Open Letter to FDA’s Dairy Head, John Sheehan: Why Hide Serious Government Data on Raw Milk Drinkers?

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The discussion following the previous post, about how government-developed data is used, strongly suggests that the American public isn’t being given the complete picture about illnesses from raw milk, and food in general. Now, in this guest post, Michigan lawyer and Farm-to-Consumer Legal Defense Fund board member Steve Bemis provides further insight into the use of government data as affects raw milk, examining why the U.S. Food and Drug Administration intentionally avoids the government’s own data on the number of raw milk drinkers in the U.S. I will feature a number of guest posts over the next few weeks while I am traveling.

By Steve Bemis

Steve BemisI have to give you credit, Mr. Sheehan, for playing your cards close to your chest as the chief FDA enforcer out to ban raw milk.  You’ve carefully directed that FDA avoid any semblance of dialogue on the topic of raw milk consumption, and now I think I know why:  FDA knows too much, and doesn’t want to risk having to answer a simple question:  How Many Americans Drink Raw Milk?

The answer to this question is hugely significant to an intelligent evaluation of the supposed risks in drinking fresh, unprocessed raw milk.  This evaluation, this dialogue with the American public, has had nothing but deus ex cathedra pronouncements from FDA and CDC since the earliest crack-downs on raw milk farmers and distributors beginning in the 2006 time-frame.  The number who drink raw milk is the denominator that is missing to give perspective to the several dramatized cases of illness and the drumbeat of CDC reports of total numbers of illness.  Being sick is no fun, and not to be minimized.  But neither should such cases be maximized without a frame of reference – particularly when the “data” are being used to drive public policy and restrict freedom of choice.

Come to find out, FDA has probably known the answer to this question since at least 2008, and probably since CDC got the data from their own Population Survey, Atlas of Exposures, conducted in 2006-2007 (a similarly-titled Survey dates to 2004, although I have not reviewed it).  In fact, it now seems more likely than not that FDA knowledge of the number of raw milk drinkers was the stimulus for the sudden escalation of crackdowns in 2006-2007 in Ohio, Michigan, New York, California and elsewhere.  The cow was escaping from the CAFO!  Quick, close the gate behind her!

I was made aware of the 2008 survey when Dr. Ted Beals distributed the above link to the detailed CDC source.  The survey was conducted under the auspices of FoodNet, a collaborative network established in cooperation with a program (EIP, Emerging Infections Program) of the CDC; state health departments in CA, CO, CT, GA, MD, MN, NM, NY, OR and TN; FDA’s own CFSAN; and the USDA’s FSIS.  It was huge, conducting telephone interviews with 17,372 interviewees representing a population of 45,883,553 people in the listed ten states, from May 2006 to April 2007.  It was undoubtedly expensive, paid for by taxpayers, conducted by an independent contractor (Clearwater Research, Inc.), and it created statistically-valid state-by-state and total percentages for scores of foods of all types, from potato chips to hamburgers, from lettuce to brussels sprouts, and from tomatoes to raw milk.  There is little doubt that this survey is sufficiently representative to extrapolate to the entire country.

Based on the CDC’s own survey, the average number of people drinking raw milk in this 2006-2007 sampling was 3.0% of the population, ranging from 2.3% in Minnesota to 3.8% in Georgia.

The population in the United States in late 2007 was about 302,000,000 people.  Thus, if someone drank raw milk 3 years ago, he or she was among NINE MILLION RAW MILK DRINKERS.  If the rate has increased today to, say, 4.0%, a raw milk drinker (the survey sampled all ages, including children under 12) is among OVER 12 MILLION.  With increases in raw milk consumption in recent years, there is no doubt the number of people consuming raw milk exceeds 10 million.

Raw milk illness data are a constantly moving target.  From what I have read, the number of reported illnesses from raw milk, excluding queso fresco and similar raw milk soft cheeses, could vary anywhere from approximately 50 to 150 per year over the last 15 years.  There were no deaths reported from consuming fluid raw milk over this entire period.  Using the 9 million raw milk drinker universe and 50-150 annual illnesses, this suggests an annual raw milk illness rate in the range of 0.001% to 0.002% of raw milk drinkers.  It may be more, since not all cases get reported (which usually means they are minor, raising questions about the real cause of a stomach-ache).  But, it’s probably significantly less since the number of raw milk drinkers (there’s that pesky denominator again!) has certainly been increasing sharply in recent years.  So, FDA and CDC, what is the current number of raw milk drinkers?   I’ll bet you know, or have a pretty good guess.

On the other hand, who cares what you know?  I’ll bet I know at least 10 million answers to that question.

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20 Comments on "Open Letter to FDA’s Dairy Head, John Sheehan: Why Hide Serious Government Data on Raw Milk Drinkers?"

Kimberly Hartke
March 14, 2011

Thank you Steve for exposing this important fact. We all know that statistics can lie, and this ones a Whopper!

You may have just cracked the code.

Many kudos to you!

Dave Milano
March 14, 2011

The number who drink raw milk is the denominator that is missing to give perspective to the several dramatized cases of illness and the drumbeat of CDC reports of total numbers of illness.

