I am away this week. Steve Bemis has written a guest blog post. Steve is a Michigan lawyer active in local agriculture and food-rights issues, and a member of the board of the Farm-to-Consumer Legal Defense Fund. He comments here about the larger questions that rarely get addressed concerning food-borne illness.
You may be familiar with the elephant-in-the-living-room teaching moment. The group leader helps to expose the “elephant” as the overwhelming previously-invisible presence influencing the group’s process. It’s the assumption that noone speaks of either because it’s too obvious, or everyone believes it, or no-one wants to talk about it – usually, a combination.
One elephant in the raw milk discussion is this: why doesn’t everyone get sick when there is a cluster of apparently food-born illness? Through studies which tilt heavily to the circumstantial and often far away from hard science, epidemiologists (usually over-worked and under-funded health department employees) wage an ex-post-facto effort to find a pathogen to blame. This search is based on the premise that an external agent (germ) has invaded. Other possible scenarios are given short shrift, and a more sophisticated understanding of how food-borne illness occurs, gets lost.
Assuming they conclude a pathogen was responsible, we may expect a snort from the invisible elephant: why didn’t everyone get sick? Answering the elephant’s call is hindered by at least two factors. The first smacks of elitism: my gut is healthier (or at least, different) than yours. A second is the cornerstone beliefs of Western science and culture: science can find answers and we can fix almost any problem. Lost critical systems in your moon-mission? No problem, we’ll bring you around the dark side and home again. Indians bothering you? No problem, John Wayne will fix things up.
Setting aside elitism, however, the question remains. Assume the majority of raw milk drinker guts are healthier and they don’t get sick in an outbreak, why is this? At least one hypothesis suggests itself (unstudied as far as I know), namely through some unknown combination of factors, even some long-term raw milk drinkers will get sick. The test for this hypothesis might be to feed the supposedly offending milk to a control population of non-raw-milk drinkers, and see how many of them become sick.
Such studies have obvious ethical problems, typical in many human studies, although in at least one published incident report, regular drinkers of raw milk (presumably, pre-pasteurized) were shown to have significant antibodies to campylobacter and did not get sick. Another possibility is that the concentration of pathogens may vary greatly in a body of fluid, with greater concentrations possible in a given “slug” of product, thus upsetting even a healthy gut.
It seems that medical researchers are beginning to creep up on these issues. Recent suggestions that gut diversity is important to overall health have been escaping academia and the medical establishment. As well, there is the European study of children which showed significantly lower incidences of allergic reactions (hay fever, asthma) in those drinking raw milk. Clearly more work is needed, and now appears to be under way as Western science attempts in its own way to isolate, quantify and thereby understand.
All food comes to us from the soil, through plants and animals. So the analysis of gut health is far from simple. The variables are likely infinite (not to mention the ethics of studies), and so to concentrate on one is myopic making little sense on the broad canvas of life. Rather than militaristically targeting one “pathogen” after another — causing untold collateral damage in the process — it seems our challenge is to understand the wealth of diversity in which we live, to get the most healthful result by teasing out the best soil enrichment, plant selection, animal husbandry, and kitchen techniques for healthful eating and living.
I wonder as I watch my dogs supplementing their diet occasionally with rabbit and deer droppings–less so since beginning to feed them small amounts of raw meat and vegetables — or quenching their thirst from the well-used birdbath, how really important it may be to have a bit of dirt on one’s plate, or in one’s glass. Indeed, if one lived, even today, in parts of the ancient world or in ayurvedic India, the elephant in the room (or, for that matter, the sacred cow) would not need a group facilitator to be noticed.
Mark, have you heard that Mary Keehn is selling Cypress Grove chevre to Emmi USA? Emmi is the largest milk processor in Switzerland, and also recently acquired Roth Kase USA in Wisconsin (another Swiss company, which relocated to the U.S. in the early 90s).
http://culturecheesemag.com/news_cypress_emmi
Who knows why? Perhaps she is in the same kind of dire straights as the other creameries in Humboldt County? Perhaps she just doesn't want the financial liability anymore. I don't know, but I do know that Roth Kase was a major distributer of her cheese in the Midwest prior to their acquisition by Emmi USA.
