Licensing. It is an issue that lurks in the background for many small dairy farms that sell or distribute raw milk and other dairy products. People frequently assume that licensing is not only straightforward and doable, but essentiala governmental stamp of approval that presumably ensures a certain minimum level of quality or safety. But theres more to licensing than meets the eye, especially when it comes to raw dairy. In this guest post, California herdshare operator Shawna Barr explores some of the challenges with licensing for small dairies.
by Shawna Barr
We may soon hear from opponents of the proposed California Home Dairy legislation (described in the previous post), suggesting that small farms just get a license like the rest of the dairy farmers in California. I remember the prosecutor in the Vernon Hershberger Wisconsin licensing case, in his closing arguments, say something similar. Just get a license! Its only a few hundred bucks! Why should small farms receive special treatment and not be required to follow the rules?
Here is the problem with that argument: dairy licensing requirements in California (and elsewhere) make it nearly impossible to build a financially feasible Grade A milking and bottling facility for three cows. Or for fifty cows for that matter.
My discovery began six years ago, when we discovered how productive a family milk cow can be, and we considered selling our excess milk to eager neighbors. I thought, Ill just call the state and get a license. How hard can it be?
The answer is: very hard. The California Department of Food and Agriculture (CDFA) informed me that I would need a from-scratch building designed specifically to the exhaustive California Grade A dairy guidelines. The price tag was a minimum of a quarter million dollars. If I planned to bottle my milk on site, I would need an additional facility for additional thousands.
As part of this preparation process, we would also need to bulldoze our existing barns and start over.
Since those figures didnt pencil, we did what many other owners of small farms have done around the state. We formed a private herdshare and began operating under Californias private home exemption (allowing milk production for private consumption). Suddenly, like a page ripped from Joel Salatins Everything I Want to Do is Illegal, we found ourselves operating on the far edges of the law.
That was never our intention, though. We would have much preferred to just get a license.
Perhaps most ironic, and frustrating, is the fact that we already have great facilities on our farm that have proven completely adequate for producing high-quality milk on a small scale. Our fully enclosed barn has concrete floors, good lighting, hot running water, and a dedicated clean room for washing our equipment and jarring our milk.
Our cows enjoy clean, dry winter housing, lush green pastures and more than an acre of land each. When co-owners visit the farm every week, they expect cleanliness, sweet smells, butterflies, flowers, green grass, and slick, bright-eyed happy cows. We give them every bit of that.
I concede that micro dairy farms have infrastructure considerations. We have management issues just like large dairies. However, our management methods and facilities can be quite different. In other words, there is more than one way to cleanly and safely milk a cow.
For example, it takes considerably less water to wash a bucket milker with three feet of milk hose and a one-cow parlor than it does to clean a pipeline system and a 100-cow parlor. We use about 10 gallons of hot water to wash up after each milking, simplifying waste-water management. We dont need flush alleys because we manage manure by hand using deep carbon bedding and a small front-end loader. Most manure falls in the pastures anyway.
Our maximum daily production is about 25 gallons of milk. That is about .3% of what is produced daily on an average-size California dairy. For us, it is easy enough to wash jars in a sanitizing dishwasher, fill and lid them by hand, and place them in an ice water bath to cool. A $10,000 bottle capper and bulk tank is way overkill.
Even in the absence of the required 25 feet of concrete flanking for my barn, and of the paved, curbed and graded lanes that flush into a lagoon, our system is working well. In six years weve never had an illness outbreak. Our Standard Plate Counts run under 500 and our Coliform counts are regularly zero. Co-owners enjoy milk that stays fresh for two weeks or more.
Quality and safety standards on the small dairy are essential, and should be at or equal to those required of Grade A dairies. However, those standards are best met when there is freedom to innovate with appropriate methods to match the size and scale.
California does not yet offer that freedom to small herd dairies. There is only one way to legally milk a cow, and it requires hundreds of thousands of dollars in infrastructure. As a result, many otherwise law-abiding small farmers participate in this form of soft civil disobedience. It is our cry for regulatory reform, and perhaps the only means we have to evoke change.
