The U.S. Food and Drug Administration has just informed raw cheese producers to expect fun and games in 2014: It will begin a pilot program lasting all of next year, during which it will test at least 1,700 samples of raw milk cheese. All this testing is in addition to rather than in place of existing sampling of raw cheese.
According to a report from the Gourmet Retailer, a trade association, the FDA will test a new microbiological sampling surveillance model that will be analyzed for contamination from salmonella, L. monocytogenes and E. coli O157:H7.(The Gourmet Retailer article says the FDA notified the American Cheese Society of the planned testing during a conference call; however, the ACS on its home page indicates information about the program is available only to ACS members; the Gourmet Retailer appears to have obtained its information from the ACS.)
For the last four years, the FDA has had its sights trained on raw milk cheese. It used much tougher enforcement action than it normally uses to shut down two raw-milk cheese producers in 2010 based on finding listeria in their cheese or on their premises, but absent any illnesses (Morningland Dairy and Estrella Family Creamery).
Also in 2010, as I reported in my book, Life, Liberty, and the Pursuit of Food Rights, the FDA conducted inspections of three-fourths of 130 members of the American Cheese Society, compared with 10% in previous years, the organization reported. Aside from Morningland and Estrella, no others had problems with pathogens in their cheeses or facilities.
Then, early this year, it came out with a study concluding 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. A close examination I did of that study showed that conclusion to be based on theoretical mathematical extrapolations made in the face of real-life evidence showing not a single illness over the previous 23 years from listeriosis involving soft raw milk cheese.
Talk about a solution in search of a problem. Even Bill Marler, the food safety lawyer and definitely not a raw milk enthusiast, concluded in a September analysis (one of several he has done in recent years) of the 60-day aging rule in place since the late 1940s for all raw milk cheeses, that there isn’t a lot to worry about with raw milk cheese safety. Based on an analysis going back more than 60 years to the implementation of the raw milk aging rule, he concluded that outbreaks and illnesses linked to 60-day aged cheese are relatively rare despite microbiological evidence of pathogen survival in these cheeses… What he was saying is that very few people have become sick during that long time period, though there is evidence that certain pathogens can survive more than the 60 days of required aging. He suggested that the reason few people get sick is likely the result either of low contamination level in milk used in cheesemaking or alterations in virulence of pathogens in the aged cheese.
Interestingly, the new FDA testing program appears to be focused on finding evidence of pathogens in raw milk cheese, not on finding evidence of illnesses. As an example of the contradiction here….listeria in very low volumes have been found not to cause illness, and as a result, the European Union allows the presence of listeria in foods at low levels, in contrast to the FDA’s zero-tolerance rule. What the FDA appears to be doing is going on a treasure hunt in search of pathogens so it can play the gotcha game–if a single pathogen like listeria shows up on one of the samples being tested next year, it will be another notch on its belt, and in the underlying purpose here: to develop an excuse for either banning raw milk cheeses entirely, or else lengthening the 60-day rule enough that most soft cheeses, and perhaps other cheeses as well, will become impractical to produce. Take a few more nutrient-dense foods out of the system.
The problem for the FDA, and the corporate processed cheese producers whose interests it is most concerned about, specialized raw milk cheese has become increasingly popular over the last five years. The ACS has seen its membership soar, more than doubling from 2003 to 2011.
What happens if the FDA inspectors find evidence of pathogens in cheese tested? The article in Gourmet Retailer answers that question with bureaucratese: Any “response to positive findings will be at FDA’s discretion, but will likely follow traditional FDA approaches similar to those used whenever a product is believed to be contaminated–including traceback, inspection, environmental sampling, additional product testing, and voluntary recall if necessary.” In other words, expect the full treatment accorded Morningland Dairy and Estrella Cheese–don’t be surprised if FDA inspectors dressed in battle fatigues show up to test your premises for days, and then call for a full recall going back six months or a year, followed by a shutdown.
The only potential good news for domestic producers of raw milk cheese (and it’s not very good) is that about 70% of the sampling will be of imported raw milk cheeses, and only 30% of domestic cheese, according to the Gourmet Retailer article. In addition, this will be more an equal opportunity program, with imported sprouts and raw almonds included in the testing.