Bill Anderson (no longer in Wisconsin… now in Ohio)
Humboldt is in trouble because they can not complete with the commodity feed prices ( trucking costs fortunes up there ) and other factors given their very remote area and lack of close access to markets. The CAFO systems in drier areas of the state out produce Humboldt.
Sound like the Humboldt producers will need to create very high value added products to complete. This means cheeses, yogurts and may be even some local raw milk.
If not….it is not pretty. Humboldt Creamery is burnt toast already.
Mark
Yup. And western science in the form of double-blind, controlled-variable study is not the only way to get there. In fact, reliance on narrow studies can waylay us, as Steve suggests. Simple, honest, macro biological observation, coupled with a willingness to adapt to what one learns, is the best method. Its the highest form of science, really. We do better always when we capitulate to nature, and use our focused research more to help learn the why than the how.
Bravo! TERRIFIC blog – Thank you!
If we got close to understanding this elephant, we'd be so robust, and I suspect the earth would be too.
Re your dogs' "supplements " of deer droppings and mud puddles – I read a while back that we needn't worry about dogs catching Salmonella from a raw food diet, because they have (had ?) such strong gastric juices that no pathogen could survive.
Recently, there was a recall of dog kibble because dogs were "catching" Salmonella. I read this and thought Hmmm, so dog digestion is becoming more like human digestion? (Seeing how rampant HCL acid problems are in humans nowadays….)
Reading your blog, it occurred to me that perhaps HCL acid qualities may also have something to do with why some raw milkers get sick, and others not. Is it because most dogs have been allowed to freely supplement – until recently – now that corporate food supplies dominate their diet, and fewer people take their dogs hunting?
Maybe exercise – good circulation, and/or sweat, which has antimicrobial properties. (Exercise before you eat, and Eat with sweaty hands?) Maybe it's sunshine. I realized I've had this same elephant in my living room for years, but until you legitimized the question in print, I never even ventured outside the bacteria paradigm (Not that I'm convinced it isn't a bacteria issue – I just never really let that elephant wander around before.)
Thanks for the nourishing thoughts,
-Blair.
Wonderful post…nice work!
May I offer some additional evidence that it is the biodiversity in the GUT that matters most when it comes to food safety, immunity and food allergies.
http://www.aolhealth.com/2010/08/04/pediatric-food-allergies-on-the-rise-in-u-s/
http://www.sciencedaily.com/releases/2009/06/090618170026.htm
http://www.sciencedaily.com/releases/2010/06/100602193326.htm
The answer is crystal clear and ragingly loud to those intelligent enough to listen and observe.
The problem is clearly….the FDA, Big CAFO Ag and Pharma that would loose their paychecks if they did listen, observe and respond…."the FOOD INC syndrome".
This is not about safety….it is about money and market control.
It is unsafe to eat CAFO food and go to doctors…..that is the safety issue.
I love the conscious superminority that eats and lives well.
They will inherit the earth….that is if they are not taxed to death by idiots that are dying and getting sick constantly and requiring medical insurance to fund even more drugs that sicken them even more.
Mark
The solution to poor gut flora diversity and the ensuing illnesses, allergies, & inflammation that result isn't going to be found in bags of prewashed, peeled "baby" carrots and so on that people find so "convenient", but rather in local carrots, etc., freshly pulled from healthy soil, lightly rinsed with plain water or even wiped clean of field grit.
http://coolinginflammation.blogspot.com/search/label/gut%20flora
I think the real elephant in the room is that information is always changing – at times radically so. We used to believe that in the absence of infection our lung tissue was completely sterile. This was because the old method of culturing healthy lung tissue to identify microbes never yielded any growth. Now, through PCR, we can see that there are many species of microbes occurring naturally in healthy lungs. This is quite a paradigm shift from "sterile good, microbes bad".
Likewise, with the inside of a cow's udder.
Ken Conrad
There was salmonella in the chicken feed!!
The officials said investigators found salmonella in chicken feed that was sold to both Wright County Egg and Hillandale Farms. More than 550 million eggs from the two farms were recalled this month after they were linked to as many as 1,300 cases of salmonella poisoning.