True, and it is not only the denominator that is suspicious, but the numerator, for we can only guess at what our morbidity and mortality figures would be if our environments were cleaner, our bodies stronger and sturdier, and our hearts more cooperative than competitive.

Todays healthcare systems are far more reactive than preventive, therefore when health problems arise (which they are doing now with ever greater frequency) we rely for care on invented, overly expensive, often destructive, external forces rather than natural, internal ones (drugs and surgery over immunity, long term care facilities over families, government agencies over community, and so on). Our food systems, likewise, are just as artificial as our healthcare, better at supplying positive GDP numbers than healthful nutrition, better at feeding the healthcare system than human beings.

Unless we can turn this tank around we will never know our true potential, never know what normal may be in regard to life and health, and death and disease.

The FDA and the USDA and big-ag and big medicine and all the rest are perfectly happy to entertain half-baked, two-dimensional morbidity and mortality data if they can just keep their paradigm intact. Can Bemis and the rest of the grassroots topple the big monster?

Brian Shilhavy
March 15, 2011

How about a side by side comparison of illnesses during the same period from pasteurized milk?

Ingvar Odegaard
March 15, 2011

In re. Dave Milano's final question- yes.

Mr. J. Ingvar Odegaard

Bill Anderson
March 15, 2011

Its also important to point out that outbreaks from raw milk are usually smaller than outbreaks from pasteurized milk. Although raw milk illnesses may be more frequent (aka more outbreaks) that is only because it is a more de-centralized food production system. The big processors may have less outbreaks events, but their outbreaks affect far more individuals. This fact is not reflected in data that only looks at the number of outbreaks.

Joseph Heckman
March 15, 2011

New Jersey update on legalization of raw milk:
Today in the Assembly 71 yeses and 6 no and 1 abstention.

Bill Anderson
March 15, 2011

Amy Goodman has some excellent coverage of Saturday's historic protest in Madison, WI, against the Walker Administration, including the farmer-labor "tractorcade"

Bill Anderson
March 15, 2011

One question we ought to be asking is if the study is including occassional or former consumers of raw milk.

For example, my mom grew up on a dairy farm and drank raw milk for the first 12 years of her life. She doesn't drink it regularily now, but whenever I visit I always make sure to bring some for her. I also know many people who worked on dairy farms and consumed raw milk in the past, and would again if they could.

The more the FDA talks about raw milk, the more they peak interest in it!

Mark McAfee
March 15, 2011

Great Work Steve!!

It shows the massive bias and the agenda of the FDA and NCIMS and the processors that hate everything about raw milk….cause they do not get to cook it and bottle it and profit from it. The CAFO cow sure has escaped from the steel fence…and now is more and more enjoying the sunshine and grass of Raw Milk production.

Even though I would love to agree to the massive 9-12 million US citizen head count of raw milk consumers, I must ask the obvious question….where does raw milk for 1 million CA citizens come from.

We barely feed 50,000 people each week here in CA with OPDC Raw Milk. Does that mean that there are huge numbers of back yard cows or lots of uncounted cowshares? Maybe…I do not know.

But if this is true, the FDA has a serious ethics challenge and their level of obvious PMO CAFO NCIMS corruption would make the most connected Russian or Italian Mafia bosses jealous.

Having spent tons of time speaking with real people a many farmers markets in CA, I know that most people do not know what raw milk is, most people do not even know what pasteurization or homogenization is…most people think that organic is raw and confuse pastures and pasteurization. Homogenization is soemthing that happens to rich single people in San Francisco.

People do not know milk….

So, that leaves me really scratching my head. Perhaps the question on the survey should be really analized. What did they really ask people? Did people respond to that question from a life long experience basis or was that truly a consumption of raw milk in the last seven days.

Supposing that the data is right and 1 million people in CA drink raw milk ( 3% of 35 million ) then where does the 250,000 gallons of raw milk that they drank weekly come from?????

OPDC only produces 15,000 gallons per week ( plus or minus ). Claravale perhaps 1800-2000 gallons per week. While I agree with the political strength that comes from quoting government data that helps support our cause….I do not get the numbers. There is no basis when the sources are considered.

This google dairy consumption chart says it all….dead milk is dying….

With CPR and added bacteria and life….sales of yogurt doing quite well… the same goes for cheese.

In CA our OPDC RAW MILK sales chart looks much like the Yogurt graph…We need more raw milk farmers….why are they not getting it??? Is the consumer demand and disconnect that distant….is the American farmer that beholden to the FDA???? Is suicide better than change???

CAFO PMO dead milk is a dead end….conventional organic or other wise.


Bill Anderson
March 15, 2011

To answer your question Mark — you have to consider your customer demographic at OPDC, which is largely urban and suburban. Its not all just cow shares that people get raw milk from. Drinking raw milk has been part of rural communities for many generations, on small and medium scale farms. Most don't see it as being that big of a deal until FDA agents with guns and badges show up at their local farm.

