I was pleasantly surprised to see the sign shown here at a Vermont food co-op where I like to shop—truthful labeling that contrasts with the questionable labeling of almonds in many food stores, often suggesting they are “raw” when they have been pasteurized.
There’s a big controversy that is ongoing about the labeling of genetically-modified food, with Congress well along in passing legislation that would prohibit states from requiring the labeling of GMO food.
I mention truth in labeling because a few days ago, the U.S. Food and Drug Administration posted a notice on its web site that it was seeking input to help it “minimize the impact of harmful bacteria in cheeses made from unpasteurized milk.” The agency said it was particularly “interested in learning more about the standards and practices in use by….the growing artisanal cheese manufacturing community.”
All innocent stuff, the FDA suggested, “part of an ongoing discussion with industry and other stakeholders about potential health risks associated with consumption of cheese made from unpasteurized milk…” Except it’s not really a “discussion,” but rather a monologue that has been going on for the last 11 years, in what can be more accurately described as an FDA campaign against raw milk cheese. The exact opposite of truth-in-labeling.
The FDA said it was seeking comments and data because it had just released “a joint FDA/Health Canada Quantitative Risk Assessment. This is apparently the latest version of a paper first issued in early 2013, which I analyzed for Food Safety News, in which I questioned the agency’s conclusion that soft raw milk cheese is 50-160 times riskier than pasteurized-milk cheese, even though the agency couldn’t identify a single outbreak of illness over a 23-year period, aside from a few from queso fresco cheese.
So what about the new version of the risk assessment the FDA is now trumpeting? Well, as co-workers used to say at a place I once worked, “Same sh**, different day.” Among the most obvious problems:
- The actual full written risk assessment is nearly impossible to find. There’s no link to it on the FDA web site notice, even though it is supposedly the main reason for the request for comments and data. I had to get some expert help in locating this chart, and way down on the list is the mysterious FDA risk assessment.
- Once you find the assessment/report, it’s nearly impossible to read, because its 177 pages aren’t written in anything approaching understandable English.
- Predictably, though, the material that is understandable does what the previous version of the risk assessment I wrote about two years ago did: It concludes that soft raw milk cheese is much more dangerous than pasteurized milk cheese, even though nearly all the outbreaks and illnesses it lists on page 19 come from pasteurized milk cheese. Of 18 outbreaks of illness from listeria in soft cheese that sickened 473 people worldwide since 2006, only one outbreak, involving 15 illnesses from listeria in blue cheese (in the U.S.), came from raw milk cheese. Everything else? Nearly all pasteurized milk cheese, or else the pasteurization status wasn’t clear.
The FDA’s risk assessment doesn’t bother to dwell on such central information, which contradict its campaign against raw milk cheese. Indeed, I couldn’t find any discussion about the actual illnesses. Instead, it goes through hypothetical risk models—what-ifs, what might have been, what could happen. It points out that there have been dozens of recalls of soft raw milk cheese in the U.S. because listeria was found in the cheese or the production environment; what it doesn’t say is that these recalls rarely involve illnesses. That’s because the FDA is nearly alone among developed countries in adhering to a zero-tolerance policy on listeria, even though it’s been well established that small amounts of listeria pose little danger of illness.
And the FDA concludes that raw milk cheese, even under the best of circumstances, which entail it being treated with “a hypothetical substance (an antimicrobial voluntarily added during the manufacture of the raw-milk cheese) that would reduce the L. monocytogenes concentration present at the surface of the cheese by 2 log10 cfu would provide a lower mean risk of invasive listeriosis per serving than estimated in the raw- milk cheese baseline, but this risk would still be 50 and 86 times higher than the mean risk per serving of pasteurized-milk cheese, as estimated in the pasteurized-milk cheese baseline, in Canada and the U.S., respectively.”
Yes, even if the raw-milk soft cheese were treated with some imaginary purification agent, it would still be 50 to 86 times riskier than pasteurized milk cheese. Can’t win for losing.
And therein lies the FDA’s “problem” since the start of its long campaign against raw milk cheese—the campaign has been unable to demonstrate via real-life data that raw milk cheese, even soft raw milk cheese which it assumes is the most dangerous and thus would make the best target for its campaign against raw milk cheese, poses any danger.
Why doesn’t the American Cheese Society, which represents hundreds of artisanal raw milk cheese producers, speak up about this crazy charade, how this campaign against raw milk cheese could lead to its ban? Because one smart move FDA made in its campaign against raw milk cheese was to co-opt the potential opposition. The ACS made an ill-advised decision to cooperate with the devil, and so it has become a “partner” in this insidious campaign against truth in labeling, and is now left speechless.
