(I have spent much of the last week reading a 189-page report issued jointly by the U.S. Food and Drug Administration and Health Canada, with the dry title, Joint FDA/Health Canada Quantitative Assessment of the Risk of Listeriosis from Soft-Ripened Cheese Consumption in the United States and Canada. The reading is as dry as the title suggests. Its full of technical statistical and research terminology, terms like risk characterization, sensitivity analysis, mitigation, rank correlation, and on and on. What that meant was that I had to read everything two, three, and four times before I could begin to make sense of it. But the more I read, the more upset I became, because I realized this is a very important document, one that could have a huge effect on food availability. If the authors of this report are successful in accomplishing what they want to accomplish with brie and camembert cheeses, you can be sure they will continue on to other kinds of cheese, and then other entire categories of food products, in their endless search for supposedly serious pathogen dangers. Equally troubling, the FDA considers this report “science based and transparent,” when it is anything but. I wrote the following analysis to try to get my thoughts down in an orderly way. I encourage you, after youve read my assessment, to try your own hand at reading the report, or at least the summary, and then to take the opportunity the FDA is offering to provide comments, and let the agency know in no uncertain terms what you think about this particular piece of literature. )
Nearly 15 years ago, a business book came out with the strange title, Who Moved My Cheese?
It was the story of mice in search of cheese that had disappeared, a parable about how people need to prepare for change, in their business and personal lives, and it became a huge best seller.
The parable may be playing out literally in real life before too long for raw milk soft cheese, if regulators in the U.S. and Canada have their way. A newly released 189-page report from the U.S. Food and Drug Administration and Health Canada concludes that there is a 50- to 160-fold increase in the risk of listeriosis from a serving of soft-ripened raw-milk cheese, compared with cheese made from pasteurized milk. As a result, the regulators suggest they want to see raw milk cheeses like camembert and brie either subject to unprecedented testing, processing similar to pasteurization, or else banned completely. I should note they also offer the option of doing away with the 60-day aging requirement for cheese, as a possible way to reduce the time pathogens have to multiply in the cheese, but its offered as kind of a straw man, since it does not consider the effect of removing the regulation on the risk of illness from other pathogens (That risk assessment should be worth another few lengthy reports.)
The risk certainly sounds serious until you read closely the full 189-page report and learn that the FDA-Health Canada conclusion about a 50- to 160-fold increase in the risk is based entirely on estimates and mathematical predictions, rather than real-life data on illnesses from the soft raw milk cheeses.
Even more remarkable, the actual real-life data presented in the report of illnesses worldwide from listeriosis in soft cheese over a 23-year period between 1986 and 2008 show not a single documented illness in the U.S. from listeriosis due to tainted brie or camembert. That data, in a table on page 17, documents four outbreaks of listeriosis in cheese in the U.S. over the 23-year period, but all four are from raw milk queso fresco cheese, a soft cheese served fresh, without being aged the required 60 days, and thus illegal in the U.S. (It gets made illegally, often in the Hispanic community, sometimes even mixed in bathtubs, which has earned it the nickname bathtub cheese.)
In Canada, two cheese-related outbreaks, which sickened 58 people, are attributable to multiple types of cheese.
Indeed, the researchers were only able to document 20 outbreaks of illness from listeria in all cheeses from all kinds of milk worldwide over the same 23-year periodless than one per year and, according to the report, half involved cheese made from unpasteurized milk.
So in actuality, were talking about ten listeriosis outbreaks worldwide from raw milk cheeses over a 23-year perioda tiny number by any stretch of the imagination.
By way of comparison, the U.S. Centers for Disease Control documents more than 1,000 outbreaks, resulting in between 15,000 and 30,000 illnesses, from all foods each year in the U.S.
So, given the absence of a single documented illness from 60-day-aged soft raw milk cheeses over 23 years in the U.S., and just the possibility of a few dozen illnesses in Canada, how do the FDA and Health Canada come to their conclusion that such cheeses are up to 160 times more risky than pasteurized soft cheeses? As I recall my grade school math, zero times any number equals zero. The regulators do it via mathematical / probabilistic modeling to estimate the risk per serving of Camembert-like cheese in both countries, according to the report.
