Mark McAfee of Organic Pastures mans the introductory RAWMI exhibit at the Weston A. Price Foundation national conference in November 2011.
I’ll say, right off the bat, that tongue was a bit in cheek as I wrote the heading above. But not entirely.
The Raw Milk Institute (RAWMI), like the Farm-to-Consumer Legal Defense Fund (FTCLDF), is facing significant growth and maturation challenges.
The Raw Milk Institute (RAWMI) is supposed to set the standard for raw milk safety. That is, ostensibly, the reason it has grown ever so slowly, to only nine members, since it was founded in 2011—it takes a long time to pass RAWMI’s rigorous standards. Even P.A. Bowen Farmstead, the Maryland raw dairy farm owned by Weston A. Price Foundation founder and president Sally Fallon Morrel, took many months before it was certified.
No RAWMI members have been associated with recalls or illnesses since they gained RAWMI certification, except for one: Organic Pastures Dairy Co., the nation’s largest raw dairy, by far. But it’s not as if OPDC has just been involved in a single incident, or even two.
In 2006, six children became ill from E.coli O157:H7, two of them very seriously; in 2011, there were five children sickened by E.coli O157:H7. Earlier this year, six children were similarly sickened. In between those incidents, there were ten people sickened by campylobacter in 2012. On top of those outbreaks, there were recalls and quarantines in 2012 and 2015.
To make matters worse, it’s almost as if the pace of problems has quickened this year. In addition to the six children sickened earlier this year, there were two recalls just last month, from salmonella contamination of dairy products.
It’s bad enough that the founder and leader of RAWMI—the chief evangelist on behalf of high safety standards for raw milk—can’t get control of contamination problems at his own dairy. There’s something more, which bothers me nearly as much as the food safety problems, and that’s the way the various incidents are handled publicly by OPDC.
Instead of committing to determining the possible problem in the dairy’s safety standards, OPDC more often than not blames others for its problems. Most bothersome, that “other” may even be another farmer.
When OPDC was forced to recall tainted cream and milk early last month because the state found salmonella, here is how McAfee described the situation in a statement to RAWMI members (which he agreed could be distributed more widely): “In 17 years of testing OPDC has never had a positive Salmonella test result. It is very suspicious that OPDC began delivery of Organic Certified Biodynamic pastured eggs produced by another grower that had been courting OPDC for more than a year in an effort to get OPDC trucks to carry their eggs to market. Two weeks ago, OPDC began delivery of eggs and now this detection. As a result of this salmonella detection, OPDC has discontinued egg delivery for the outside grower. In retrospect, this seems to be a clear risk. Cartoned, packaged eggs would seem to be low risk, but our experience shows otherwise. Some eggs became broken and as we all know, Bio-dynamics does not embrace strict cleaning policies. In fact, unwashed eggs are all the rage. Eggs on delivery trucks means, salmonella on hands and feet and that can get tracked back into our cold storage and that area is very close to where we handle raw cream.”
McAfee advised other RAWMI members to be wary of eggs anywhere near their raw milk: “Live and learn…..the hard way. There are 1.3 million cases of salmonella every year in the USA. Eggs test positive for salmonella all the time and so does chicken. It is not enough to separate the chickens on the farm from your raw milk operations….be very wary of eggs from other farms or even your own coming into contact with raw dairy products even when being delivered on the same truck. Wash hands!! Wash feet!! I feel like I have egg all over my face.”
If McAfee had egg on his face then, in early May, you wouldn’t know it two weeks later, after he had thrown the biodynamic egg producer off his farm and under the proverbial bus…..and the salmonella appeared yet again, prompting the California Department of Food and Agriculture (CDFA) to order yet another recall of OPDC milk.
“There is not any story,” McAfee wrote me in response to my inquiry about the new recall. “No illnesses reported and not any potential for illnesses. One cell does not create illness. If one cell did create illness….we would all be dead!!This is purely a conflict in lab test results. Some of the state tests are in conflict with the state’s own tests! No shut down. All of our 3rd party FSNS lab, USDA approved BAX PCR tests are negative!! No local coverage of the recall. Products all on the shelves. Only one code date recalled. There are at least 6 date codes of product out in distribution at any time.”
Oh, by the way, no mention of that biodynamic egg producer McAfee so unceremoniously blamed for causing the previous salmonella contamination. He is probably still wondering what he did wrong to get booted out of OPDC barely days after being allowed into the inner sanctum.
That egg producer might want to commiserate with Amos Miller, the Pennsylvania farmer who has also experienced the full force of McAfee’s business wrath. Miller’s food products were made available to attendees at the Weston A. Price Foundation national conference last November in California, when Orange County health inspectors descended on the place and quarantined and confiscated various foods. That raid led to a report from the U.S. Centers for Disease Control accusing Miller’s dairy of being responsible for a death in Florida and a serious illness in California. I have published several reports on this blog finding serious flaws in the CDC report, but it has nonetheless led to subpoenas and threats against Miller from the U.S. Department of Agriculture, the U.S. Justice Department, and the Pennsylvania Department of Agriculture.
Miller might share with the egg farmer that the Orange County health inspectors told Miller’s people that the inspectors only showed up in response to a complaint made the previous day. It’s never been certain where that complaint came from. Mark McAfee, in a comment on this blog following my post about the CDC study, stated: “If you all remember, I warned the Millers well in advance of them being shut down in their selling of raw dairy products at the WAP Anaheim Convention last year. Instead of shutting down, they accelerated their selling and got caught by the local health department…..Remember also that just a couple of days ago I shared about RAWMI getting calls about Amish having serious listeria found in their raw milk. Listeria is a sign of unclean equipment and bio films. Is this an Amish problem? The church refused to allow use of chemicals to clean equipment.”