David, this travesty of science and data goes even deeper…..it is not possible to make an honest assessment of raw milk cheeses, because the definition of raw milk cheeses is completely adulterated. Milk that is heated to 155 degrees can be labeled as a Raw Milk Cheese!!!!!
The problem is that raw milk cheeses are not defined. Milk can be heated to 100 degrees F and be truly raw…or it can be literally pasteurized just 1degree under PMO temps ( fake raw ) and miss branded as raw! Under the FDA they are the same…physiologically that are completely different. One welcomes listeria and the truly raw does not!!!
Lies….and more lies compounding the first round of lies. The truth is so deeply buried underneith layers of regulatory loopholes and carve outs…it is difficult to make any relevant assessments.
It makes me sick…I was born into a family that taught and lived an ethical and moral life. This issue conflicts with everything I believe.
Lets not get started on USDA approved misbranding and mislabeling of raw almonds. That is simply a bold faced lie approved by the USDA.
What is a citizen supposed to think of a government that lies to us.
This citizen believes in teaching the truth and exposing the SOB’s
“Same sh**, different day” = the typical lip service + the usual measure of misinformation and deceit.
C.S. Lewis dscribes it well, “I live in the Managerial Age, in a world of “Admin.” The greatest evil is not now done in those sordid “dens of crime” that Dickens loved to paint. It is not done even in concentration camps and labour camps. In those we see its final result. But it is conceived and ordered (moved, seconded, carried, and minuted) in clean, carpeted, warmed and well-lighted offices, by quiet men with white collars and cut fingernails and smooth-shaven cheeks who do not need to raise their voices. Hence, naturally enough, my symbol for Hell is something like the bureaucracy of a police state or the office of a thoroughly nasty business concern.”
Dear David,
sitting here eating my raw goat cheese soft cheese. Hand milked by me, and fully knowing that my milking hygiene was low in the dirty warm goat shed.
Thank you for your investigation into the study. A QMRA that is performed with investigation and selection bias will yield whatever result you are looking for. Seems strange not to include data from Europe where there are an abundance of raw cheeses and lots of consumers, and furthermore god centralized data on food-related outbreaks.
The challenge with tracing back bias is always a problem, since many people eat pasteurized fresh cheeses it becomes very difficult to identify it as a source for thr illness, compared to the small nichee consumption of raw cheeses, where source attribution is easier.
Cat, the FDA actually suggests in its risk analysis that there are problems tracing back illnesses even for small-batch consumption of soft raw milk cheese. It says, on p. 20, “Importantly, the majority of listeriosis cases are sporadic cases, i.e. not linked to outbreaks (86% of the listeriosis cases reported to CDC (2013c)). There is very little information about the origin of these sporadic cases (Varma et al. 2007). For multiple reasons (small batches, extreme heterogeneity of individual susceptibility), we expect to see primarily sporadic cases of listeriosis linked to small-scale cheese producers. Note that a French case-control study carried out on 120 sporadic cases of listeriosis observed in 1997 indicated that some cases could be associated with consumption of soft cheeses ((De Walk et al. 1998) cited by (De Buyser et al. 2001)).”
“Sporadic cases” are individual cases–not “outbreaks,” which are clusters of two or more cases–and tend not to be investigated. So what the FDA seems to be saying is this: The reason there are practically no outbreaks involving raw milk cheese is that the illnesses are sporadic, except we can’t even make a clear association between those illnesses and raw milk cheese. But don’t worry, we’ll keep working at it. We’ve been at it 11 years now, and we have endless amounts of time and money to keep up the drumbeat about the dangers of soft raw milk cheeses.
To state that there are cases of sickness all over the place, but nobody knows of these because they are not reported, is a fact-free, science-free statement. It, however, IS propaganda.
Dear Catharina,
Hi,
LiveMy name is Nancy and I live in the Northeast Corner of Mass. I have Lupus, (an autoimmune disease), and my immune system is shot.
I remembered my mom, used to make me Homemade Yogurt, using Raw Milk, and ADDING RAW, Live, Probiotic, Cultures to the milk. (Probably she adding a 1/3 cup of Yogurt), to the milk, to have it grow GOOD BACTERIA, for the “GUT”.
I take three capsules of RAW, Organic, Probiotics, covering 33 Strains of Probiotic Flora, in the Billions, live cultures, per capsule. These Capsules are becoming too expensive for me to continue taking them, in that form. I decided to make my own Yogurt, and use Raw Milk, and adding my “OWN 33 STRAINS of PROBIOTIC, TO MY own Yogurt.
Do you have any suggestions, or a referral, to someone, who knows, how to do this.?