I have sent several “want to be micro dairymen” to her for mentoring and consulting. She is a model of goodwill and functional raw milk food safety in action.
We at RAWMI are so proud of her!!
What Shawna is doing is reasonable if it were merely about micro dairies producing clean, low bacteria count milk.
Unfortunately small inefficient micro dairies dont fit into the future plans (at least in Canada) of tptb. As far as those powers are concerned, bigger is better, with licensing and regulation being used as tools to establish absolute control over the dairy industry in order to achieve that bigger is better objective.
The push to collect and truck milk from thousands of cows across the countryside, storing it in huge milk silos, pasteurizing and homogenizing it, then ship it back out again across the land, all the while suggesting that it is nutritionally equivalent to raw milk, is a clear indication that those who implement regulation and licensing care little about truthful dialogue and providing consumers with wholesome healthy food. The flagrant advertising tactics used by the industry for products such as Lactaid, showing old time farming practices is a deception designed to manipulate the consumer. Government regulators seem to have no problem with such advertising!
As a parent, am I using my freedom irresponsibly for failing to take heed of government mandated vaccination protocols by not vaccinating my children?
Likewise as a parent am I using my freedom irresponsibly for failing to take heed of government raw milk regulations by feeding my children raw milk?
Responsibility does not begin and end with the producer. It begins and ends with both producer and consumer.
There is no need for government involvement in order to license small producers serving a handful of consumers who share a common goal of what it takes to be healthy.
On another note, this notion of biosecurity that has crept into the raw milk debate is a myth fueled by fear and designed to provide a false sense of security. Those preoccupied with such a notion have chosen to live life as a problem to be solved rather then a reality to be experienced. As Soren Kierkegaard suggested, Life is not a problem to be solved, but a reality to be experienced.
Ken
Well, baloney. We may be uniformly trained for a corporate economy, and largely subjects of it, but just because it’s just about all there is anymore is no reason to think it’s right and good.
Think instead about what a corporate economy does to us workers trying to live shoulder to shoulder in this world. Think about how human relationships changed when the vast majority of our goods and services came not from a person you could meet and talk to (or likely knew) but instead from multilayer organizations. You might try to imagine what it was like back in the days when personal interaction between consumers and tradesmen, farmers, store owners, etc., was the common currency of community relationship. That is what the corporate model has eradicated. Consumer-business relationships in the corporate economy are mediated not by owners, but by employees and experts (also employees) trained to follow rules–trained ultimately to fit round and square pegs alike into the same round hole, which is, not incidentally, formed, sized, and maintained by corporate interests. Personal is really no longer.
The new distance between people has had far-reaching consequences. It has made us far less social, far less schooled in personal interaction. We are less able to handle people, less trusting of tradition and common sense, less able to think for ourselves. When conflicts arise we tend to turn immediately to systems and their rule-inspired bureaucrats for central-planning solutions. We turn to experts to discover what is true, proper, allowed, even what is right and wrong.
Certainly some valuable industries cannot be accomplished on a small scale. They will remain forever foreign to the average Joe, and therefore require expert regulation. But food production (among many others) is the opposite. Large-scale is anathema to good food. That is a biological reality we all ought to apprehend now that the corporate-ag model has so spectacularly failed at everything but making money. (Which should be no surprise since a corporation, by definition, exists only to churn money.) Corporate-ag and the money economy has sent our soil to hell and our health with it. Clearly we need to discard the notion of agriculture as industry. We need (NEED!) food production that does not require long-distance transport and corporate machinery.
It is immutable biological law that will make food production a key factor (perhaps THE key factor) in the long overdue regeneration of our old personal business model, and of our damaged social-community relationships. For both our physical and social well-being we must have a food system that depends not on rules, regulations and expert intermediaries, but on people, together, enjoying their successes and working through their failures face to face.