I asked McAfee some weeks after this statement if he was the one who made the complaint against Miller’s with Orange County regulators, and he insisted he hadn’t. He said he made his warning to the Miller people at the WAPF conference based on statements by the regulators when OPDC received its own permit to sell product at the conference, that the regulators would show up during the event.
Whatever the real story about who said what to whom before or during the WAPF conference, I can’t help but wonder if RAWMI’s mission is being put at risk by the actions of its leader. You just have to question how long California regulators are going to allow recall after outbreak after recall, without any penalty, at the nation’s largest raw milk producer. What does OPDC have to do to continue staying in the state’s good graces? At what point does RAWMI’s credibility become irreparably harmed? Not nice or fun questions. Wish we had some answers.
David,
As with all things strategic….we do not share war plans with anyone.
Things are not what they appear to be.
Correction…there are 10 LISTED dairies. 2 were LISTED last month. 1 is not shown because of Canadian oppression.
OPDC raw milk has never been cleaner and or safer. All FSNS 3rd party lab tests ( OPDC lab ) use AOAC validated current FDA BAM methods. Split CDFA samples of OPDC products taken as samples are all negative. We now find out that CDFA does not use validated FDA approved methods. The CDFA lab methods can detect down to one cell of salmonella in 1 liter ( 1000 ml )using Moore Swabs and other environmental methods, media and temps and extreme time for incubation. The medical threshold for illness ( Dose Load ) is 10 to the 5th or 100,000 cells in a small sample coming from 25 ml. A huge load. According to a PhD we have been working with….it is not possible to become ill from levels detected by CDFA. It would take more than 100 liters of terribly abused raw milk to cause illness in the most immune depressed consumer. This is not going to happen. 25 gallons of abused raw milk in one sitting is impossible. We do not produce abused raw milk!
This entire issue is a conflict in lab methods. This is not a food safety issue.
As far as RAWMI is concerned…there is no dairy in the world that is more tested than OPDC. In Pennsylvania, pathogen tests are performed once every six months and those tests are done using a private lab and BAX PCR tests ( the same one as used by OPDC lab ). CDFA tests each month and right now one time per week. It is intense. OPDC uses USDA FSIS AOAC FDA BAM approved tests and finds negative results. Remember that the CDFA lab uses a method that is intended for “environmental testing and not for food”. None of the salmonella tests that the CDFA lab uses include PCR BAX,USDA FSIS or the AOAC FDA BAM methods. This is direct from their lab PHD, even though CDFA led us to believe that they use only approved validated FDA BAM test methods.
In private communications with LISTED dairies in other states…the dairymen marvel at how OPDC can exist given the intense regulatory scrutiny and use of non standard methods that detect one cell in 1000 ml. When the standard is detection of 1000 ( 10 x 3rd )or more for detection to trigger ( ie BAX PCR )in 25 ml sample sizes.
This entire issue has born through one fact…OPDC is very safe and very clean. No other raw milk or pasteurized milk in the world is subject to such non standard and unusual testing.
Remember this…NO shut down…NO illnesses…Market confidence is excellent! Our consumers know the truth and love their farmer!
It takes guts to stand and take the pioneering regulatory jabs and hits….I am so proud of our team at OPDC and our consumers that stand with us and 100% of the time enjoy the benefits of clean and safe raw milk. I can assure everyone that testing must be based on standards and they must be current and validated by AOAC or other approved agency. CDFA is off the reservation and went rogue. Standards matter and zero pathogens is not the standard by which safe food is measured. There are triggering thresholds and that is why AOAC FDA BAM and USDA FSIS set those standards.
Let the tomatoes, eggs and rocks start to fly….
Please do not expect me to respond to all the comments. I have much more important things to do, but…. I thought at least I would share some grounding facts.
Lastly…RAWMI is a community of sharing and caring producers of raw milk. OPDC is not RAWMI and neither am I. It is so easy for journalists to dream up inflammatory stories and headlines when things get boring. David…the real story is in raw butter and why it should not be allowed over state lines.
I am saddened that you chose story content which tends to feed the likes of certain litigation firms and the FDA that loves to see raw milk in conflict.
OPDC and RAWMI have never been stronger or more affirmed in their missions.
Mark, I am sure you know I did not write this post easily or lightly. It was certainly not the result of boredom. I have been the first to come to your defense in the past, most notably last February, after the E.coli O157:H7 outbreak (which you did take responsibility for).
As I said in the post, I am especially concerned about your recent tendency to go after other farmers you see as problems or enemies. That is the quickest way to break down unity and stimulate in-fighting, which I agree the FDA and other raw milk opponents love to see.
I don’t quite get how “the real story is in raw butter…” Is it because the FDA may be forced to allow interstate shipments of raw butter? Or because interstate shipments will increase competition among raw dairy producers?
If its just a matter of testing methods, why’d you kick the egg producer off the truck and blame him? And why if eggs are so risky arn’t raw dairies the country over getting people sick with salmonella considering egg laying chickens are common on such farms?
Its no coincidence that the LARGEST raw milk dairy in the country has so many problems. Nor that as he’s gone hyperclean the issues have seemingly accelerated.
At some point we have to ask ourselves, how big is too big?
Holy moly, I guess I’m committing a cardinal sin when I crack an unwashed egg into a glass of raw milk and drink it in the morning. I suppose I am guilty of child abuse as well when I encourage my children and grand children to do likewise?
We should be thankful when given the opportunity to be exposed to a microbe such as salmonella. Unfortunately once the germ control bug bites a person irrational and accusatory reasoning is without limits.
Thank you Ken…
The road to sterile food is lined with good intentions, but the true result is an immune depressed generation of families and children and a GUT sick nation with even sicker policies.