I have made my own Yogurt before, when my two sons were babies. They had a lot of allergies, in the mid 1970’s, and the homemade yogurt really hel;bed them.
I just picked you out, on this site, hoping you could help me.
I appreciate any help you could provide.
My understanding is that the queso fresco cheese that was contaminated was illegally imported into the SW United States by illegal aliens. Right now, there are millions and millions of $$$ of Mexican groceries being imported in cars and vans to the Mexican-owned grocery stores all over Texas, Az, and NM that i’ve seen. Probably all over SoCal too, just haven’t personally seen those….
Then we can assume those foods are safe 🙂 Unless all those deaths and illnesses are not being reported.
Yes, you can assume the foods in question here are safe. Otherwise, the FDA would do research based on real illnesses. But since the FDA can’t find real illnesses, it must resort to made-up illnesses (another term for what they call “modeling” and “risk analysis.”).
I believe they bring food in because they are trying to bring in fresh live food. A lot foreigners have a higher expectation of food quality than of those Americans born in the USA. I often shop in Mexican, Chinese, Middle Eastern markets because their food especially meats are fresher. The herbs actually smell pleasant where the American chain stores often have produce that have no fragrance.
David –
First of all – THANK YOU!!!! So few of us stuck around after NAIS… I, for one, applaud your tenacity as well as your persistence!!
Sleeping with the enemy has plagued us from the beginning. Many would rather throw cash at a cow than drink the milk if you will pardon the obvious analogy.
We need more grocers and small businesses to take up the idea – and to promote these as places to get food. ONLY when we hit the corps in the wallet will they sit up and rub some of the sand out of their eyes. Even then it will still be a fight, but at least we’ll have SOMETHING going for us! Chair sitters (politicians) and corporate honchos certainly don’t want to listen – so we need to develop our local markets and contacts further.
What has become known as the DARK Act is just the tip of the iceberg, and we are all going to be called upon to trumpet the truth to whoever will listen. Its not just the labeling issues, as you yourself have warned, but many of the bills that we defeated/changed during the NAIS fight are coming back under different titles with different marketing – all the same thing.
Unfortunately, some of us (me!) have had circumstances change drastically since those days, and don’t have as much time to devote to the research. Unsolicited materials sent to the newspapers aren’t being printed as often as they used to be, information is harder to find, and when it can be found, figuring it out is nearly impossible without a copy of Black’s on one hand and an engineer sitting on the other side.
And yet, the studies themselves are quite easy to read and understand. Its finding them and then researching the $$$$ that gets a bit complicated.
Nobody (sans present company, of course!) wants to hear that the “findings” of the gooberment are based on cash, lies and deception – but that fight continues in other areas in addition to ag and food. Everyone wants to believe that FDA/USDA et al are conducting research and yet it is the same as it always was…. The corps are doing their own, paid and skewed research which the Alphabet Agencies then regurgitate along with pseudo-legislative directives, initiatives and “rules.” And that is when actual research is done at all!
How many of us realize that these things are not law? We are justly worried about actual bills, but how many watch register notices and other types of under-the-radar crap in both our individual states as well as at the federal level? They enforce them as if they were law when they are not. Therefore, whatever actually comes to the floor usually follows what is in the registers…
We need to reform, restructure and redouble the effort and commitment we had in fighting before, and hit them right where it hurts. We are, after all, gearing up for another prize fight for the White House as well as a number of hotly contested seats in the states as well as the federal legislatures!
My new rally cry is “Send them ALL home!” (Not that anybody running is any better than what’s there already, lol)
Always,
GrannySue
Hear hear!
I don’t think the truthful labeling of almonds that are truly raw deserves much commendation other than kudos for raising awareness of the U.S. government pasteurization requirement. No risk to the store in that case.
Now if a store labeled almonds that are usually labeled raw as actually being pasteurized via steam, irradiation, or fumigation, that would be something to cheer about. A consumer seeking raw almonds might take their business elsewhere, thinking almonds sold elsewhere with the label of raw are truly raw.
Mr. Gumpert —
Great post. I nearly gagged on my coffee when I read Brad’s Aug. 3rd comment regarding the FDA’s research being “fact-free” and “science-free.” Great comment, Brad! And right on point. It’s like I heard it said before, “Never let the facts stand in the way of a good story.”
Rule of thumb why can’t it be rule or first middle finger/ never mind if you do
http://www.chow.com/food-news/134471/can-you-get-sick-from-eating-moldy-cheese/
Not entirely OT, but I didn’t know where else to put it when it came to David’s current posts.
