria in similar samples of pasteurized milk or raw milk intended for pasteurization might furnish more credible information for risk assessment.
In early 2017, reports emerged of a Campylobacter outbreak in the UK’s South Lakeland District, sickening fifty-six people. Authorities associated the outbreak with milk from a raw milk vending machine, shutting it down pending further testing and investigation. No reports have been forthcoming to identify or confirm the source of the bacteria.28
The European Union watchdog for food safety—the European Food Safety Authority’s Panel on Biological Hazards—has its eye on raw milk. Clearly this is because of the growing consumer interest in the health benefits of raw milk consumption. The panel has been unable to quantify accurately the public health risks associated with drinking raw milk due to gaps in data (or shoddy records?). However, member state data on food-borne disease outbreaks point to twenty-seven outbreaks between 2007 and 2013 due to consumption of raw cow’s or goat’s milk. Most (78 percent) were caused by Campylobacter; others were caused by Salmonella, Shiga-toxin producing E. coli (STEC) and tick-borne encephalitis virus (TBEV). No further information is available regarding the outbreaks or their relationship to raw milk vending machines.9
THE BIGGER PICTURE
According to raw milk expert Dr. Ted Beals, consumers are about thirty-five thousand times more likely to get sick from other foods than they are from raw milk.29 Informed consumers are aware of the true risk-benefit ratio of consuming raw milk from farms employing diligent practices. Despite government attempts to intimidate farmers and consumers through police and regulatory actions, authorities in the U.S. and elsewhere have not been able to stem the tide of the raw milk movement, which continues to spread. The rising popularity of raw milk vending machines and direct farm-to-consumer sales reflects a strategic business model that is helping many dairy farmers not only stay in business but make a reasonable living.30
REFERENCES
1. Fallon SA. A campaign for real milk: full-fat, pasture-fed, unprocessed. Weston A. Price Foundation, PowerPoint slides 59-60, September 2011.
2. US Food and Drug Administration. The dangers of raw milk: unpasteurized milk can pose a serious health risk. https://www.fda.gov/Food/resourcesForYou/consumers/ucm079516.htm.
3. Centers for Disease Control and Prevention. Raw milk questions and answers. https://www.cdc.gov/foodsafety/rawmilk/raw-milk-questions-and-answers.html.
4. Farm-to-Consumer Legal Defense Fund. Raw milk nation—interactive map. State-by-state review of raw milk laws. Updated February 10, 2017. http://bit.ly/2rS2sM1.
5. Kennedy P. Dan Allgyer, Pennsylvania. Campaign for Real Milk.
6. Hesser A. The French resist again: this time, over cheese. The New York Times, May 20, 1998.
7. Brasch S. Raw milk vending machines take over Europe. Modern Farmer, March 25, 2014.
8. Transparency Market Research. Raw milk vending machine market—Europe industry analysis, size, share, growth, trends and forecast 2016-2024. April 11, 2016. http://bit.ly/2qR5fa2.
9. Onusic S. Fresh milk, raw milk, anytime at the mlekomat—automatic milk machines in Slovenian markets. Taste of Slovenia, April 12, 2014. http://bit.ly/2qhUNpo.
10. EFSA Panel on Biological Hazards. Scientific opinion on the public health risks related to the consumption of raw drinking milk. EFSA Journal 2015;13(1):3940. http://bit.ly/2qYuQOO.
11. Milk maps [Italy]. http://www.milkmaps.com/.
12. Pope S. Raw milk machines are EVERYWHERE in Europe, why not USA. The Healthy Home Economist, December 23, 2016. http://bit.ly/2qYcRWN.
13. Village Milk. Dispensing machines for raw drinking milk. Takaka, New Zealand. http://www.villagemilk.co.nz/.
14. Midgley O. Raw milk vending machines helping farmers steer through the dairy crisis. FG/Insight. March 25, 2016. http://bit.ly/21R2dLe.
15. Onusic S. European raw milk perspectives. Second Annual International Raw Milk Symposium, Madison, WI, April 2010. The PowerPoint slide presentation and audio file are available on the Campaign for Real Milk website at www.realmilk.com.
16. Alibaba.com. http://bit.ly/2qif3XO.
17. Chocolate milk vending machine. http://bit.ly/2rjelhe.
18. Welcome to raw milk suppliers [UK and Ireland]. http://rawmilk.simkin.co.uk/.
19. Smithers R. Selfridges’ raw milk dispenser “contravenes food hygiene regulations.” The Guardian, December 15, 2011.
20. Raw milk vending machine supplier in UK targeted by government. Health Impact News, May 24, 2017.
21. Fen Farm Dairy. Welcome to Fen Farm Dairy. http://fenfarmdairy.co.uk/.
22. Barrie J. British dairy farmers are starting a raw cheese revolution. Munchies. June 17, 2015. http://bit.ly/2rWqbKr.
23. Payne M. Hartlepool milk vending machine first in North East. Hartlepool Mail, September 2, 2016. http://bit.ly/2qYl8Ml.
24. Selick K. Raw-milk fans are getting a raw deal. The Globe and Mail, September 24, 2010. https://tgam.ca/ 2riT07s.
25. A lotta bottle-but no milkman! Farm installs vending machine that delivers milk pumped straight from the udder. Daily Mail, April 25, 2014. http://dailym.ai/2qm4q5u.
