Raw Milk

[TLS4...@aol.com]

Everyone -

 

Before 1987, raw milk was legal in interstate commerce.  In that year, FDA was ordered by Judge Norma Holloway Johnson, U.S. District Court of the District of Columbia, following a suit filed and won by the consumer advocacy group, Public Citizen, to ban interstate sale of raw milk.  FDA put forth a proposal to do just that under the authority of the Public Health Service Act.

 

Once that proposal was "finalized," it became a federal violation (of 21 CFR 1240.61) to sell raw milk in interstate commerce.

 

The finding was based on the scientific assertion by FDA, with the support of CDC, that "raw milk, no matter how carefully produced, may be unsafe." 

 

There are at least 10 different potentially deadly pathogens historically associated with raw milk.   

 

Tom Schwarz

Food Safety Consultant

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[harrisc]

well, fair enough . . .

 

but that does seem to me to leave three questions to be explored . . .

 

1) now, 20 years later, is there reason to reconsider the proposition that, no matter how carefully it is produced, raw milk may be unsafe . . .

 

2) to the extent that that proposition is currently valid, are there (many) other foods moving in interstate commerce for which that proposition is also valid . . .

 

3) even if (1) is currently valid, if the strong version ("many other foods") of (2) is also currently valid, is that a sufficient reason to reconsider the prohibition on raw milk in interstate commerce . . .

 

cheers,

 

craig

 

craig k harris

department of sociology

michigan agricultural experiment station

national food safety and toxicology center

institute for food and agricultural standards

food safety policy center

michigan state university

http://www.msu.edu/~harrisc/

 

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From: Foodsa...@googlegroups.com [mailto:Foodsa...@googlegroups.com] On Behalf Of TLS4...@aol.com
Sent: Monday, October 29, 2007 9:42 PM
To: Egg...@aol.com; kboo...@vitafoodproducts.com
Cc: Foodsa...@googlegroups.com
Subject: [Foodsafe] Raw Milk

[Carl Custer]

Harris Cogitated,

"but that does seem to me to leave three questions to be explored . . .
1) now, 20 years later, is there reason to reconsider the proposition
that, no matter how carefully it is produced, raw milk may be unsafe .
. . "

[Carl]: I believe that there are procedures that could greatly
increase the safety of raw milk. Even safer than 95% (Who wants to be
wrong one out of 20 times?). But, I also believe that the criteria by
which raw milk has been "certified safe" were inadequate.

"2) to the extent that that proposition is currently valid, are there
(many) other foods moving in interstate commerce for which that
proposition is also valid . . . "

[Carl]: Well HHS confirmed that salad greens pose a risk but then we
knew that 15 years ago when certain companies began requiring
stringient growing and harvesting procedures on their suppliers.
Jerky pops up every once in a while but maybe the processors, prodded
by FSIS, have fixed the problems now.
Coppa hasn't been looked at very closely but not much is sold.
Carpaccio, yuk hwe, and similar products are only sold at retail.
FSIS took raw mettwirst and teewurst out of commerce 14 years ago.

"3) even if (1) is currently valid, if the strong version ("many other
foods") of (2) is also currently valid, is that a sufficient reason to
reconsider the prohibition on raw milk in interstate commerce . . ."

[Carl]: Often, because of political pressures, regulators have to pick
their battles carefully. Having victims to demonstrate that the
product is "ordinarily injurious" helps the cause. In the 1980's
(when I worked in FSIS) I heard the phrase more than once, "Show us
the (additional) bodies and you can regulate".
I believe the epidemiological evidence supports the decision to
declare raw milk produced under the current requirements as a highly
risky product.

"cheers,
craig"

[Carl]: Say, yew enny kin to ee cummings?
Carl in Spring, Texas

[Roy Costa]

From the prevention side, if we are not going to ban sales within states then there must be an effort to bring compliance with microbial criteria to the highest point we can.
 
What we are dealing with are the classic three p's of public health, promotion, prevention, protection. Promotion of raw milk is increasing, mandatory protection (prohibition) is missing except in Interstate commerce, so prevention must be stressed I think this may be where the best result is going to be in reducing cases.

Roy E Costa, R.S., M.S./M.B.A.
Public Health Sanitarian Consultant
Environ Health Associates, Inc
1.386.734.5187
www.haccptraining.org
www.safefoods.tv
rco...@cfl.rr.com

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From: Craig....@ssc.msu.edu
To: TLS4...@aol.com; Egg...@aol.com; kboo...@vitafoodproducts.com
CC: Foodsa...@googlegroups.com
Subject: [Foodsafe] Re: Raw Milk
Date: Mon, 29 Oct 2007 21:54:52 -0400

<BR

[Roy Costa]

Thanks Tom that is right to the point.

Roy E Costa, R.S., M.S./M.B.A.
Public Health Sanitarian Consultant
Environ Health Associates, Inc
1.386.734.5187
www.haccptraining.org
www.safefoods.tv
rco...@cfl.rr.com

---

From: TLS4...@aol.com
Date: Mon, 29 Oct 2007 21:42:07 -0400
Subject: [Foodsafe] Raw Milk
To: Egg...@aol.com; kboo...@vitafoodproducts.com
CC: Foodsa...@googlegroups.com

[Egg...@aol.com]

Craig,

 

In Tom's defense, I say that #2 is the killer issue.

 

More product should have intervention of a kill step.

 

We have been asking since childhood, "Jimmy did that so why can't I do it too?"

 

Good Night

 

Rich W

 

 

 

In a message dated 10/29/2007 9:57:20 P.M. Eastern Daylight Time, Craig....@ssc.msu.edu writes:

well, fair enough . . .

 

but that does seem to me to leave three questions to be explored . . .

 

1) now, 20 years later, is there reason to reconsider the proposition that, no matter how carefully it is produced, raw milk may be unsafe . . .

 

2) to the extent that that proposition is currently valid, are there (many) other foods moving in interstate commerce for which that proposition is also valid . . .

 

3) even if (1) is currently valid, if the strong version ("many other foods") of (2) is also currently valid, is that a sufficient reason to reconsider the prohibition on raw milk in interstate commerce . . .

 

cheers,

 

craig

 

craig k harris

department of sociology

michigan agricultural experiment station

national food safety and toxicology center

institute for food and agricultural standards

food safety policy center

michigan state university

http://www.msu.edu/~harrisc/

 

---

From: Foodsa...@googlegroups.com [mailto:Foodsa...@googlegroups.com] On Behalf Of TLS4...@aol.com
Sent: Monday, October 29, 2007 9:42 PM
To: Egg...@aol.com; kboo...@vitafoodproducts.com
Cc: Foodsa...@googlegroups.com
Subject: [Foodsafe] Raw Milk

Everyone -

 

Before 1987, raw milk was legal in interstate commerce.  In that year, FDA was ordered by Judge Norma Holloway Johnson, U.S. District Court of the District of Columbia, following a suit filed and won by the consumer advocacy group, Public Citizen, to ban interstate sale of raw milk.  FDA put forth a proposal to do just that under the authority of the Public Health Service Act.

 

Once that proposal was "finalized," it became a federal violation (of 21 CFR 1240.61) to sell raw milk in interstate commerce.

 

The finding was based on the scientific assertion by FDA, with the support of CDC, that "raw milk, no matter how carefully produced, may be unsafe." 

 

There are at least 10 different potentially deadly pathogens historically associated with raw milk.   

 

Tom Schwarz

Food Safety Consultant