For those that remember 2007-2008….remember AB 1735 and the CA “less than 10 coliform” sneak attack? No hearings, No voting, No opportunity for science or debate…No democracy… just a new CDFA policy passed secretly into legislative law and heavy enforcement. It was a huge uproar. Hearings were held and SB 201 was passed as the Dean Flores Gold Standard for raw milk food safety law. It was then vetoed by the governor after letters from Bill Marler were sent and big dairy went into revolt against anything good for raw milk. RAWMI was based on SB 201 and individual RAMP plans and appropriate testing and sound science.
Even though SB 201 was vetoed….we adopted it ourselves as the Gold Standard for Raw Milk at RAWMI.
Well….we just found out that the CDFA Moore Swab test environmental test methods and the current CDFA salmonella pathogen test system was initiated in 2007. The more we dig the more anti raw milk bodies we find buried around the state.
What a coincidence. Another sneak attack just discovered. CDFA is probably scratching their heads. I am sure someone planned this out….”less than 10 coliforms and zero salmonella” would surely be the end of raw milk in CA. That was a bad bet. They did not know the spirit of the people or the tenacious spirit of the raw milk producers that produce here in CA. From this survival in spite of these great odds….I think we actually earned deep respect from our regulators. We not only turned the other cheek…but we grew and thrived in an impossible set of conditions.
Hence, so few will follow to produce in the CA raw milk markets…or if they do…they do not use the permitted process and go largely untested and certainly unregulated.
I do not blame them.
HI David, Mark, and all,
As a RAWMI farmer and recipient of that email from Mark regarding the detection of Salmonella, I just wanted to add a little context to how the RAWMI community of farmers works in real life. First of all, OPDC is certainly not the only RAWMI listed farm to have experienced test results that were unfavorable or confusing…not by a long shot. Livestock tests, well-water tests, fecal testing, and of course milk testing…things come up that warrant further investigation and understanding, ideally BEFORE we have problem with illness. The RAWMI community often goes to one another for support and sharing of information, as OPDC did this time and has in the past.
When a fellow farmer has an unfavorable test result, the immediate question is, why did that happen? What happened? What changed? What can I learn? What don’t we understand about this?
When a raw milk farm has performed literally thousands of pathogen tests on their milk, and never has had a positive for salmonella…and then suddenly does, it raises lots of questions
And that, I believe, is what you are reading there in Mark’s theory on the eggs. In no way do I think any of us believed is was settled science that eggs were the root cause. We were all asking “Was this from feces? A cow with systemic salmonella? Cross contamination from humans or other products?” These are the right kind of questions to be asking.
Another question that we always asks when test results are different, is “What has changed?” At OPDC, the introduction of those eggs on the truck corresponded to the time of the salmonella positive. So, its very understandable to ask the question…did the eggs play a role?
Proper handling for eggs and raw milk is different. Salmonella on an egg shell is less concerning because eggs shells are not intended to be eaten, and eggs (for the most part) are cooked. Not so with raw milk. Dr. Cat Berge has long recommended that care be taken when handling raw milk and eggs on the same farm.
So I don’t believe this was throwing a fellow farmer under the bus at all. Rather, it was a working through the possible root causes within the supportive, and largely private, RAWMI email list. It sounds like OPDC has moved on from that initial theory now that more information is known
Anyway, perhaps that gives a bit of insight into how it works within RAWMI. Farmers speculate about all kinds of things when it comes to trouble shooting and trying to connect the dots. It can be terribly frustrating sometimes…as we can run our plan to the T, and sometimes you still don’t get the results you want 100% of the time. That is because we are dealing with the complexities of the natural world. And while we understand many of its secrets, so many more we do not.
Shawna. You are so right. Eggs came up high on my list. I never named the outside farmer.
Now I know the whole story. But it took weeks to figure it out.
David,
The media is the great chooser of consciousness. It selects the headlines….frames the story. If the media decided to unite America, America would be united. If the media decides to divide America….America falls apart.
David….you are the media for raw milk. Chose to unite us. Chose headlines that find unity. Chose headlines that create progress and understanding. Chose content that educates and unites us all.
When you chose to tell stories of throwing farmers under the bus….that is so unfortunate. I have thrown no farmers under the bus. As to Miller, I wish him all the best, as he fights an impossible battle.
Mark, the media is much more a mirror of society than a chooser of consciousness. Unfortunately, many of us don’t like what we see when we look in the mirror. Believe me, I didn’t make up the growing discord in the food rights community. At its heart, it is discord over whether the public and private food markets can co-exist.
You and I have had this discussion on and off over the last several months. The big picture, in my view, is that most food producers, like you, operate in the public sphere. When you operate in the public sphere, you gain access to the vast public channels–the retail stores, the farmers markets, and increasingly, Internet outlets like Amazon. However, to use these lucrative markets, you must pay to play. You must say “Yes, sir,” when a particular town public health department, the CDFA, FDA, USDA, and whomever else comes up with a new permit (and fee) or a new rule. You can rail against one or another rule or standard, as you often do, but in the end, you have to do what they say. That is the unwritten agreement you entered into when you decided to sell in the public domain.
An increasing number of small farms (including Amos Miller’s farm) have decided the controls imposed by the public regulators are inconsistent with producing good food, and these producers have opted to sell in the private domain. They can essentially do what they want in the private domain, so long as they don’t have permits, and don’t use the lucrative retail/wholesale structure that exists. Most of what they do is sell directly to individuals, like me, via private contracts like herdshare or food club agreements. I understand that these producers may not do the monthly or weekly testing or have the concrete floors or otherwise abide by the public regulations you abide by. I and many other individuals are okay with that, because we have seen their farms and have confidence in their ability and integrity as individuals. If I get sick, I understand that is a private matter as well. Moreover, the private domain is protected by our constitution, and by a fair amount of case law.
The FDA, CDFA, PDA, USDA, and all the other regulatory agencies HATE the private domain, because they don’t have power and control there. This is about power and control, not about safety.