Get ready then for another study based on this testing program showing raw milk cheeses to be hundreds of times more dangerous than pasteurized milk cheese. The goal is clear: to find excuses to limit or eliminate entirely access to raw milk cheese, and possibly to other nutrient-dense foods like raw almonds (which are nearly entirely imported, since domestic almonds must be pasteurized) and sprouts, whether evidence of a problem exists .or not.
the parallel with the Campaign for REAL MILK, is, that real fish, ie, salmon from a wild fishery, costs significantly more at retail. And is worth it, in flavour alone. You can have the image of what appears to be food, or you can have the real thing. So if you choose to eat garbage because it’s cheaper – welcome to it, as long as there aren’t laws preventing me from choosing what I prefer, and paying what it takes to secure the line of supply to get it.
JS,
I have heard this complaint before from raw food aficionados, and I think it is well taken. However, I seriously doubt the FDA views the problem of heating raw milk cheese the same way you do. As far as its people are concerned, the fact that it hasn’t gone through “official” processing that includes pasteurization means that it is as suspect as if it had been heated to less than 105 degrees. Its people don’t recognize the subtleties you refer to about enzymes or proteins being affected by excess heat. To them, raw milk is raw milk is raw milk .and it’s all high risk and shouldn’t be allowed for sale.
They don’t quite have all their wagons in a circle, but admit it? Never. And certainly not where raw milk is concerned when bigdairy has their red dot on the FDA’s monetary interests.
excuses moi sil vous plait.
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Oh, and: great article David. Very informative.
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Has everyone seen the:
Revised Presentation July 8 Raw milk myths and evidence by Nadine Ijaz pdf
Nadine’s study is perfect and it proves raw milk is a low risk food which should be enough to end the raw milk debate once and for all.
http://www.bccdc.ca/NR/rdonlyres/00E8757C-99E4-4414-8C54-2C92BB776567/0/RevisedPresentationJuly8RawmilkmythsandevidenceNadineIjaz_PROTECTED.pdf
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Are these conference calls a way of keeping things off the record? Can they be recorded?
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Thank you David, theoretical mathematical extrapolations made in the face of real-life evidence showing not a single illness over the previous 23 years(Is this since monitoring began?) from listeriosis involving soft raw milk cheese..
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illnesses linked to 60-day aged cheese are relatively rare despite microbiological evidence of pathogen survival the new FDA testing appears to be focused on finding evidence of pathogens not on finding evidence of illnesses. …listeria in very low volumes have been found not to cause illness, the European Union allows the presence of listeria in foods at low levels (despite the use of the ambiguous term linked) What if this is true for raw milk? We know there is what is called the infectious dose but has anyone bothered to test the infectious dose in raw milk? I’m sure we could easily find thousands of willing volunteers.
Farmed fish could be done to a point where it would be a better alternative than ocean fish, but instead of making it a credible, lucrative, healthy business venture, the entrepenuers of today have seen a dollar sign and forgotten about all the good things. The farmed fish could be raised using good water (better than ocean water probably as it stands right now), they could be fed a diet as close to what they’d get in a natural ocean setting, they could be allowed to live their lives pretty much as they would normally do. Using a few nets rather than fish pens/corrals it could be done as close to natural as possible.
There are online sources for salmon but the buyer really has no idea. I read an article last year which stated that if a package says “Alaskan Salmon” it must be ocean fresh and not farmed. I don’t know if that is still true today or not.
http://www.davidicke.com/forum/showthread.php?t=240415
Russ, I had the same Qs. I’ll see what I can find out.
So you can build any mathematical model you like (e.g. “Hey guys, let’s multiply it by 1000!”) and publish your “results” without disclosing what your model is, and the press and health safety “experts” lap it up. Notice that they never reveal the model or the assumptions that go into it – that’s kept well hidden.
It’s worked now for the “150-times” study, the “Minnesota 20,000” study, and now they’re going after raw milk cheese with it too.
When is anyone going to question the hocus-pocus their hiding behind the label of “mathemathical model”? When is the press ever going to ask “What model?” and begin dissecting whether the math is right or not? Is everyone so intimidated by math that they won’t ask questions?
Cravens pasteurized cheese kills three in mid 2013….and what does the FDA do, it attacks raw milk cheeses!!?? I have seen repeated food safety incident reports that report illness or death from a pasteurized dairy product, only to have the recommendations read: only eat pasteurized dairy products, raw is very dangerous.