When a 3-cow dairy shows up in the neighborhood, we ought to rejoice and partake, but average Americans, and more important, America’s corporate and government minions, have no idea what to do with it. The common response, as Shawna points out, is to attempt to force that square peg into the prevailing round hole. When that fails (as it always does) there may be some attempt to tickle the rules and regulations, to cajole or coerce the oddball into behaving like a miniature version of a real business. That, however, is a very deadly wheels-on-fish idea, akin to arguing how many links should be on our ankle chains. At very best it is a half-measure, and a colossal waste of time. You might think that small-business owners would understand that instinctively, but strangely, even they often cannot envision an existence outside the corporate framework. The three-cow dairyman feels he must buy into corporate science (don’t fall into the trap of believing science is not driven by paradigm), follow some manner of corporate-style regulation, and own corporate-style financial insurance. These are traps which should be avoided like the devils they are. Food production got along fine for nearly all of mankind’s history without anything like our modern corporate structure. It can still. It needs only to decentralize, and respond to only that which biology and human kindness demands.
A little while back Ken wrote that the typical Canadian small dairy doesn’t give a shit about global markets. I found that heartening, and unsurprising. People are, like everything else in Nature, healthy only when fully connected to the great, good, infinitely complex biological machine of which we are a part, and that includes (begins with) connections between individuals.
Corporate America depends for its survival on creating distance between people. It usurps the very thing people require to be healthy and fulfilled. We must ignore the corporate money machine and learn to live together, to take care of each other. That is where we find meaning and truth. Corporate America would have us cede our responsibilities over to faceless systems, but we are designed to behave like cells in a body. Break our connections, separate us from our planet, our food production, our history, from each other, and we die.
How do we fix this horrendous mess? A three-cow dairy is not a bad place to start.
What is happening though is that small herd farms are beginning to work together to breed our own replacement heifers, from our own closed herds. Ironically, this small-herd network has resulted in large part due to the “herdshare crackdown” that happened here a few years ago, bringing many small herd owners into contact with one another. Prior to that event, small-herd farms were typically very “off radar” and didn’t know one another, and couldn’t help one another. RAWMI has also played a big part in improving the network. We’ve lost a lot of our small-farm infrastured in our state due the consolidation of agriculture, and we really need to restore it.
I’d prefer to never purchase a cow off a large dairy ever again. Until that is a reality though, disease screening will remain important. The last cow we brought to the farm was raised from a calf as a 4-H project on a one-cow farm. We paid a premium for her, and she is healthy and totally worth it. (Any northern California 4-H kids reading this? Pay attention!)
I think many don’t give a “shit” about global markets, most are just living their own lives. I could careless about global markets, I care about what’s in my own back yard.
That is one way to look at the situation. I prefer an entirely refreshing and liberating look at the same set of conditions. Why not view standards as a challenge to differentiate and define your excellence!!!
One mans chains are another mans consumer-connected deeply respected Briar Patch powerhouse.
Lemons are the basis for organic sweet lemonaide!!
I couldn’t agree more with this statement.
For me, having a set of quality and safety standards in front of me that I am free to achieve in ways that are financially, practically, and environmentally sustainable seems like a breath of fresh air, not a ball and chain.
Producers who favor the “good practices” definition want to distiguish between milk produced responsibly, that which is not.
http://www.commondreams.org/view/2014/03/21-0
A lot of farmers don’t know how or where to test, or understand what testing can tell them and what it can’t. It is one of the most frequent questions I get from other producers…so frequent we actually posted testing instructions on our website.
The correct frequency of testing is again, a matter of size and scale of each particular farm. These indicator tests provide a snap shot into how well your production plan is working. The more complex your production plan, the more variables such as equipment, personel, number of cows, etc., the more a farmer may want to test.
The more simple your plan…fewer cows, fewer personel, more simple equipment… less frequent surveillance testing may be appropriate.
Edwin tests every batch of milk prior to sale. Mark McAfee runs hundreds of tests each month on farm and through a lab. We test a couple times a month, both locally using our own supplies and at a lab.