For many years, in the food rights and raw milk arenas, the two domains (public and private) have peacefully co-existed. You may have been jealous about the fact they didn’t have to do the same dances and pay for the same permits as you, but you kept your resentment under wraps. Many of them were suspicious of RAWMI for pushing the regulatory agenda too aggressively. But like you, they kept their resentments under wraps. The dissension and mistrust that has developed over the last year or so occurred in part when you got so pissed off at the private sphere (as represented by Amos Miller) that you decided to make public noise about it. Moreover, your dairy has gotten itself into ongoing trouble because it’s been unable to consistently abide by all those regulations you agreed to abide by.
One of the points I made in our discussions is that you, as a food producer, can’t operate in both the public and private spheres. You choose one, and that is where you do your business. If you as a public producer try to distribute privately, and not abide by all those public regulations, the regulators will squash you very quickly, which is what they did nearly a decade ago when you tried to sell raw milk as pet food outside California–the FDA hit you with felony charges. Similarly, the farms that produce privately better not try to sell in Whole Foods or health food stores, or the regulators will squash them just as quickly.
So that’s a long explanation of why this particular media source is suggesting problems at OPDC and RAWMI, and previously at Farm-to-Consumer Legal Defense Fund. I am just a mirror.
You write that many of the farmers operating in the private domain “…were suspicious of RAWMI for pushing the regulatory agenda too aggressively.”
In fact, RAWMI has never pushed a regulatory agenda, and RAWMI certainly has no regulatory authority itself. Rather, RAWMI encourages farmers—whether they choose to pursue the RAWMI listing process or not—to understand, assess, and mitigate the risks associated with their specific operations. Testing for pathogens is a crucial part of the assessment process, but is in no way regulation.
Thats BS Ram. We can all read between the lines. Not to mention his direct statements against small and unregulated dairies. Go peddle your lies elsewhere.
I have to wonder = Pete = if you’ve ever come within 100 yards of the man whom Mark McAffee is in the real world? Having spend about a day in his company, I can give all-concerned vive voce evidence that he has, consistently supported raw milk for human consumption from every source. As long as those providing it are oriented to doing it to the best standard we can. So it puzzles me when I read – time and again – people slagging him as though he’s out to run “the competition” off the playing field.
… the Campaign for REAL MILK has been underway for about 20 years. We have passed the tipping-point ; the trend to normalize it, is unstoppable. The Jig is Up for Cooked milk | that model of Dairying in Hammerica is a sunset industry. If his detractors would only honestly examine what Mr McAffee presents, you’d realize that his business cannot possibly fill the demand for butter and fluid milk from genuinely grass-fed cows.
… I’ve said it before and I’ll say it every time I see its ugly visage raised in this forum : the knock against Mark McAffee ‘that small and unregulated dairies ought not to be allowed to provide REAL MILK’, arises from covetous-ness of his success
Thank you for this ” An increasing number of small farms (including Amos Miller’s farm) have decided the controls imposed by the public regulators are inconsistent with producing good food, and these producers have opted to sell in the private domain. They can essentially do what they want in the private domain, so long as they don’t have permits, and don’t use the lucrative retail/wholesale structure that exists. Most of what they do is sell directly to individuals, like me, via private contracts like herdshare or food club agreements. I understand that these producers may not do the monthly or weekly testing or have the concrete floors or otherwise abide by the public regulations you abide by. I and many other individuals are okay with that, because we have seen their farms and have confidence in their ability and integrity as individuals. If I get sick, I understand that is a private matter as well. Moreover, the private domain is protected by our constitution, and by a fair amount of case law.”
freedom from inspection and control and more regulation. Now from inside the movement? no thanks. The whole point is hand shake contractibility and staying within a range of being able to handle it. 🙁 not getting so big that it’s putting all the raw movement in jeopardy. Pushing RAWMI on small farmers as now some kind of gold standard. If you want to see healthy animals walk my paddock. clean milk room come on in and see it. This getting bigger is only walking further back into the hole a small farmer like myself opted out of decade ago.
Eventually, Jojo, some customer is going to ask to see your test results before buying your milk, and they might be the first of many. Are you ready for this?
From what I’ve seen, where RAWMI differs from government is that RAWMI is entirely voluntary. Government is mandatory. Governments tell us what to do and order us around, but RAWMI sets standards and then leaves everything up to us on how we get there – if we choose to – we set our own procedures.
Can you consistently meet your state bacteria standards (if any) without RAWMI training? Or, RAWMI Common Standards of a rolling 3 month average of <25 coliforms, <15,000 SPC, and zero pathogens in your monthly tests? If so, then good for you!
Don't like RAWMI? Then how about set up another producer organization that fits the bill for you. Right now though, RAWMI is the only national one we have.
Yes, you are right. RAWMI = voluntary. Its farmer and consumer driven. And, it focuses on mindset and going through the process of understanding risks and managing them on your particular farm. Writing your own plan, often with mentoring, is a great exercise.
Don’t expect the government to set raw milk safety standards anytime soon. The mindset largely remains that raw milk cannot be produced safely, no matter what you do. In my opinion, its going to be a farmer-led movement for the foreseeable future.
Shaking my head… people pushing an agenda and then claiming its voluntary. It’s like stating all organic is better when now in fact its such a mutable word no one knows what to do with it. Give the consumer a little bit of information, and they think they’re experts. I did have a person once come and ask… i gave them my DHI reports. And extra lab reports on milk testing i had done. They had no idea how to read them or what it all meant. They were just spouting off what made it to mainstream, as a request for getting raw milk. I have no doubt they didn’t even know what they were looking for or asking….
David, while I think I understand your reasons for writing and asking questions regarding OPDC/RAWMI, I have to say, Mark’s response sounds reasonable to me as I certainly identify with Ken C.’s culinary experience. Of course, as a Californian, I am blessed to be able to purchase Mark’s milk when my own farmer’s cows are not performing generously.
