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Mark McAfee of Organic Pastures Dairy Co., who filed the Citizen Petition that led to a new FDA assessment of raw milk. There has been lots of upbeat news about raw milk over the last 18 months or so. Research out of Europe and the U.S. continues to suggest that raw milk strengthens the immune system so as to provide a protective effect against allergies, asthma, and other illnesses. Indications are that dairies certified by the Raw Milk Institute (RAWMI) are successfully using very low coliform and standard plate counts to reduce the risk of illnesses. And raw milk seems to be growing significantly in popularity, as aggressive federal enforcement actions against raw dairies around the country appear to have slacked off. 

 

So encouraging has the news been that a few raw milk supporters have begun to wonder if, maybe, just maybe, the U.S. Food and Drug Administration (FDA) might be impressed enough to relent a tad in its hostility against raw milk and the people who produce and consume it. 

 

Well, I can’t, unfortunately, report that the FDA is about to relent in an ongoing way. In a new assessment of raw milk, the agency concludes: “FDA remains of the view that there is a demonstrated association between the consumption of raw milk and the outbreak of disease, and that raw milk can contain a wide variety of harmful bacteria…”

 

And the FDA isn’t about to lift the ban on interstate sales and shipments of raw milk, according to the director of its Center for Food Safety and Applied Nutrition, Michael Landa, in the same assessment, a detailed 47-page response to a Citizen Petition from Mark McAfee of Organic Pastures Dairy Co. 

 

However, the FDA isn’t nearly as hostile as it was in a response it provided nearly two years ago, to a similar petition from McAfee. Indeed, the new response to McAfee, completed late last month, actually contains what may be the first-ever positive statements the FDA has made about raw milk: “FDA acknowledges that milk allergy is an important food allergy of concern in the United States, especially in children. We also acknowledge that there have been studies examining infants and young children mostly from rural areas and finding that those infants or children with reduced incidence or manifestations of allergic disorders or asthma were more likely to be raw milk consumers rather than non-raw-milk consumers. In some studies, the association between raw milk consumption and reduced incidence of allergic disorders/asthma was found to be independent of other farm-related factors or living on a farm, and individuals reported to consume raw milk were found to have evidence of certain protective immune markers as a possible explanation for this association.” 

 

Well, the positive remarks end there, on page 7, and beginning in the next sentence, it’s back to business as usual: “Notably, however, these studies do not always distinguish between raw milk and pasteurized milk.” The document then descends into denial and rejection of any positives about raw milk, including the following: 

 

  • Rejection of the large-scale European studies, the PARSIFAL and GABRIELA studies. One reason: “The subjects of the larger studies, children and infants from rural European communities, may have a different genetic make-up and more diverse environmental exposures compared to children growing up in non-rural areas outside Europe.” 
  • Rejection of the notion that RAWMI’s approach of using strict sanitation and other standards to reduce coliform and standard plate count readings and thereby reduce the risk of pathogens. Low CC and SPC readings “cannot ensure raw milk safety,” FDA states. “That is because….these milk quality indicators….are general indicators of animal health conditions and the level of sanitation that exists as milk is being produced and stored. These quality indicators do not provide any information as to the presence or absence of harmful bacteria. Raw milk with acceptable SPC and CC numbers may still contain deadly pathogens.” 
  • Rejection of McAfee’s contention that “the public has displayed huge support” for raw milk. It rejects the finding from a survey by the U.S. Centers for Disease Control in 2007 that indicated 3% of the population consumes raw milk, saying it considers an estimate by a CDC researcher that less than 1% of the American population regularly consumes raw milk “to more accurately reflect usual or regular raw milk consumption.” Why? FDA doesn’t say, but it doesn’t matter, in FDA logic. “Even if 3 percent of the U.S. population consumed raw milk regularly, FDA would still find that (the ban on interstate sales/shipments) continues to be justified. That is, the level of consumption of raw milk does not call into question FDA’s concern that raw milk may contain dangerous pathogens.” In other words, we think you’re wrong about raw milk’s popularity, but the matter is moot because we are convinced raw milk is too dangerous and our opinion is the only one that counts here.

There’s more, but you can review the document yourself if you enjoy rigid ideological thinking and double-talk. Still, I am going to try to take the glass-is-half-full approach. The FDA actually has something positive to say about raw milk’s apparent healing powers, however tentative it is. But beyond that, the FDA analysts gave the evidence in favor of a relaxation of its interstate shipment ban a thorough going-over. I have to think that if they are reading all the positive developments, some of it, maybe just a very small amount, but some of it will sink into the agency’s collective consciousness. At some point, its officials may decide they don’t want to be alone in rejecting reality.