Where was the FDA? How about you regulator, milky way and cp?
The FDA was probably investigating a dairy farm with one cow.
http://www.washingtonpost.com/wp-dyn/content/article/2010/08/26/AR2010082604062.html?hpid=topnews
Well, look at the bright side… it's kinda hard for TPTB to justify harassing raw milkers with very few illnesses, after slipping so badly on infected eggs that sickened or could sicken millions.
Irradiation and egg pastuerization, here we come!
Something for your consideration…FDA has federal regulations 21 CFR 1240.61 and 21 CFR 131.10 relating to raw milk (which, BTW, were forced upon them in 1987 by a judge ruling). They have nothing similar for on-farm regulation of eggs, feed, etc. Regulators enforce what's in the, well, regulations. There isn't anything with teeth for big ag on-farm production. Although I know many here loath and are suspicious of SB 501 (perhaps with some reason given the "raids"), but notice that it does have the potential to keep FDA busy with the Parnell's and Decoster's of the world instead of focusing on 21 CFR 1240.61 and 21 CFR 131.10 . Think about it…they'd have new CRFs to focus on that currently don't exist.
MW
1240.61 wasn't "forced" upon fda. what the court said in the heckler case in 1987 was that fda must promulgate a rule that REGULATES the "sale" of raw milk. what fda did instead was PROHIBIT the interstate "distribution" and "delivery" of raw milk in interstate commerce. not only that, 1240.61 also classified "raw milk" as a "communicable disease," you know, like measles, mumps, rubella, aids, typhoid fever, scarlet fever, etc. i wonder when fda will consider an apple a "communicable disease?" please read the rule and its history before making such posts.
as for your comment that "There isn't anything with teeth for big ag on-farm production" and ""regulators enforce what's in the, well, regulations." DUH! who do you think promulgates the regulations? fda does. why aren't there any fda "teeth" for big ag on farm production? because fda has chosen not to regulate big ag farm production with teeth.
fda can certainly promulgate a rule under the authority conferred upon it under the food, drug and cosmetic act and the public health service act that will give it "teeth" to regulate big ag. not surprisingly, fda has chosen not to do so.
as for sb 501, you must be naive to think that fda won't use that additional authority to quarantine raw milk, or execute warrantless raids on raw milk producers, or require the production of all sorts of private, business records without cause.
Naive is not the word I would use. And trusting the FDA, if one is not a large corporation, is totally foolish. They have been corrupted (bought) by the influence of Big Money.
Oregon farms Alert!! Charlotte Smith said: FYI… I am a legal raw milk dairy in Oregon. Yesterday we received a call from the Or. Dept. of Ag Food Safety Division that they received an anonymous call that I was doing something illegal. No mention what, but the ODAg. had to follow up. 6 hours before that my brother who sells meat at a farmer's market was asked …if he would bring raw milk to the market if this person prepaid. He said of course not, you must drive out to the farm. I'm not sure if that was the ODAg. calling first & testing us… I'm just wondering if there's a way you can let your Oregon fans know this is going on. I know many customers take their access to raw milk for granted and it's being threatened all the time. Maybe you have suggestions for us all on what we can do to get more involved and protect our access to real food??
Giving up its Grade A rating allows Siskiyou Crest to sell raw goat's milk
August 24, 2010 2:00 AM
Calling Oregon Department of Agriculture's policies misguided, owners of the Siskiyou Crest Goat Dairy on Monday voluntarily renounced their state-sanctioned Grade A creamery dairy license.
In addition to giving up the highest ODA rating achievable for an Oregon dairy, Michael "Mookie" Moss and his father, Roger, co-owners of Boone's Farm half a dozen miles south of Jacksonville, launched a herd share program allowing customers to own a portion of the herd to make it easier for them to provide raw milk and other raw dairy products.
"As a community-based dairy, we are proud to have met and exceeded Oregon's Grade A standard," Michael Moss said. "However, the licenses that earned us a Grade A standard came at a cost."