Forgive me for going off topic, but while Mark’s attention is on the blog presently, could I ask him his take on “cold pressed milk?” I just read about this method for ‘raw’ milk processing that they are doing in Australia. Is this really ‘raw milk?’ Mark, do you know
about this method of processing? I’m just curious what, if anything, you think about it.
Thank You.
Murrieta,
I know a little about alternative forms of log reduction methods. I said log reduction methods because these methods are not recognized as replacements for heat pasteurization. Uv light is used in South Africa and some other countries and has remarkable differences because lysis of cells does not occur.
As for pressure…that is called “pascalization” it is in the range of more than 50,000 pounds per square inch and literally crushes milk or other fluids. It is currently only approved for juices and not milk.
Any killing of raw milk bacteria that does not use heat or other approved method that has been validated by the FDA to equal a five log reduction of target pathogens….is not approved. That means milk is not raw when pascalization….but it is not pasteurized either.
In the USA, it takes big politics and huge money to get alternatives to heat pasteurization approved etc….
I do not know the effect on enzymes and proteins. Would love to know about flavor, lactose intolerance and allergenicity. Uv treated milk is supposed to be non allergenic because cells are in tact and not lysed. It is also supposed to still build antibodies because the body still recogized bacterial cells that are intact. As for lactose intolerance…..would love to have more information.
The lactose fermenters naturally found in raw milk ( coliforms and some other good bacteria ) takes care of digestion of lactose found in raw milk. Kill those bacteria and digestion of raw milk generally follows.
The answer to alternative forms of pasteurization lays in good food safety programs, solid accurate rapid testing programs, with excellent herd health and a RAMP program.
This is a political will question. Raw milk is very safe…but it is the whipping boy and the dairy industry is bloody jealous of raw milk…cause the rest of processed dairy industry is loosing money faster than ever. It costs at least $18.50 to produce 100 pounds of milk…dairies in CA are getting about $12. Per cwt. this is a road to hell. It is no wonder that raw milk is hated by industry and those dairies that work so hard to get less than nothing for their very hard work. We are losing a dairy a week in CA.
There is no true replacement for raw milk, processed by any method is processed milk. There are better processes and worse processes….pick your compromise. I chose safety and good whole raw milk. . The QMRA’S in the EU speak the truth. Raw milk is a low risk food.
as for “cold-pressed raw milk” = about 6 years ago, at the health show in Vancouver BC I met the representative for Lovett fruit juices from Eastern Washington State. At that time they were promoting apple and cherry juices packaged using ultra-high pressure. He mentioned that they hopes for doing the same thing with milk. From a ‘google’ search, apparently Lovett is not in biz. anymore
… What’s presented as an image from a micro-scope in the news reports about high pressure preserving of milk, appears to show damaged bacteria, i.e.. dead. but the super-high-pressure does not discriminate between pathogenic bacteria, and the pro-biotics bacteria = the good ones. Thus I am pessimistic that this method is THE answer for purists like me.
Consumption of Low levels of pathogenic bacteria is no different than what our official governments vaccination programs do quite intentionally. In order to develop immunity….vaccines with pathogenic bacteria are ingested, injected, absorbed or inhaled.
It is no wonder that raw milk consumers have strong immune systems….they get exercised.
One more thing….if you test raw milk enough….you will find things. Test it daily and you will definitely find things…. If you never test raw milk…you never find things. Untested raw milk is therefore very safe because you never find things!! . Isn’t logic wonderful?
This logic is used for pasteurized milk….FDA policy says…never test pasteurized milk….just trust the five log heat process and it is always safe. Because there is no test data….There is no evidence otherwise. Therefore….pasteurized milk is very safe and there is no pathogen test data to show to the contrary.
Our FDA needs to get its head out of its political back side and be a little more faithful to science.
Marietta,
Overall good health is the furthest thing in the minds of those who advocate and use processing methods such as HPP. Increasing the products shelf life is first and foremost… I share Gordon’s purest view when it comes to milk/food. http://www.vivejuicery.com/the-cold-pressed-difference/
“All fruit and vegetable juice found at the supermarket must be processed and treated to maintain a longer shelf-life as required by the Food & Drug Administration. Most commonly this is accomplished by adding preservatives and pasteurizing. Pasteurized juice is heated to a high temperature for a short time before it is sold. While that may sound fine, pasteurization kills the vital raw vitamins, enzymes and minerals making the juice nutritionally pointless.
‘A new “alternative” method to pasteurization, known as high-pressure pascalization, bridgmanization, high pressure processing or (most simply) hpp, is a method of preserving and sterilizing food, in which a company send their fresh pressed juices out to a factory that submerges the bottles under water and bombards them with up to 90,000 lbs of pressure (HPP) and then ships the juices back to the juice manufacturer who then releases them into the wholesale distribution chain with an expiration date of twenty-some-odd days later. Simply put, when you drink a hpp juice, you may be drinking a “fresh” juice that is 20+ days old. Keep in mind that companies that use hpp are able to promote their product as raw, organic and unpasteurized.”
Indeed, “A processed product of any kind is NOT raw”.
Thank you Mark, Ken, & Gordon. That gives me a better explanation than what I have been reading regarding “cold, high pressure” processing. Maybe in the future we will find out what further happens to milk when subjected to this process. It seems to be the same old story…man just cannot improve on “mother nature,” and few know how to respect her rules enough to produce decently nutrient dense food products. I truly respect those farmers who do.
“One cell does not create illness. If one cell did create illness….we would all be dead!”
Actually, this is not true. A single cell does have a probability of causing illness. This is a well described feature of most microbial risk assessments.