To include all cheeses that are made at temperatures just below pasteurized temps as raw is completely disingenuous and stinks of the FDA agenda. OPDC has even branded our raw cheeses as Truly Raw just to expose this thermal wasteland between 102 degrees and 160 degrees that the FDA allows industry to call raw….but it sure is not!!
According to our milk inspector, there was a regional milk inspectors meeting in PA last fall where the milk inspectors left with the impression that FDA’s goal was to regulate the small producers out of business by requiring testing of every batch of cheese before it was sold. Think of the impact that will have on fresh cheese makers! So, I then asked, what will this cost and the inspector said testing a batch of cheese costs $1,200.00. A typical small cheese maker makes 50 gallons at a time, so that cheese is worth $800.00 at $16 per pound. I then ask who is going to pay for this and the inspector said he didn’t know. There is a meeting in January 2014 to discuss these issues and I may find out then.
Small producers have enough problems without having to deal with this. It is little wonder there are any left and as I said, the goal appears to be to put those who are still afloat out of business. I’m glad I got out of the cheese business while I still could rather than having to sell my vat and other equipment to the scrap yard at $0.12 per lb.
Raw milk will be next. The FDA hates it. They don’t want animals to drink it and they certainly don’t want you to drink it. Remember the Dane County, WI judge who ruled a few years ago that the family standing in front of him didn’t have the right to own a dairy cow? Things are going to get much worse on the food front in the years ahead. (The judge in question went on to work for Monsanto shortly after that ruling…. golly gee… what a surprise.)
So far raw milk is clearly been a states rights issue. So far it is clear that the FDA will stay & steer completely clear of raw milk. It is whey too hot and they know better.
This is perhaps why my OPDC FDA citizens petition has languished at the FDA for more than 4 years in spite of FTCLDF legal heat to move it along. They can not and will not touch it because if they do they must acknowledge states rights issues and that opens Pandoras raw milk box for them. Something that would bring in RAWMI data, the CA market experience, RAMP, Testing standards, EU studies, Asthma, mad moms and the genie would be out of the raw milk bottle forever.
FDA best policy for now….just keep on denying and staying away from raw milk. They do that quite well.
http://www.cdc.gov/foodborneburden/PDFs/11_228412_pitts_factsheet_table2_remediated.pdf
Revised Presentation July 8 Raw milk myths and evidence by Nadine Ijaz pdf
http://www.bccdc.ca/NR/rdonlyres/00E8757C-99E4-4414-8C54-2C92BB776567/0/RevisedPresentationJuly8RawmilkmythsandevidenceNadineIjaz_PROTECTED.pdf
http://guardianlv.com/2013/12/fukushima-radiation-hits-us-west-coast/
As for my appeal : When one gets entangled in political issues which wind up as “contempt of Court’, we find that judges are not the slightest bit interested in real evidence to the contrary of the Central Party Line. Judges owe their appointments – and very existence – to political connections. See Jonathan Swift’s satire Gulliver’s Travels into the Land of the Houwhynyms. His take on the legal racket from 300 years ago, is perfectly applicable.
It’s my calling to “walk through the exercise’ in Court. so when I rail against the stupidity of the Powers-that-Be, it’s harping-away on my perennial point : we are not going to be allowed to win in their ball-park. Rather, the victory is being won by those who go out and do the chores, this evening … actualizing our heritage = this land of REAL MILK and honey. As long as we acknowledge the Source where our food comes from, the race traitors in high places can never take it away from us
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The court must have a definition for public health hazard that doesn’t include everything and everyone. Or it must admit that health hazards are not illegal.
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I just looked up the definition of public health hazard and found that :
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It is not illegal to sell products that are a public health hazard and it is not illegal to drink raw milk. So what was the courts point?
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There is no such thing as an illegal public health hazard.
https://www.youtube.com/watch?v=XbEF42ogYek
However it may very well be just whats needed in order to upset the apple cart.
Have a Happy, Happy, Happy New Years everyone!
Ken
That is a serious taunt. A old and very wise man once said to me….”be careful what you wish for??!!” You might just get it. Well…my wish is that if the FDA approved conditional insterstate sale of raw milk…they would in fact sit down and come up with some really smart and really good standards. That is not a bad thing. That is a challenging but perhaps a very good thing. I know that RAWMI is up to the challenge. We would love to sit down and smoke the raw milk peace pipe with the FDA if they would truly listen and we could share what we know with them from our work with RAWMI and also other great national and international raw milk research sources.