The source of their data? Literature data, previous risk assessments and expert sources in Canada and the U.S. What about information from real-life farms and cheese producers? There is none: Risk was expressed on a per serving basis because (of) the lack of data on overall levels of cheese production (particularly for small cheese makers)
In the absence of real-life farm or producer data, the report relied heavily on a single study published in 2003 that include values for both the prevalence and the level of contamination of soft-ripened cheeses in the United States and Canada from a random sample of cheeses obtained at retail in Maryland and California as part of a larger survey of ready-to-eat foods.
Moreover, while the 2003 survey measured the presence of listeria monocytogenes (L. monocytogenes) in various foods, including deli meats and salads, along with assorted cheeses (the overall presence of L. monocytogenes. was 1.82%) there is no mention in the study of any illnesses resulting from the pathogens the researchers found, strongly suggesting that no illnesses resulted from the L. monocytogenes (the sample foods were collected over 14 to 23 months, plenty of time to have recorded illnesses).
So essentially what happened is that the FDA-Health Canada report writers worked backwards, and extrapolated what might happen on farms and at cheese-making facilities, based on the presence of L. monocytogenes shown in the 2003 study of ready-to-eat foods in retail markets. And the summary report notes near the end: The prevalence and level of contamination in Canada and in the U.S. rely on a single study to infer in-plant environmental L. monocytogenes contamination. Additional information about the prevalence of contaminated lots and contaminated cheeses within lots is needed.
Despite such obvious and serious limitations, the FDA-Health Canada report spends most of its 189 pages describing complex mathematical formulas and computations and providing diagrams of the cheese making process before, presto, spitting out its conclusion that anyone who consumes a serving of raw milk soft cheese has a significant chance of becoming ill, up to a 160 times greater chance than if he or she ate pasteurized cheese.
All the fancy mathematical gyrations and fear mongering come in the face of a simple and seemingly successful public health initiative implemented after World War II, whereby both the U.S. and Canada require all soft and hard cheeses to be aged a minimum 60 days, to allow for any pathogens that might be present to die off. (Quebec has no aging requirement, meaning that soft cheeses can be sold immediately after production.)
Serious makers of raw milk soft cheeses have long chafed under the 60-day aging requirement, since such cheeses dont age well in terms of taste, and are best served shortly after production. But American and Canadian makers have learned to adjustsome even using pasteurized sheep, goat, and cows milk to avoid the 60-day aging requirement–and as the FDA-Health Canadas own 23-year analysis showed, there have been remarkably few illnesses.
But the problem gnawing at the FDA, in particular, has been the growing popularity of raw milk, including raw milk cheeses. Actual sales of soft raw milk cheeses in the U.S. arent known, but the American Cheese Society reported in a December 2012 survey that 59 per cent of more than 200 respondents to a survey it conducted of members last year said they make raw milk cheese. The ACS has grown to 1,500 members since its founding in 1983.
The current assault on soft raw milk cheeses actually began nine years ago, when the head of the FDAs dairy division, John Sheehan, concluded as the lead author of a 2004 article in Food Safety magazine, that there were fundamental problems with the FDAs 60-day cheese-aging rule. New research, he wrote, suggested that 60-day aging is largely ineffectual as a means of reducing levels of certain pathogens in cheeses. With this information in hand, FDA is now developing a risk profile for raw milk cheeses, which will aid in the Agencys assessment of the requirements for processing these cheeses.
There was particular concern, he and his co-authors stated in the article, over listeria in cheese. They wrote about an action plan for cheeses that have resulted in new efforts to improve the safety of cheeses.
Shift to the report just issued, of which Sheehan is an author. Instead of acknowledging the paucity of recorded illnesses from raw milk soft cheeses during the 23-year period covered by the report, it suggests there is some kind of lurking problem: The United States and Canada continue to experience sporadic illnesses and outbreaks of listeriosis associated with the consumption of cheese, particularly soft and soft-ripened cheese. Presumably the sporadic illnesses and outbreaks of listeriosis refer to the four outbreaks from queso fresco and the two outbreaks in Canada over the 23-year period. By the way, the report also notes that the overall incidence in the U.S. of listeriosis is approximately 3 cases per 1 million individuals That is very low, especially when compared to something like autism rates, which have soared to one in each 88 children.