Personally, since we live such a long distance from a lab, I like having access to local testing, and w as glad to learn about the 3M products. I first found out about them by readind Edwin’s farm blog!
OPDC has been hounded by our radiation conscious consumers incessantly. We have tested four times through Silliker labs Italy. Each test costing $500 each. That is more than $2000 dollars in the last 18 months. All results are at zero Fukushima fallout levels. These raw milk tests are from OPDC which is in the drought area near Fresno Ca. We have had a grand total of about 3 inches of rain this entire year. We normally get 10 inches. We are a desert. The science tells us that rain brings down radiation fallout from the jet stream that travels at the 50,000 foot high levels at more than 125 mph.
I would ask that consumers please take a chill pill and not listen to the paranoid pseudo conspiracy theory scare oriented Internet personalities that love to insight fear of all things. It is unfounded and rediculous. The facts are reported on our website…..please relax
I try to be avoid conflict between my understanding of cow health and my cow management practices. My understanding of cow health sometimes conflicts with the state’s understanding, or maybe it is that the state’s understanding is contradictory in itself. To use TB as an example: The TB test tells us whether or not a cow has been “exposed” to the TB bacteria. The cow is injected with a small dose of “killed” TB bacteria.My research tells me that the TB bacteria is not killed,it simply has no cell wall so it cannot be detected by a simple stain technique. As with MAP this cell wall deficient TB bacteria is much more dangerous than TB with it’s cell wall intact. Without the cell wall intact it can enter into our cells and even cross the blood brain barrier. I don’t believe exposure to TB is a problem.In fact TB bacteria are common in the soil.Exposure is impossible to prevent. The information that makes the most sense to me is that the wasting disease that is called tuberculosis is a result of crowded ,stressful confinement ,lack of sunlight and poor nutrition. Historically most diagnosis of TB occur in late winter when confinement ,lack of sunlight and stored feed have taken their toll on the cow’s health. Their are more TB bacteria in people or cows when their health is at a low point.That is because TB bacteria can tolerate poor conditions better than the bacteria that normally do our bodies’ janitorial chores like breaking down waste products. The TB bacteria are carrying on important functions in a toxic environment and are helping to eliminate the toxic accumulation of waste products.
I manage my cows to be outside all winter with shelter that is not crowded, with clean bedding and they are fed plenty of the best quality hay throughout the whole winter. Do I need to do a test to see if they are feeling good? I can judge their energy level and health by observing them. If I follow the state’s management plan they would recommend that the cows be confined because the deer are thought to carry TB and contact between deer and the cows might cause the cows to become infected. The state vet does agree that confinement and poor quality feed is the underlying conditions that lead to the proliferation of TB in a cow,but still feels that it is a disease that is passed from one animal to another. Is this a contradiction? For me it is.
Do you think that TB testing and culling is the best management plan to keep cows TB free? If there was a vaccination for TB ,would you consider vaccinating your cows? Is it possible to pasture cows without exposing them to TB? For that matter is it possible to confine cows without exposing them to TB?
Our individual opinions about TB are irrelevant. State law is crystal clear about TB positive cows and sale of raw milk. In CA if you want to sell legal raw milk, you get your cows tested for TB. Even the state vets themselves will argue and disagree about the relative risks of TB and raw milk….even that does not matter. State law is state law. One of the pills we take to feed our consumers.
Sometimes going by what is legal turns out to be more risky,as in this case.The legal situation with TB testing is putting people and cows at risk. Are you saying that safety is irrelevant? I am going to go with safety first,not the state’s version of safety,but an informed version of safety. The “science” behind the TB test is not valid,never was, now that that is known we should act accordingly. The trouble with blindly accepting the state’s protocol for producing food is that it is often completely backwards. Aren’t we still wondering why pasteurization has been the law for so long? RAWMI should take it’s mission to educate seriously and start with investigating ALL of the legal requirements to see if they make any sense. You are patting yourself on the back for seeing that pasteurization is not good. Take a good look at the rest of the package . It is all based on the same flawed foundation.The theory that individual micro organisms cause specific diseases is not valid,but the legal situation will not recognize this truth for a long time unless we question it and act according to our best information.