And this goes back to your "two raw milks" — many of these raw milk drinkers are getting milk that is destined for pasteurization, which also partially explains some of the illness statistics. This milk could easily be reformed to be a raw market milk, or for making artisan raw milk cheese — in fact, some of this milk is probably already very near to meeting California-style raw milk regulations. There are over 14,000 dairy farms in Wisconsin, and the average herd size is 90, and most midwest and new england states still have a fair number of small to medium sized dairy farms (although they are being driven to the brink of extinction because of historically low bulk milk prices).

Also, as far as the cheese consumption goes, you also have to consider USDA's ongoing subsidies to the cheese industry. The federal government financed the development of the "stuffed crust pizza" in order to drive cheese sales. In Wisconsin — the second largest producer of milk in the U.S. after California — 90% of our milk goes into cheese, and the main cheese produced is commodity mozzerella. Also, yogurt is more shelf-stable than fluid milk.

Not trying to undermine your theory here, just suggesting the reality is a little more complicated.

Also, kudos to Steve for a great analysis!

Steve Bemis
March 15, 2011

There are other hints lurking in the Survey data: "Home-made Mexican style cheese," 4.1% (as distinct from "Store-bought Mexican style cheese," 6.4%); and "Any cheese made from unpasteurized milk," 1.6%. Assuming home-made Mexican style cheese may involve raw milk, it is possible that some of that milk gets consumed before being made into cheese. These data concerning cheese (together with the Survey's introductory information that the two languages used in conducting the Survey were English and Spanish) suggest corroboration of the fluid raw milk data, and may indicate that the consumption of raw milk extends beyond the more visible retail sales and may well include people other than those who read TCP.

Brian Shilhavy
March 15, 2011

I have to agree with Bill Anderson answering Mark's questions. Having lived in Wisconsin and presently living in California, I can say that anywhere you live in Wisconsin you are within driving distance to a farmer willing to sell raw milk to consumers. Here is California it is difficult to find such situations, and we end up paying a premium to retailers who carry Mark's milk. I think Mark, that you milk is primarily sold to those with no rural access who can afford the price in retail stores. That does not represent most of the country buying raw milk direct from the farm.

Bill Anderson
March 15, 2011

Even within Wisconsin, there are different demographics of raw milk consumers. I live in Madison which has a few types of demographics for a raw milk consumer — the foodie locavore type, the WAPF parenting type, etc… If you go to more rural areas, especially Northern Wisconsin, its more just a small-town culture, and many of them consume raw milk simply as matter of immediate access — they live closer to a dairy farm than to a grocery store.

I do agree with Steve Bemis that the majority of raw milk consumers are not of the type that read and comment on TPC. Of course, our activism, advocacy, and research is still incredibly important if we want to maintain access to raw milk and increase the number of consumers.

I am reminded of the quote — "Never doubt that a small, group of thoughtful, committed citizens can change the world. Indeed, it is the only thing that ever has."

Bill Anderson
March 15, 2011

WOW, this is an incredible speech from Saturday's rally.

Family farmer Tony Schultz, a labor activist and member of Family Farm Defenders. Incredible Speech!!!!

Bill Anderson
March 15, 2011

Also, Mark, I wouldn't discount the possibility that (in California) there are undocumented migrant workers on the CAFO farms that drink raw milk from the farm they work at.

March 15, 2011

And don't forget the Amish and all their many children… and all the non-Amish people they supply for $2-3/gal.

An interesting thought about Sheehan's constant references to how drinking raw milk equals Russian Roulette: I recently read that Russian Roulette is actually quite safe because, according to physics and gravity, spinning the chamber with just one bullet before taking a shot practically guarantees that single bullet will always end at the bottom, not the top where it can be discharged.

Using two or more bullets of course changes things… sort of like using dirty raw milk or eating bathtub cheese…

Smy Opin
March 15, 2011

Thank you, Steve for taking the focus off of the "science" and demanding the math!

Here is an interesting thought for folks to chew on concerning how big government and big business do math and risk assessment:

Japan is only 16% energy self sufficient.
It has 55 nuclear plants. These plants supplied only 11% of it's energy needs.

Risk = the entire population and eco system of a whole country, and neighboring areas….
Benefit = 11% of energy needs

I'm sorry, but the math that determined this to ba an "acceptable risk' was skewed by far more than folks wearing rose colored glasses. Those glasses were completely obscured by dollar signs!

The folks making the decisions about our food and health are equally blinded by the dollar signs.

BTW, I can account for some of those missing raw milk consumers –
the number of folks who have acquired their own animals is large and is growing…

Barney Google
March 15, 2011

The Philosophy of Liberty –

People have the right to be free!!

Sylvia Gibson
March 16, 2011

"A new bill up for House ruling in Iowa today would make whistle-blowing documentarians like Robert Kenner of "Food, Inc." fame criminals, reports the Iowa Independent. And similar action is on the table in Florida."

Is this not what hitler, et al did?

Bill Anderson
March 16, 2011

Good catch Sylvia.

"Fascism should more properly be called corporatism because it is the merger of state and corporate power." – Benito Mussolini