As further justification, the report notes that over the same 23-year period there were a total of 137 recalls of various types of cheeses, of which 108 (79%) were Listeria-related. In Canada from 2004 through mid-2009 there were 15 cheese recalls, of which 11 (73%) were Listeria-related. A wide variety of cheeses were involved in these recalls.
But as evidenced by the number of outbreaks and illnesses in the U.S. and Canada, those recalls were carried out after cells of L. monocytogenes were discovered in the cheeses, but not as a result of actual illnesses. Recalls nearly always occur well after whatever foods in question have been sold, and thus consumed. And its been well established that the presence of small numbers of L. monocytogenes cells rarely cause illnesses; for that reason, the European Union doesnt institute recalls for food containing small numbers of cells.
Now, I could accept a nearly completely conceptual analysis of this sort (aside from the terrible expense and time sink associated with it) if it was issued with the intent of sparking additional reality-based research. But its not. Its not only a solution in search of a problem, but it has been issued with one intent and one intent only: to fear monger about the supposedly huge risk associated with eating raw milk soft cheeses like brie and camembert as a lead-in to stricter rules against raw milk soft cheeses.
And the report has succeeded in that respect. A number of publications that cover the food safety arena have picked it up and run with the fear mongering about raw milk cheeses as if it is fact, notably Food Safety News and Barfblog, among others.
Whats most troubling is that the FDA has shown itself so completely opposed to raw milk and raw milk products under any circumstances that it would move to limit or ban such products even without evidence of a single illness. Talk about an ideological commitment.
Consumers have until April 29 to submit comments on this study. I suggest you let the FDA know about any concerns you might have. If there arent many comments, you know the FDA will simply assume everyone supports their direction, and their direction is crystal clear after nine years of effort.
**
Natural News has a great story about a Texas farmer who was rescued by angry consumers after he was forced to dispose of 700 gallons of raw milk. The farmer posted a video of the raw milk disposal on YouTube and hordes of angry people phoned local public health officials, who decided the better part of valor was to restore the guy’s raw milk permit. The Farm-to-Consumer Legal Defense Fund was active in working on behalf of the farmer as well.
Let me rephrase a statement I made a few years back, I have very little faith in Health Canadas resolve to sort through the rhetoric, misleading information and so called scientific fact. There appears to be a status quo or mindset if you will that interferes with her ability to be objective and non-partisan.
If one wish to acquire some insight into Health Canadas sincerity then read Corrupt to the Core by Dr. Shiv Chopra.
http://beyondfactoryfarming.org/get-informed/regulatory-matters/whistleblowers-health-canada-fired
Ken
This is excellent. Brief statements like this inform people better than long drawn out stories. Pictures would be the icing on the cake, as the visual would stay in a persons mind forever. And each time they pick up a piece of meat, the picture of the factory farm would flash through their subconscious.
Elaboration should be used if further inquiry is made (and the courious will almost always ask for more information).
“So essentially what happened is that the FDA-Health Canada report writers worked backwards, and extrapolated what might happen on farms and at cheese-making facilities…”
Before they got there, they worked backward from their basic mandate and mission: Aggrandize the corporate/industrial sector, assault its economic and political challengers.
http://jonrappoport.wordpress.com/category/fda/
This has got to stop.
The cows, the goats, and the grasses they eat, and the foods then prepared, predate these swarms of Officers.
And I pay for these swarms?
Mr. J. Ingvar Odegaard
ACS strives to work collaboratively and professionally with regulators and FDA. In response to our correspondence with FDAs John Sheehan in December 2012 (see http://tinyurl.com/d3r3rh9), ACS was contacted and invited to FDAs pre-publication stakeholder briefing on the risk assessment, which allowed us to prepare our members for its February 11 release.