What they’ve just done is pigeon hole all start-up dairies into a 3 cow or less ‘legal’ size they can’t escape from. To be profitable and make a living at it as a small dairy you’re going to have to be a lot bigger than 3 cows, but not as big as would be required to pay for full grade A. Trapped.
Watch for these dairies to stay small and irrelevant or get beet down as they try to grow beyond 3 cows and drop the license.
Black’s Law Dictionary, License , “In Constitutional Law, and in the Law of Contracts, A permission, accorded by a competent authority, conferring the right to do some act which without such authorization would be illegal, or would be a trespass or a tort. A permit or privilege to to what otherwise wouyld be unlawful. A permit, granted by the sovereign, generally for a consideration.”
The Fukushima event happened two years ago?
I do agree that there will be areas more effected than other areas. I also agree that there are many things that can be done nutritionally to reduce radiation illness. bentonite is a really good one and so are the suggestions with the iodine. One of those things is to not become so stressed out that it causes mental illness. For some reason there are some people that are so focussed on disaster that they do not seem to think about anything else. I ignorance is not bliss…but paranoia is not good either. We all live on space ship earth and some of the inhabitants have really messed things up. That is a reality that we all need to evolve with and protest. The Monsantos of the world are just as bad or worse than back ground radiation from Fukashima.
Ingvar
Now I am completely confused. Us farmers do not irrigate with salt water. Sea water dilution over 5000 miles and extreme depth of ocean water?? Maybe this is payback for Hiroshima and Nagasaki. Why would a raw dairy consumer worry about trace radiation in sea water? Where is the connection?
There has been recent radiation contamination in fresh water rivers in Canada, and the news stated the Canadian govt is “baffled as to how it got there…DUH
It’s the radiation in the air, rain, show, wind that I’d be concerned about. It lands on crops, grasses, in the fresh water and we eat the animals who eat the grasses, they and humans eat the crops and drink the water…..
During WWII, Japan sent fire balloons to the US on the wind currents,http://news.nationalgeographic.com/news/2013/05/130527-map-video-balloon-bomb-wwii-japanese-air-current-jet-stream/
There was one family that died from them, in Oregon. A family was picnicking and the gov had been silent and the family didn’t know what it was, they apparently went to investigate and it burst into flames, killing them. Just think, had the US gov warned people, that family may have avoided investigating and continued to live.
I have nephews who live in Huntington Beach and Newport Beach, and relatives who live alllllll over southern CA (Oxnard, 1,000 oaks, monterey park, fontana, la canada/flintridge, la crescenta) as well as northern CA (stockton, galt, lodi, jackson, oakland, chico, paradise, eureka – and even reno and carson city, NV) and they say it’s no more worrisome than everyday pollution. Personally, I’m not sure pollution is even that big a deal because ma nature has a way of working with all that stuff in one way or another. It’s one of the reasons Obozo’s *carbon credits” don’t mean diddly squat to me or a lot of other people.
I see and talk with these people often (they are relatives, after all) and when I do they assure me they are not the least bit worried about radiation alongside the pesticides in the air and they are most concerned with the state of wind drift.
…I go back so far that, our high school teachers called it “cosmic energy” … which would pass right through us! if can you believe it!!.
… I don’t know much, but I do know that the amount of radiation you’ll be getting in California, from the event in Fukushima, is about one-billionth of radiation from all other sources, as we, aboard this Space-ship Earth, hurtle-through = [ cue the voice of Carl Sagan saying “biwyuns and biwyuns” ] = of random cosmic rays, per human lifetime. You’d get more radiation walking by your local dentist office ( with an Xray machine) than the fallout from Fukushima. And that guess-timate is before we discuss what actually went on there
An example of accumulating in tissues: radioactive iodine (RAI), also known as I-131, concentrates in thyroid cells and destroys the gland.