Although they were allowed to sell raw dairy products before giving up their license, he described the red tape as too much for even a goat to chew through.
Moreover, when offering their wares at a local farmers market, they often had to either trade their product or simply give it away, he said, noting the restrictions were such they invariably turned away five to 10 customers.
"We have been saddled with regulations that have inhibited our ability to provide our community with a product that is very much in demand, a product we very much believe in and stand behind, that product being raw milk and cheese," he said.
Department officials, noting the regulations are in place to safeguard food safety, say the Mosses' decision, while unusual, is legal, as long as the customer is also the owner of the farm animal.
In fact, herd share program participants buy into the herd and assume ownership of an animal as well as the products it produces, Michael Moss said. The national Farm-to-Consumer Legal Defense Fund helped the dairy by drawing up legal contracts for herd-share customers, he added.
"Right now, the public's ability to receive farm-fresh raw milk is greatly hampered by state and federal agency regulations," he said. "These agencies treat raw milk as a dangerous and hazardous substance."
But he said the hands-on approach commonly found at small family-owned farms enhances food safety.
"When we look across the agricultural landscape we see an unacceptably high number of product recalls and food-borne illness," he said. "The lion's share of these problems originate from the industrial factory food production sector, not the family farm."
There's more – full article here: http://www.mailtribune.com/apps/pbcs.dll/article?AID=%2F20100824%2FNEWS%2F8240325
And a follow up article
Owners' move is a first, officials say
August 24, 2010
The decision by the Siskiyou Crest Goat Dairy owners to terminate their top-rated Grade A license to adopt an alternative ownership model marks a first for the Oregon Department of Agriculture, said agency director Katy Coba.
"We're not aware of anybody giving up a Grade A license in order to move in the direction the Siskiyou Crest dairy is moving," she said Monday in a telephone interview.
However, plenty of Oregon dairy owners over the years have given up their licenses when they were going out of business, she noted.
After reviewing the statute, her staff concluded that the herd-share program the dairy owners plan to practice is legal, she said.
Full text here: http://www.mailtribune.com/apps/pbcs.dll/article?AID=%2F20100824%2FNEWS%2F8240326
http://www.washingtonpost.com/wp-dyn/content/article/2010/08/27/AR2010082701957.html?hpid=sec-health
MW
We're still waiting for your promised reply to the David's post about the CDC/et al cooking the books.
Instead we get lies and misinformation from you about 1240.61
" Genomics and the bacterial species problem"
W Ford Doolittle* and R Thane Papke
"Whether or not bacteria have species is a perennially vexatious question. Given what we now know about variation among bacterial genomes, we argue that there is no intrinsic reason why the processes driving diversification and adaptation must produce groups of individuals sufficiently coherent in their genetic and phenotypic properties to merit the designation 'species' – although sometimes they might."
"The species problem is caused by two conflicting motivations; the drive to devise and deploy categories, and the more modern wish to recognize and understand evolutionary groups. As understandable as it might be that we try to equate these two, and as reasonable and correct as it might be to use taxa as starting hypotheses of evolutionary groups, the problem will endure as long as we continue to fail to recognize our taxa as INHERENTLY SUBJECTIVE(emphasis added), and as long as we keep searching for a magic bullet, a concept that somehow makes a taxon and an evolutionary group both one and the same."
Jody Hey [1]
If farm animals exchanged genetic material the way that bacteria do we would find it very difficult to put them in categories too.Suppose when the pasture was too short for the cows to get enough to eat that they acquired the genes to grow a duckbill and waded out into the swamp to graze on the duckweed.If we categorized it by what it consumed we would think of it as a large, four legged, flightless duck.Species designations of bacteria are subjective.The designation depends entirely on what part of the genome we choose to categorize it by.Unless we consider the complete genome of each individual bacterium we can't say if the are related or not.When we consider the complete genome we realize that we do have a lot more diversity than we thought.
Why does this matter?When the epidemiologists say they found the same species(salmonella) and strain in the sick people and in the chicken feed,we need to ask if they have sequenced the whole genome or just a part of it .If it was only a part then what was their reason for only looking at that part?What percentage of the genomes really do match?