I found this article by accident (didn’t even know the site existed, and I was searching for something entirely different), but read it anyway. A few (if not more) TCP readers won’t exactly like what was written. It’s a short read, but most of you will figure it out (I’ll give one hint: genetically modified seed, and the remainder of things mentioned in that sentence will likely stir things up).
http://www.thebullvine.com/news/consumers-dont-care-if-u-s-farmers-feed-the-world/
I wonder what corporations support The Center For Food Integrity, sponsor of the article Dairy Duchess links to. A quick glance at their web page makes me think I wouldn’t agree with their idea of food integrity.
DD
In response to the article you provided, affordable as in “affordable food” is a highly subjective term in North America (the land of the plenty), where farmers have to source off farm income in order to provide for themselves…in essence subsidizing the farm gate price of food thus making it, “AFFORDABLE”.
Such a scenario, is not sustainable resulting in the erosion of family farms, the deterioration of healthy food in all its abundance and shamefully wasteful where North Americans throw out more food then many countries are capable of producing.
http://www.worldwatch.org/node/4060
http://persquaremile.com/2012/08/08/if-the-worlds-population-lived-like/
In truth, it is not the job of the USA to feed the world. Where did we get that idea? Or, should I say, where did our goobermint get the idea that it WAS our job? It’s also not our job to police the world, or protect the world. We are NOT a superpower, never were. And we should stop claiming we are. We get into trouble when we brag; are the prez & CONgress never going to understand the principle?
Ken,
I tried to find it, but could not, and it is in reference to being wasteful. I remember reading about a trash/garbage collector who made the observation that the areas which had the most food thrown out were poor neighborhoods. This doesn’t surprise me, and I’ll tell you why. If they have their food subsidized, why would they care if some of it gets thrown out? I’ve seen that kind of attitude with other things as well; it isn’t costing that person anything, so it doesn’t matter. There’s no appreciation for whatever it is they got for nothing/cheap.
I’m not saying everybody is this way, but I’ve seen it plenty of times with my own eyes. It’s kind of like this: a person borrows an item from someone, ruins it, and says, “So what? It isn’t mine”. I just apply that same attitude when it comes to food, because it’s basically no different as far as I’m concerned.
As for the link, I was searching for information on a particular AI bull, and the ‘Bullvine’ site came up. I never heard of it. While scrolling through the other links on the page, that’s when I found the one I posted. Some of the other links I saw were nothing more than a joke to me. It’s like, “Seriously??? You actually believe this nonsense?”
David, all excellent points, although I think your characterization of the American Cheese Society is a bit unfair. They are engaged in the battle, but need to do so in a manner that keeps the channels of dialogue open with the FDA. I know for a fact that immediately following the just-completed ACS conference in Rhode Island, there were extensive meetings between the FDA and ACS board members and other parties to discuss this matter and bring the voice of artisan cheese makers to the table.
Matt, I know ACS reps have had extensive meetings with FDA over the last few years. Unfortunately, they have had about as much of a sense of equality and respect as meetings between the Germans and the Greeks. In other words, ACS kind of crawling in on its knees and hoping for a few crumbs of recognition. I believe it was the ACS that announced the FDA’s raw-milk cheese testing program, as if it the ACS was an important insider in the know, when it should have been questioning the very premise of the program. Because it’s been playing a subservient role, at best, ACS hasn’t been of a mind to raise tough questions or complaints–at least as far as anyone on the outside is aware.
I’d say the best that ACS members can hope from this “collaboration” is that the FDA feels compelled, when the FDA’s 11-year raw-milk-cheese adventure finally concludes, to suggest flexibility on its side, as if to give ACS some credit. I fear, though, that the examples of FDA flexibility will be all show and no substance. The substance will be a crackdown on raw-milk cheese. I truly hope ACS proves me wrong.
With the blog owners’s permission, I would like to add some context to this post.
At first, it may seem that large commercial dairies would have little to lose to competition from artisanal creameries. However, over years of trying to start a dairy/creamery in Maryland, I’ve gleaned the following:
(1) The government keeps the price of milk relatively low. This stimulates farmers to produce more, since the profit margin is lower, and only by increasing production can they make a living.
(2) In turn, milk haulers, the kind with tanks that hold tens of thousands of gallons, have a small profit margin.
Both dairies and milk haulers run 24/7 businesses in order to stay in business.
Enter artisanal dairies/creameries as competition, and the already slim profit margin for larger concerns becomes razor thin.
It seems to me, then, that the FDA, to the extent that it perceives itself as representing the interests of larger dairies, may have an agenda of limiting the expansion of artisanal producers.
Joe Orlow
Softwine LLC
torah104@gmail.com
(301) 812-4050