Don, theoretically yes, a single cell could cause illness. But, what is the actual quantitative risk of this single cell actually causing an illness? One in N billion? One in N trillion? And, what does the host environment need to look like for this illness to be caused? What effects might competing bacteria have on this cell’s chances? The considerable differences in gut microbiomes between individuals? The host’s immune system? Do you have numbers?
Don,
If one cell caused illness, then why is the pathogen dose load for salmonella at least 10 to the 5th or 100,000 cells.
This is data straight from a UCDavis Phd epidemiologist ?
The load in the air behind a chicken truck carrying live Chickens would kill everyone if you were right.
That one cell you are talking about must be found, isolated, grown under extreme lab conditions, in temperatures not found in the body, in Ph conditions not found in the body, with growth media not found in the body or nature, with the addition of antibiotics not found in the body, to get that one cell to grow to more cells for possible detection.
The science says that lactose fermenters found in raw milk ( coliforms etc ) …actually destroy salmonella through their acidification and creation of lactic acid . First the lactose fermenters must be killed off at the lab to get salmonella to grow.
Now tell me honestly….how could one cell of salmonella trigger illness especially in raw milk.?
Even the FDABAM or even BAXPCR says that it takes more than 1000 bacteria to trigger a detection….not one cell. 500 cells means no detection!!! ( specifically with regard to salmonella ) Please explain your scientific methods and basis.
Public and private food models must be able to co-exist, and I think we are still trying to figure that out how that works in real life. It is unfortunate that regulations make producers choose which camp..and what David says about there being trade-offs for each model it so very true.
I believe the real adversary to the production and access of real-food is the web of inconsistent regulations. They are inconsistent state-to-state, they are often inconsistent with safety, and they regularly are inconsistent with customer demand. Regulation makes it NUTS for a public-sales producer like Mark as he so clearly articulated in his comment. And in my case, regs make it impossible for me to come under a regulatory umbrella at all without committing financial suicide or completely changing my farm model.
Or in Amos Miller’s case, there is no regulated way for him to do what he is doing…to provide the type of food he does over state lines. So he operates in this grey area that is very open to scrutiny and pushes the limits hard. I can appear unfair to farmers who are subject to regulations, and that’s understandable.
Its a bit of a hot mess. But at the end of the day, Amos Miller, Mark McAfee, me, and the many other traditional-food producers have the same goal–to produce real food that people want and need. The best way to achieve that goal depends on many variables…your state, your community, your business model, your customer demand and demographic. As I say to my kids all the time, “fair does not always mean equal.” We have to extend freedom and support to one another as producers to operate in the way that best meets our goals.
I’ll add that one place where the two models co-exist extremely well is within RAWMI. Ten listed farms so far, 6 not-regulated and 4 publicly regulated. What unites us is our shared goal to produce quality raw milk as safely as possible, and it works wonderfully.
Shawna, you six not-regulated dairies are fine working with RAWMI, with one major proviso–you don’t grow large enough to become perceived as a competitive threat to OPDC. If you do, I advise you to watch your back. That, I believe, was Miller’s major sin in life.
Don,
Could you please inform me of where you find indications that one Salmonella bacteria can cause infection. Please provide reference. I have seen no evidence that such a low dose can cause disease.
I performed a study in 2005 just looking at public source waste water, from two cities. (http://www.ncbi.nlm.nih.gov/pubmed/17105561)I sampled municipal water (source humans) and I found Salmonella in every 1 ml from waste water. Sometimes so much Salmonella I had to add antibiotic to my enrichment media to suppress some growth. I therefore conclude that a large proportion of our urban population are naturally and without causing disease carrying and shedding Salmonella. We are hugely lacking studies of fecal shedding in humans, but infection is never a black or white of presence of one bacteria in one food. It takes a series of unfortunate situations to cause disease.
I do not understand the hype and distrust and conflict and confusion that David Gumpert is trying to create about some bacteria in some samples. I thought we were dealing with raw food and not sterile food intended to feed astraunats.
I have looked at the sampling methodology of the CDFA and it is totally inappropriate for food safety screening and seem to be unfounded and not used by any other food safety programs elsewhere.
Cat, my reference to salmonella being found in samples of OPDC milk last month wasn’t meant to be a scientific description of what actually happened. I was expressing frustration, that these regulatory problems weren’t isolated examples, but just the latest in a very long list over a period of years. I was also expressing frustration that OPDC blamed an egg producer for the first problem in May, and then, after getting rid of the egg producer, had another excuse for the second problem in May (the CDFA standards and measurement approaches, from what I understand). In the absence of the OPDC history, I would be out there banging the drum about regulatory injustice about the May issues, but it becomes difficult when the problems keep coming, and when OPDC accuses other farmers, with virtually no history of safety problems, of selling tainted milk.
David,
The germaphobe will always be searching for excuses to their disruptive and restraint based methodologies.
Mark understands very well the shortcomings of the methods used to control microbes including, RAWMI’s ability to mitigate illness. Unfortunately he is attempting to serve two masters…one master (the germ theory) is telling him that microbes are harmful and need to be controlled and the other (the hygiene hypothesis) is telling him that microbes are good and necessary for survival and good health. He, including those in the raw milk movement who share his view are, according to Dr. Daniel H Duffy Sr. of Geneva, Ohio, “victims of the germ theory propaganda that has about 85% of the world’s “educated” population under its control…” Those who are attempting to accommodate both masters are engaged in a precarious balancing act that represents a temporary band-aid solution at best.
Natural, unadulterated raw milk is safe and always has been…the only reason why it and all foods become unsafe is because of the attempt to manipulate them and human physiology six ways from Sunday. To suggest that raw milk’s safety can be improved by limiting the presence of a highly ubiquitous microbe such as salmonella is plain foolish.
For those who preoccupy themselves with keeping track of specific microbes let me again ask you this question. “In what way does identifying a specific microbe enable humans to control it in a practical sense; in other words, without undermining the “natural” integrity of the entire microbial ecosystem and its symbiotic relationship to humans, animals, plants and the environment?”