ACS survey data cited in this blog post can be found at http://tinyurl.com/cw4fayh.
Spinach again. Where’s the out cry to boil it before selling?
http://www.youtube.com/watch?v=uV7am_97k30
The first one is more informative.
Just an FYI and simple request: I always appreciate your comments and links, but when you post links before any text, clicking on your comment takes me to the link, not to your comment. I would suggest that you post your comment text before the link, and then when we click on the comment will take us to the comment rather than directly to the external link. Thanks.
I just found this out today! Interestingly this is not common knowledge (no surprise there!), it is not freely advertised, but if one does the research, they will find the ordinance for allowing this.
Hope this link works: http://sdfoodpolicy.org/downloads/SD_City_Keeping_Goats.pdf
Deborah, as you suggest, the main hope for enacting change affecting food regulation is at the local level. The further away our rulers get, the less responsive they become. The FDA-Health Canada report I analyzed here is a classic case of distant government bureaucrats being so disdainful that they wouldn’t even bother to go out and gather real data from real farms and producers–they used a single unrelated secondary study as the basis of their decree that soft raw milk cheeses are up to 160 times more dangerous than pasteurized cheeses. Totally pathetic.
http://healthychild.org/blog/comments/us_vs_uk_mac_n_cheese_smackdown/
Many American food manufacturers now create two versions of their product, one for the US and a cleaner version for the moms, dads and kids in the 27 countries in Europe, Australia, Japan, New Zealand and the U.K.
U.S. Version of Kraft Mac & Cheese:
Enriched Macaroni Product (Wheat Flour, Niacin, Ferrous Sulfate [Iron], Thiamin Mononitrate [Vitamin B1], Riboflavin [Vitamin B2], Folic Acid), Cheese Sauce Mix (Whey, Modified Food Starch, Whey Protein Concentrate, Cheddar Cheese [Milk, Cheese Culture, Salt, Enzymes], Salt, Calcium Carbonate, Potassium Chloride, Contains Less Than 2% of Parmesan Cheese [Part-Skim Milk, Cheese Culture, Salt, Enzymes, Dried Buttermilk, Sodium Tripolyphosphate, Blue Cheese [Milk, Cheese Culture, Salt, Enzymes], Sodium Phosphate, Medium Chain Triglycerides, Cream, Citric Acid, Lactic Acid, Enzymes, Yellow 5, Yellow 6).
U.K. Version of Kraft Mac & Cheese:
Macaroni (Durum Wheat Semolina), Cheese (10%), Whey Powder (from milk), Lactose, Salt, Emulsifying Salts (E339, E341), Colours (Paprika Extract, Beta-Carotene)
Ken
Wow, I knew there were differences, didn’t know it was to that extent. Something to share with others, thanks.
Better yet, don’t wonder, just avoid the whole mess by not using this junk on either side of the pond.
http://www.food-info.net/uk/e/e339.htm
http://www.food-info.net/uk/e/e341.htm
Time is the unstoppable push on every life. There is a lot to do. Right.
Thanks again for the horrifying update.
Mr. J. Ingvar Odegaard
http://www.fifthtown.ca/artisan_cheese/editorial/the_importance_of_knowing_your_rennet/
FPC rennet is a GMO product. And, according to the culture companies, 90% of all cheeses produced in North America is made with FPC rennet. However, ingredient labels do not distinquish between this type of microbial rennet or the original non-GMO based type. And the fact that use of FPC type microbial rennet is not labeled a GMO product leaves those who oppose the use of GMOs in the dark when it comes to choosing their cheeses.
In addition, further confusion and debate arises over the general differences between GMO products versus genetically engineered products as the latter elicits deeper concerns from those opposed to this type of science. While FPC rennet is GMO, it is not a genetically engineered product, technically speaking, because, the DNA taken from the animal cell and inserted into the DNA string of a bacterium or mold is not changed. Genetically engineered foods actually goes as far as to modify the specific gene responsible for a particular function in order to improve its function. In other words, it takes messing with genes to another, deeper level. Its like playing with the shape of the lego block its self, not just with the order of the lego blocks.