26. Rothschild M. Study finds pathogens in Italian vending machine raw milk. Food Safety News, March 27, 2012. http://bit.ly/2qXUsev.
27. Bianchi DM, Barbaro A, Gallina S, Vitale N, Chiavacci L, Caramelli M, Decastelli L. Monitoring of foodborne pathogenic bacteria in vending machines. Food Control 2013;32(2): 435-9.
28. News Desk. UK’s raw milk vending machine outbreak expands; 56 sick. Food Safety News, January 3, 2017. http://bit.ly/2rSnJ8x.
29. Beals T. Those pathogens, what you should know. A Campaign for Real Milk, July 31, 2011.
30. Australian Raw Milk Movement (ARMM). Raw milk & vending machines save small family farms. https://www.ausrawmilk.org/blog/raw-milkvending-machines-save-small-family-farms.
31. Watson M. Death of NZ’s raw milk cottage industry feared as new rules introduced. NZ Farmer, April 26, 2016. http://bit.ly/2qsSI9r.
32. Jooste J. New Zealand dairy farmers use glass bottles and vending machines to sell raw milk from the farm. ABC News, February 8, 2015. http://ab.co/2rIwXqv.
33. Ministry for Primary Industries [New Zealand]. New requirements for the sale and production of raw milk. http://www.foodsafety.govt.nz/industry/sectors/dairy/raw-milk/.
34. Raw milk. Consumer, June 30, 2016. http://bit.ly/2qoVVHO.
35. Salt L. From the cow to the coffee cup. The Mercury Bay Informer, September 30, 2015, p. 6. http://bit.ly/2qoCCOO.
36. Dolly’s Milk. http://www.dollysmilk.co.nz/dollys/.
37. Wilkins A. Raw milk vending machine an udder success for Canterbury farmer. Newshub, May 31, 2017. http://bit.ly/2oTam5W.
38. Jersey Girl Organics. https://jerseygirlorganics.co.nz/.
39. Organic Dairy Farm BnB. https://www.booking.com/hotel/nz/organic-dairy-farm-bnb.html.
RAW MILK VENDING MACHINES IN NEW ZEALAND
In New Zealand, according to a raw milk dairy called Village Milk, “enthusiasm for real milk has been growing” by leaps and bounds.13 The company’s website notes that “people love the taste, the health benefits and supporting their local farmer.” Village Milk sells raw milk and helps other farmers who wish to produce “the best, highest quality raw drinking milk possible,” including providing advice on using dispensing machines.
There are more than sixty raw milk producers in New Zealand, and the number continues to grow.31 Until last year, New Zealand’s dairy farmers could sell raw milk under a fifty-year-old law that allowed remote and rural customers to buy milk from their local farmer.32 Unfortunately, new regulations were introduced in March 2016 that could endanger smaller-scale raw milk producers.31 Under the new regulations,33 raw milk producers must file and pay for reports from a dairy assessor, complete various application forms and furnish documentation from a food quality standards agency.31 Dairy farmer Tim Jopson, who supplies three hundred customers with raw milk from a vending machine, estimates that his current administrative costs will more than double to ensure compliance with the regulations.31 According to Jopson, a dairy would need to produce at least six thousand liters annually to cover the cost, and this will be “the death of the cottage industry-style suppliers with less than six cows who rely solely on their raw milk sales income.”31 On the other hand, the new rules will allow for home delivery of fresh milk and remove an existing five-liter limit per customer. The chairman of the Raw Milk Producers Association of New Zealand, Ray Ridings, mostly supports the new regulations but believes that the regulators overstepped their bounds by eliminating collection points that have expanded consumer access.34 Ridings nonetheless states, “It’s important our industry has some regulations because the danger of having cowboys selling raw milk puts everyone at risk—both consumers and responsible producers.”34
A number of New Zealand farmers are using vending machines to sell raw milk. For example:
• Village Milk, owned by Mark Houston in Golden Bay, has on-farm sales of up to three hundred liters of raw milk a day from the farm’s raw milk vending machines. Houston reports that he has never had a “health scare” in four years of operation.32 The dairy’s website offers consumers recipes for mozzarella cheese, kefir, homemade butter, yogurt, milk punch and smoothies.13
• Carl and Jeannette Storey from Whitianga are “living their dream” operating a small “boutique operation” with a planned herd size of thirty Ayrshire cows. They purchased a raw milk vending machine to sell their milk. They also foresee selling soft cheese, yogurt and fresh fruit ice cream.35
• Pete and Margaret Dalziel of certified organic Dolly’s Milk in New Plymouth produce raw milk (“straight from the teat”) from their large herd of Friesian-Jersey crosses. They also distribute vending machines manufactured in the Czech Republic. With a “Dolly’s card,” consumers can purchase milk at a cheaper price.36
• In Christchurch, farmer Mark Williams sells fifty liters a day of Aylesbury Creamery milk from his herd of ten cows. He has been so successful that he plans to double his herd.37
• Jersey Girl Organics at Cleavedale Farms in Matamata sells milk (“straight from our herd to you”) that is pasteurized but not homogenized. The Jersey herd grazes on organic pasture. Jersey Girl Organics maintains dispensing machines in two locations and also sells their milk in a variety of retail outlets.38
Raw milk farm tourism has caught on in New Zealand as well. Breakfast at the Organic Dairy Farm BnB, located in Mangawhai in the Northland (featured on Booking.com), includes raw milk, yogurt and butter.39