Having had raw milk from both RAWMI-trained farms and untrained farms, and having suffered no ill effects what-so-ever from farms with the low bacteria counts that result from RAWMI-training, let me advance a potentially radical theory:
1) Bacteria which may be in raw milk are NOT what make it more digestible or “better for us” than pasteurized.
2) Most people not from an Asian background can digest milk. Lactose intolerance in other populations is exceedingly rare. Most of us do NOT need bacteria in the milk to make it “more digestible.”
3) The main benefit of raw milk is that it has not undergone pasteurization OR homogenization, two processes which damage milk’s cell structure. Pasteurization leaves (as Mr. McAfee described it so well in one of his talks) “blasted bug bits” in the milk, these being small proteins from the dead bacteria which then act as irritants in the gut and can pass through the gut wall and cause histamine reactions. No-one has truly examined the damage done by homogenization – this needs to be be investigated, but take a look at the photos at http://www.westonaprice.org/health-topics/microphotography-of-raw-and-processed-milk/ and come to your own conclusion.
If you want more “beneficial bugs” in your milk, then certainly culture it into yogurt or kefir, both having coliform counts of over 100M – counts this high have a far better chance of passing through the stomach and into the gut in order to do us some probiotic good.
Meanwhile, if “RAWMI-training” or its equivalent can result in fewer outbreaks, then sign me up. I don’t want any bad press or lawsuits from any of my customers getting sick.
Correction: meant to say “bacteria counts” not “coliform counts” in regards to cultured products.
This is my experience. There was local coverage on the latest CDFA declaration on OPDC. My current gallon at the time was from June 1st batch. I read symptoms would show by the 4th day which was about where I was. I know Mark tests with outside sources and his tests came back negative so since I was not experiencing any symptoms, I finished drinking the gallon with no ill effects. Perhaps it was my tested immune system as I’ve been drinking OPDC raw milk for years. My choice.
Where is the applause button for our champion of food safety PhD, Vet and epidemiologist Dr. Cat Berge and RAWMI board member!!
David, OPDC welcomes new members into the commercial raw milk community. Because we know that each new member of the community must build new consumers and that means a large base for everyone.
Teachers vs. Leachers:
Market builders and teachers….there is always room for those that expand markets. If you have a problem with that….you should call me and lets talk.
Their must be a fair and balanced market system, that is a tenant of democracy.
Shawna is a teacher. She produces raw milk is a strict Cow Share program in Shasta CA. She is member of RAWMI and is LISTED. She mentors farmers all over the country to help them. She is also a teacher and has expanded beyond her ability to feed all that want her precious good safe raw milk. So….what does she say to the extra Cow Share owners or random consumers that want her raw milk….go to Berryvale Market down the street and get OPDC products.
Berryvale market saw 35% growth last year with sales of OPDC products. That was because Shawna is a teacher and not a leacher. She gives more than she takes and with this teaching the world is good to all. I help Shawna in any way that I can as my morsel of love to say thank you for all she does for OPDC and all she does unselfishly for all that need mentoring in the greater community.
David….do you really think that I am a selfish self centered monster to be guarded against? Those that know me know better.
I think I am going to reserve further posts. I did not post for a couple of months….I was shocked to see negative headlines with RAWMI and OPDC in the same sentence.
FTCLDF, OPDC and RAWMI are all a little in shock. We are all strong and doing great work for the raw milk community. We would appreciate it very much if The Complete Patient would support our causes instead of starting up and stirring up negative divisive narratives.
You should be writing about how CDFA uses “Environmental testing” methods on food when that is completely unfounded and an invalid method.
The idea that this blog will get mileage out of turning large raw milk producers against smaller cow shares….is really not good, not productive and unfounded.
Lets see if we can get a new post up soon that concentrates on some good work.
Mark, I definitely don’t think you are any kind of monster. You have done too much good in the food community. But I do think you have shown yourself to be more about the money than you let on.
You know, the Marines have a motto, “Always faithful.” That means they are loyal to their country, and to each other, through the toughest battles. I thought that the FTCLDF and RAWMI lived by something approaching that motto. Even when a farmer like Michael Hartmann of Minnesota behaved in ways some of us thought were erratic or questionable a few years back, the community stood by him in court and via public communications. That shifted with Amos Miller, and with your egg producer (I know, you didn’t name the farm, though I have seen the producer’s name mentioned.)
Once you start making exceptions, sacrificing one farmer, or two farmers, because of some personal grudge or some worry that they are taking business from you, or whatever, you open a pandora’s box. One thing that quickly escapes from that box is a reasonable expectation of getting the benefit of the doubt when you encounter problems. And OPDC continues to encounter problems, despite all the talk of RAMP and test-and-hold and all the other mainstays of RAWMI.
I definitely continue to support the raw milk community. I just don’t like it when other segments of the community are reckless and also endanger a farmer who supplies me and many hundreds of other individuals who depend on that food. Definitely not the best ways to gain credibility and to unify the community.
It started farther back than that, after his MM lawsuit when he got RAWMI going and started openly attacking small dairy producers as filthy producers who can’t produce clean milk without RAWMI and started pushing producers to come under state regulation.
That was also the inflection point when he turned his back on probiotic milk in favor of making ‘raw’ milk as sterile as possible.
Yet here we are and OPD continues to have contamination problems while the small farmers who produce clean safe milk without regulation for centuries continue to do so unabated.
saying ” … OPD continues to have contamination problems …” knowingly leaves out the fact that Organic Pastures in under the micro-scope of The Authorities. Meanwhile all the others ” … who produce clean safe milk without regulation for centuries …” have the luxury of operating in the shadow cast by Mark McAffee as he takes the flak.