TC, don't get your panties in a wad. Here's what I put together separately for David about the CDC conspiracy on data:
1. If you go through the CDC online database year-by-year, the numbers add up. No secrets.
2. The total number of illnesses in outbreaks linked to raw dairy in the press releases are a combination of everything including a food vehicle that had "unpasteurized" milk in it – legal and illegal raw dairy products; there is no discrimination regarding whether it was unpasteurized milk intended to be sold as raw milk, cheese, ice cream, etc. Mexican-style cheeses made with raw milk implicated in outbreaks/illnesses are included in the count.
3. The illness counts only include those that were tied to an outbreak. Sporadic (individuals that got sick and were not part of an outbreak are not counted). So this total is actually an under-estimate. Additionally, the outbreak-related illnesses include only those people who went to the doctor and then got reported as part of an outbreak. Who knows how many were missed in the counting.
The database is completely transparent. You can argue that public health should break down the illnesses and outbreaks based on whether they were from legal/illegal raw milk, or break it down more by milk vs. cheese vs. ice cream vs. etc. But, you could say the same thing about other foods like deli meats. Should they break it down to how much turkey meat vs. bologna caused illness? Maybe some bologna activist would think they should. Anyway, check out the database. It is transparent and it is what it is.
Thanks.
MW
If you are going to impugn raw milk for causing illness it should be in liquid form and the person ingesting it should be knowingly consuming it. Otherwise it's just padding the numbers to make your case.
Worry about you own panties not anyone else's.
You give no numbers for the CDC numbers. What are the numbers? I see no refuting of David's analysis. Give some specifics.
"Okay…so that thought about giving regulators more power to enforce violations on industrial farms went over like a lead balloon here. Mea culpa, forget that thought."
You should reread Gary's post. Did you even read it?
No comment from you about your erroneous post about 1240.61. Are you lying about 1240.61? Are you wrong about 1240.61? You couldn't be wrong so you must be lying. Which is it?
Or are you just obtuse?
Yes, we CAN argue that public health SHOULD break it down by product…. because the issue is FLUID raw milk for drinking, not bathtub cheese made in Mexico or even San Antonio. Because most raw milk drinkers are drinking raw milk as a lifestyle choice to improve their health and because raw milk tastes very much better than store milk; or, at the very least, they are trying to avoid dead, CAFO milk. This last point is the very issue why Big Dairy is crying and trying so hard to kill raw milk: Once most people drink real milk, they will do almost anything to avoid buying/drinking dead milk again… even to the point of going dairy-less. That is certainly true for me, and all my customers, and everyone I know who drinks raw milk.
"But, you could say the same thing about other foods like deli meats. Should they break it down to how much turkey meat vs. bologna caused illness?"
No, because turkey meat and bologna are very similar deli products, eaten the same way AND sold in far less than optimal conditions compared to bottled raw milk which is not opened until it reaches the consumer's home. Think of the deli case in your local store, with unsanitary hands and grocery store air going in and out of the case all day, not to mention other issues like subclinically ill employees or those who frequently wear the same gloves after touching various surfaces, then grabbing rolls of cheese or meat for slicing, then weighing and bagging the slices. Yet, FDA thinks a deli case is perfectly fine! Talk about hypocrisy. lol
But the main reason why turkey and bologna data should not be broken down is, people do not drink turkey meat while making sandwiches with bologna.
Anther erroneous assumption in the CDC's data is that illnesses from pastuerization failure is considered to be illness from raw milk. In other words, if milk was improperly pastuerized, or if pastuerized milk is cross-contaminated with raw milk and then gets people sick, the CDC considers this to be an outbreak from raw milk.
I believe that Dr. Ted Beals has sifted through the CDC's data, and I know he would have something more to say about this topic. By his calculations, it is more risky for the consumer to drive in his/her car out to the farm ONCE, than it is for him/her to drink properly produced raw milk (be it legal or illegal in the given region) for an entire year.