In the end, what this means is that most cheese in North America is made from vegetarian friendly but still animal originated, GMO derived FPC rennet. And that while use of this type of rennet is banned in GMO-free European countries doesnt mean the cheese we buy from those countries are necessarily FPC free. To quote one Danish expert We cant use FPC rennet in Denmark for our own domestic cheese or cheese make for other European countries which have banned its use. We only use it for cheese we export to North America. .Why? Because again, it is a cheaper and more consistently available form of rennet.
Ken
GrassFood, I’ve heard similar tales about the sale of conventional dairy raw milk to Hispanics to make queso fresco. The stories too often have unhappy endings. The only two deaths recorded by the CDC from raw milk over the last 15 years were from queso fresco, and have been used by the CDC and the FDA as “evidence” that all raw milk is so deadly dangerous it should never be consumed by anyone anywhere.
But I have a question for tomm or Russ or anyone who is striving for this goal (as well as myself). How long do you think it will be before us commoners are no longer able to purchase seeds?
Without seeds to grow veggies and fruits, we get sorta cut off at the knees. I know, a lot of folks will say “well just save the seeds from whatever you purchase” or something to that effect. That might work, but do I really know if I want to save those seeds? WHat I’m finding out is just because something is marked organic doesn’t mean it IS organic. So you don’t really really really know what you’re truly buying. Maybe the people growing it (like for farmers markets and such) don’t know either because it all starts with the seeds. I think part of the whole GE/GMO interface is that eventually there won’t be any seeds for us to save or buy or use in any way. It’s that *control the food* thing. All communities and families are centered around food because it’s essential. Without it, well, you know . . .
Well surprise surprise….
http://www.ktvu.com/news/news/local/chickenpox-immunization-could-lead-increase-shingl/nSwWf/
“There’s growing evidence that immunizing children against chickenpox may be leading to more adult cases of shingles. ”
http://www.nytimes.com/2005/02/03/health/03vaccine.html?_r=0
” vaccine against chickenpox has sharply cut the death rate” I was courious as to what the “death rate” was from chicken pox.
So according to this site: http://www.all.org/article/index/id/MjUyNg It was; “Approximately 3.9 million cases of chicken pox occur annually in the United States, killing an estimated 90 persons (0.0023% death rate).” Wow, 90 people out of 3.9 million!
And from the govt; http://www.cdc.gov/chickenpox/surveillance.html ” Each year, more than 3.5 million cases of varicella, ——–, and 100 deaths are prevented by varicella vaccination in the United States. ” Again Wow, 3.5 million people and 100 die……..
Jack, good point. I’m not sure how “a shadow comment feed” would work, how people commenting would know about it. An alternative approach might be to seek out the comments after the comment period has closed. I believe the government agency needs to post those, or at least have them available on request, or possibly via a Freedom of Information Act request. Anyone else know the protocol?
In practice, they intend to impose proprietary varieties as the monopoly standard wherever possible, causing non-proprietary varieties to become unavailable. That’s already the case for many commodity crops, in the US, India, and elsewhere. They want to do this for all commodity crops. They also intend to contaminate non-GMO varieties as much as possible, in this way ruining those varieties, destroying the organic food sector, and where possible using lawsuits to discourage planting of anything not bought from the rackets.
They also buy up as many seed companies as possible, increasing their ability to cause non-proprietary varieties to disappear.
This still would leave the small seed trade, and grassroots seed-saving. Continued buyouts, the contamination onslaught, and other forms of strong-arming are intended to wipe out as many of the small businesses as possible. If we were reduced to grassroots seed-saving networks, it would be difficult to maintain the integrity of many varieties of many vegetables, on account of the precision skills required for cross-pollinators and the need for a vigorous trading network to keep all the varieties in constant cultivation. The system intends for such efforts to gradually wither.
And then there’s the stepping-up of the food police assault. They intend to make personal gardening and organic farming, and Freedom Seed projects among these, as legally difficult as possible.