The notion that the contamination from Japan is negligible is pretty laughable in a sick way. For some there will be no effects shown, for others, it will be toxic to their health and life. There is a HUGE difference between environmental exposure to ionizing radiation and exposure to bioaccumulated radionuclides. Ionizing radiation such as the ‘background’ radiation we all experience is general whole-body exposure. When you accumulate or are contaminated with radionuclides your body, in whatever place the nuclides accumulate in receives much higher specific doses. The type of radiation is also different. Alpha is much more damaging than the beta and gamma/x from background. You simply cannot compare the two things 1:1.
Walking by the dentist office most likely won’t affect you, just as a chest x-ray probably won’t adversely affect you, but standing near or next to it 24/7 has the potential to adversely affect you. How much of the radioactive fallout will adversely affect the US, only time will tell, but to ignore the possibility or down play the possible threat is just plain foolish.
http://toxnet.nlm.nih.gov/cgi-bin/sis/search/a?dbs+hsdb:@term+@DOCNO+7389
…No doubt that that isotope of Iodine certainly DOES harm people … for instance the whole co-hort of females who were exposed to it by the above-ground testing done at Alamagordo / Las Cruces, back in the 1950s … now dead or dying of thyroid cancer. … I refuse to accept that the reactor at Fukushima was running on I-131/ radioactive iodine. Onus is on anyone who’s proposing that whatever happened at Fukushima, sent radio-active matter into the atmosphere – especially, iodine I- 131 = and that it’s raining-down on us, to prove so. I don’t believe it, and even if it is happening, it’s insignifant against all the other kinds of pollution.
http://www.sfgate.com/science/article/California-drought-Solar-desalination-plant-5326024.php
http://nyvic.org/nyvic/health/disease/incao-infection.htm
Private corporations already own 5 percent of the worlds fresh water. Billionaires and companies, including Monsanto, are purchasing the rights to groundwater and aquifers. In an even more ominous twist, Monsanto is accused of dumping its plethora of toxic chemicals, including PCBs, dioxin and glyophosate (Roundup) into the water supply of various nations worldwide. Then, seeing a profitable market niche, it has begun privatizing those water sources it polluted, filtering the water, and selling it back to the public.
http://obrag.org/?p=74144
Ken
Every parent or parent t be aught to read it.
Ken
I first learned about the amazing power of two person stretching when I attended a weekend seminar by a Native healer who had also spent time in China. People were coming in with arms in slings, … and all kinds of medical conditions… and this man who lay them on a table, and adjust there neck (stretch it where you here clicks as the bones unlock), pull on their leg, etc., take the sling off and the person would be fine…
Even though the establishment denies that there is a reverse mass (spirit) realm, and other dimensions, … just looking at the human body as a machine, you can see that if joints are locked up, and you unlock them, all kinds of health benefits can ensue. A friend just sent me a short piece by an alternative doctor talking about how ear infections are cleared up when the upper back vertebrate are unlocked. When they are crimped, the lymph system isn’t able to clean out the body as it is supposed to, and ear infections can result.
My dad had this racing heart condition and establishment medicine was prescribing all these weird drugs and weird “treatments”, and I looked online and quickly found a number of articles with people claiming exactly the same racing heart symptoms, and a quick chiropractic adjustment clears it up. So many nerves go thru your spine, if things are crimped up there, all kinds of problems can be caused.
Doctors in general are not taught about these simple stretching techniques. Chiropractors in general want you to think they are experts on your body and generally have lost or never had the awareness of how simple stretching that takes a half hour to teach, can clear up so many health conditions, without anyone having to pretend they know how to make a single cell of your incredibly complex body.
http://pjmedia.com/blog/epa-unveils-largest-expansion-of-authority-to-regulate-private-property/
**As a point of interest, PJ Media is a sister-site (sort of) to the Instapundit blog written by Glenn Reynolds, the attorney who helped with the Vernon Hershberger case.