Talk about prejudice and conspiracy. The food safety and health authorities are extremists and corporate minions of the milk processing industry. There is very good reason why we oppose the latest "food safety" bill before congress, because its only effect will be to further entrench and enforce the corporate monopoly of the food system. I don't for one second believe that the regulators will use it to start going after corporate factory farms and industrial food processors. They will just use it as an excuse to tighten the screws on small scale sustainable farming, as they always do.
When I posted on Bill Marler's blog asking him what the propose legislation would do to improve food safety, I got no response:
http://www.marlerblog.com/lawyer-oped/mr-president-senator-reid-there-are-550000000-and-one-reasons-to-move-on-s-510/
Very telling.
Keep in mind that both E. coli and Salmonella infections are preventable with proper food handling and kitchen sanitation.
By this logic, we should consider all our food to be contaminated and act accordingly.
Point by point:
1. You don't explain how the numbers I came up with might differ from what you say are in the database. For example, are you suggesting that the numbers in the CDC database are different from those CDC supplied to the Farm-to-Consumer Legal Defense Fund covering 1973-2005 under its Freedom of Information Act request? In particular, are the numbers for 1998-2005 supplied to FTCLDF different from those in the database?
2. I never disputed the actual illnesses included in the database attributed to raw milk and/or cheese (which many do). I questioned the CDC's continual reference to "two deaths from raw milk" between 1998 and 2008. That's not a database issue, it's a presentation/communication issue, and CDC is using two deaths from bathtub cheese as part of a propaganda campaign against raw milk. There are no deaths from raw milk consumption, but acknowledging that fact would render moot CDC and FDA arguments that "people can die from drinking raw milk."
3. I have frequently acknowledged that there are likely more illnesses from raw milk/cheese than are included in the database. As I'm sure you're aware, that's the same with any food–there are assumed to be perhaps 20 or more times as many illnesses as are reported, depending on the pathogens involved. You are suggesting raw milk is unique in this respect.
The big point here seems to be CDC misstatements and misuse of its own data, which raises a very serious credibility issue, since the media fully trusts that CDC is being accurate and fair.
David
Q1. The online database you link to in your previous entry is the National Outbreak Reporting System (NORS), which according to the CDC website was launched in 2009. The FTCLDF line lists pre-dated this database. It is possible additional reports were submitted by the states during the process of moving to an electronic system. Also, I don't know which line list you used to come up with your totals from the certified document, or what criteria you used to define "raw dairy." The second list includes all dairy.
Q2. I agreed with that point. Here's an example of a paper where the queso fresco cheese outbreaks are analyzed separately: http://www.foodpoisonjournal.com/uploads/file/Comparing%20Food%20Safety%20Record_Revised(1)(1).pdf
Q3. You misunderstood my point. I only talked about under-reporting of raw dairy cases because those were the numbers you used. The same applies for all of the food vehicles.
To WRMC:
No, if the milk was sold as pasteurized, it is classified as a pasteurized milk outbreak even if the cause was from failed equipment or cross-contamination with raw milk. The exception to that might be queso fresco cheese outbreaks – if pasteurization status is unknown, I think they get classified as unpasteurized since that is the most common way the illegal cheeses are made. Note too that the pasteurized milk outbreak/illness totals include all the norovirus outbreaks even though those were from foodhandler's dirty hands (in most of those cases the pasteurized milk product didn't leave the creamery with norovirus, but someone in a home or restaurant later contaminated it through poor hygiene).
MW
p.s. I don't work for the CDC and never have, so consider these my personal opinions based on studying the issue.
It is undisputed that all types of raw milk are unsafe for human consumption and pose a significant health risk. The appropriate remedy in this case is therefore, an order compelling the agency to promote a regulation prohibiting interstate sale.
Quoted from Public Citizen v. Heckler, 653 F. Supp. 1229, 1241 (1987)
The word "control" in Center for Disease Control must refer to the practice of using the fear of disease to control the people for the profit of the corporate world.Does CDC have any credibility?For that matter, do the individual state health departments have any credibility? They are all run from the CDC and are used by the CDC for it's purposes.
I may be naive as I do not know a lot about "bathtub" cheese, though I will say it conjures a rather frightening image. I can think of myriad adjectives to call something like this, but "illegal" is certainly not one of them.