In spite of all that, there’s good news! Whether or not all this comes to pass is in our hands. It’s all going to be a function of the will of people to reject the industrial food system (completely, in principle, and as much as possible in practice), grow their own food, buy local, form community food infrastructure, and build a cultural and political movement out of this. This will include supporting small, independent, locally/regionally oriented seed sellers. I agree that we can’t trust “USDA Certified Organic”, but must use that only in a pinch. With seeds, as with food itself, there’s no real substitute for getting to know your local grower/processor, and knowing their reputation among their customers. And as much as possible providing our own food and inputs/processing.
Therefore, it also means building a Freedom Seed network of decentralized libraries and trade networks. We can’t this effort wither the way the enemy intends for it to. The toughest part of this will be building the infrastructure (the number of plants required, and the responsibility to grow them) and skill level to reliably save seeds from cross-pollinators like brassicas.
In all this, we’ll also need the will to resist, in whatever way possible, the assaults of alien structures – governments and corporations. We also need to overcome such a fundamental moral failure as that the people are willing to accept the whole evil and rationally fraudulent notion of seed patenting and bow and crawl in obedience to it.
I don’t know how long it would be before it was difficult and then impossible to get truly organic seeds if we don’t take action and work hard to change our direction, but that’s definitely the vector we’re on now.
If you get NATURAL chicken pox (not the kind that can be picked up from a kid who’s been vaccinated because the vaccines shed) as a child and are periodically exposed to the natural virus throughout your life, you will have natural immunity to chicken pox and shingles. However, widespread use of the vaccine will drop the incidence of exposure to the NATURAL course of the disease, which will result in a weakened immune response to shingles, which is why shingles generally affects older people more than younger. Although, the health of your immune system definitely plays a huge role here. The elderly generally have weaker immune systems because they’ve been (generally) under the care of a physician long enough so their natural “everything” is ruined, shot, kaput. They can thank bigPHrMa for all that lovely itching and scaling.
One of the best things around to treat shingles is cold-pressed castor oil. You can also do the castor oil warm packs on skin that is broken open or bleeding. A few years ago I had an Aunt still living at age 98 and she got shingles while visiting with us. I’m sure it came from one of my day care infants who’d been shot up. It took me a couple of days to come up with a solution, but the castor oil nourished and fed the skin (because it’s an emollient) and she was better, with little scarring, in about eight days. She lived to be 102 and just died recently.
all that monkey-pus which we allowed to be injected into us, then merchandised as “measles / mumps” vaccine, only hid out in our bodies, to re-surface now as that baby-boomer demographic ages and our natural immunity wanes. It won’t be Big Pharma coming along to comfort people who are = this very hour = in severe pain / torment. Nope …. antigen specific transfer factor therapy, is too simple ||| too cheap. No obscene profits to be made from low-tech biotech of immune milk therapy … so we have to do it ourselves
I agree with you, being exposed, sporadically keeps our immune system working. I’ll add the cold-pressed castor oil to my list of home remedies.
http://news.yahoo.com/blogs/lookout/hand-sanitizer-possible-cause-freak-fire-injuried-11-195802532.html
The truth is kept in the minds of the researchers….what they know they can not say. If they speak they get fired!!!
Mark
Not dangerously contaminated? Just under dangerously contaminated?
“lab tests which reportedly show that much of the milk sold in Serbia contains high levels of aflatoxins, a fungus linked to mildewed cattle feed that can cause cancer if consumed in high doses. ”
“withdrawal of 50 types of milk, produced by nearly all Serbia’s dairies. ”
50 types of milk? There’s that many kinds of milk?
“Suspicions of a government cover-up are fed by the region’s widespread corruption and the cozy ties between politicians and industry. ”
Words are not needed.
“Goran Jesic, an agriculture official who broke the silence and published the results of the aflatoxin tests on Tuesday, demanded on Wednesday that the government also withdraw the cattle feed and instruct the farmers how to neutralize the presence of aflatoxins. ”
Kudos to him, bet his career is dead now. The contamination is probably more wide spread than known or reported,
http://news.yahoo.com/serbia-withdraws-suspected-toxic-milk-154131735.html