The other side of the taunt is that the FDA would have some serious control over rawmilk….at least if it went over state lines.
All this is wishful speaking….but crazier things have happened.
if I was the FDA, I would seize the opportunity to control interstate raw milk sales and set some very impressive raw milk standards and be done with it. It would make the FDA look good and make that raw milk very impressive as well.
I love challenges. That would be awesome!! Never saw a challenge I didn’t learn to love. Some of them I did not understand up front…but when we figuered them out…I loved them all.
mark
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Has the FDA determine a regulatory limit, or action level? Haven’t they already said that these so called foodborne pathogens don’t normally cause illness in most people?
Here’s a very interesting:
Presentation Transcript on
PREBIOTICS AND PROBIOTICS
and supplementation of lactobacillus culures in animal feed.
http://www.authorstream.com/Presentation/punururavi-2037762-prebiotics-probiotics/
Consumption of Raw Milk: A threat to Public Health
Leslie Nichole Sadeghi – University of Tennessee – Knoxville
Milk-induced allergies are another topic of debate. Poulsen et al. (1987) conducted a study in mice showing that homogenized milk increased the likelihood of milk allergy, whereas raw milk did not. Nonhomogenized pasteurized milk did not induce as much of an anaphylactic response as homogenized milk.
…the cost and benefits of possibly living without allergies verses taking the chance of succumbing to a possibly life-threatening bacterial illness need to be measured. Overall, substantial differences between nutritional values of pasteurized and unpasteurized milk and the specific benefits of raw milk have not been proven scientifically (Potter et al., 1984).
http://trace.tennessee.edu/cgi/viewcontent.cgi?article=2229&context=utk_chanhonoproj&sei-redir=1&referer=http%3A%2F%2Fsearch.yahoo.com%2Fsearch%3Fei%3DUTF-8%26fr%3Dcrmas%26p%3DRaw%2Bmilk%2Bcompetitive%2Bexclusion%2Band%2Blactoferrin#search=%22Raw%20milk%20competitive%20exclusion%20lactoferrin%22
Peas on earth. A little dirt, a little water and there is life growing and sustaining despite the suppression forces that be for money interests.
As a result, home birth outcomes in America are generally good, and likely much better than would be should home birth be banned. If home birth was banned, mid-wives would be denied access to training, insurance, partnerships with the greater medical community, and would be forced to operate “under the radar.” Women would still choose home birth, not doubt. But the conditions would undoubtedly be less safe.
Where one gives birth, what one feeds their family, what medications one choses to use…these are DEEPLY personal decisions, and ones that people are going to make in their own way, regardless of bans.
I implore the AAP and other health and medical organizations to ditch the banning effort in favor of education, information and research. People are going to choose raw milk even though the FDA holds there is no benefit in doing so. And given that fact, if public safety is the primary concern, more research and information is yet needed to promote best practices.
http://childrensmd.org/browse-by-age-group/newborn-infants/vomiting-is-that-yesterdays-lunch/#comments
I guess for a while everyone thought the fish that were caught farther north were probably better because of the colder water. and were not as tainted due to our lovely environment, but I’m thinking it probably doesn’t make a hill of beans of difference. This is a good article which helps clarify the whirrds used today, meant to confuse us mostly. With confusion comes victory, or so they think: http://www.huffingtonpost.com/2008/08/15/sustainable-seafood-wild_n_119175.html
I think we are all a little bit alarmist about our foods though, because we’ve probably been eating a certain amount of radiation, etc., for a long time. It’s not like Fukushima is the first disaster we’re had involving air/ground quality. The military has been using NV as a testing ground for decades and all that stuff in the air had to go somewhere. Not only that but if CA is really having the problems with radiation that people are saying, it would affect all foods, including milk, because the cattle are eating grass which has been tainted by the stuff. It’s not just in the ocean waters, after all. So how would you escape that? And why would it be limited to CA?? That doesn’t begin to include natural pollutants like ash from volcanoes, etc. Volcanoes have been erupting for a long time.
The FDA should be more worried about this metallic kind of poisoning in the food supply if they’re going to take on the subject of food. Mark is right – the FDA should be narrowed to the DA and concern themselves only with drugs (and lose the food part of their *title*), letting the USDA work on the food supply. But there’s a reason why the words food and drug are both used in the same title. We haven’t yet begun to see all the reasons why.