… In fact, people who drink raw milk get sick from it, occasionally. But when someone falls ill from raw milk from a small producer, whom CAFD doesn’t even know exists, no-one finds out, outside a very small circle. When OPastures has a recall – Gunslinger Marler and his handmaiden = the Wicked Witch of the the Milk~Woe = do their damn’dest, ensuring the incident gets national media coverage. But their one-trick pony routine went stale long ago.
… Washington state is a good example for how REAL MILK is now normalized. A few times a year, one of its 18 licensed raw milk dairies goes through a scare, in which someone new to it, gets diarrhoea. That batch gets recalled, the dairy then has to meet testing standards anew, and life goes on. Just like every other foodstuff in commerce.
Pete, what proves you completely wrong about Mark and small farms is the existence of farms such as Charlotte Smith’s RAWMI-listed Champoeg Creamery in Oregon – she has 3 cows.
Never-mind the smallest producer I know: hand-milking one cow, mentored by a RAWMI-listed farmer, and consistently beating state bacteria standards in monthly milk sample tests.
Can we have a show of hands for small producers (or former small producers) who feel supported by Mark and/or RAWMI? An “aye” from here.
Mark
At the end of the day, the important thing is to trace and eliminate the source of the salmonella. In my mind, this is just another ‘poop in milk’ contamination problem. So investigate the usual suspects (and any physical interactions). For me, milk-fed calves and their care-takers are way out in front. Next, I’d take wild birds and where they roost/poop. Finally, other vermin, flies (often a problem for Organic production), cats, dogs and yes, the staff themselves. A major strip/sanitation of the parlour, the milker’s break-room and the bottling area. Might not solve the problem, but cannot hurt, I’d think.
Good luck sorting this out and getting back to consistently safe milk for the rest of 2016.
John
“Once you start making exceptions, sacrificing one farmer, or two farmers, because of some personal grudge or some worry that they are taking business from you, or whatever, you open a pandora’s box.”
David, it is a worrisome stretch that you extend these words to describe Mark’s decision to no longer carry eggs simultaneously with raw milk. Troubleshooting the source of salmonella and choosing to make changes based on the evidence at hand could hardly be called a “personal grudge” or a worry about business being lost to someone else. Although, choosing to take no action could certainly result in lost business… which would inevitably go to someone else. I fail to see what alternative action you would have recommended in this case.
I would be greatly interested in hearing more about CDFA’s sampling methodology as referenced by Dr. Berge. I do not live in California, but it is always good to learn more.
John, “at the end of the day” you are not the producer dealing with the obviously huge discrepancy between “environmental lab testing” and “food safety lab testing” that the CDFA put forth in regulatory fashion to make it nearly impossible to put raw milk on the retail shelf. “At the end of the day” you and I probably have more “pathogenic” microbes in just our random sneezes that would make germaphobic individuals treat us like we had leprosy! “At the end of the day” a food server/chef at a typical eating establishment should cause more concern than trying to sanitize my farmers milk stanchion. You should wish Mark “good luck” because you know intuitively that you just couldn’t do/accomplish the work that he has. So, I wish you “good luck” in the pursuit of “a sanitized food chain.”
As for Salmonella in specific, it’s routine in the U.K. to vaccinate chickens yet against this bug, and hence eggs there can be sold unwashed, unrefrigerated, and unlikely to contaminate nearby milk. Is the poultry industry in North America looking at this option yet?
Trace numbers of pathogens are (in my personal opinion) crucial to immune function and strength of immunity.
Our regulators do not share this opinion. Hence the disconnect. Even the standards approved by the FDA agree with me….trace numbers are not a trigger to detection!
It takes 10 to the 3rd power or 1000 to trigger detection taken from a sample of 25 ml of product. Not 1 cell in 1000 ml.
There is also a disconnect between regulations in CA and reality in raw milk. People drink raw milk because it builds immunity…not because it is sterile! We at OPDC are regulated by those that protect and inspect pasteurized milk. They know nothing but sterile dead milk. It is really not their fault. We are the outlier and the anomaly of their inspection day.
All across America, labs test raw milk every day and they use standards and methods that are AOAC ( BAX PCR FDA BAM USDA FSIS etc ) approved, current and validated.
When David says that we are having continuing problems with our milk…I think that there has been a failure to communicate.
If OPDC raw milk was tested at any lab other than CDFA, salmonella tests would have been negative. Penn State uses the same tests that our lab uses. No problems.
So….my issue is why is this an issue? Why is OPDC raw milk a story?
It should very much be a story that CDFA does not use validated FDA BAM methods but claimed they did until we discovered this fact( that have random positive results )….but pointing a trouble finger at OPDC, that borders on raw milk treason.
the notion that vaccinating every single bird in the CAFO supply chain, will dial salmonella down to zero, in eggs or poultry meat, is insanity writ large. But of course, it’s a wonderful pretext for putting small flocks out of business.
… The contrast between the nutritional content of eggs from CAFO raised birds, versus pasture-raised birds, is one of the handy demonstrations of how Big Gag failed us. The mindset that ‘bigger is better’ does what the Soviet model always winds up doing in every area : stealing value by stealth in order to meet some propaganda illusion. On Southern Vancouver Island, genuine free-range eggs sell for Cdn $7.25 per dozen, in the same display case as other eggs of various grades, priced all the way down to ~$2.00 per dozen. Informed consumers pay that premium because they know they are getting more food value for the money. Same with REAL MILK = “why not the best?”
Meanwhile public health officials are well-aware that their own tests prove ~25% of eggs coming out of egg factory farms, show positive for salmonella. But not a peep nor the rustling of a wing, about those eggs being used in the dressing for authentic Caesar salads!
No-one ever said zero, Gordon. That’s hyperbole. But how about this report: “the number of laboratory-confirmed cases of illness dropped from more than 18,000 in 1993 to just 459 in 2010. – https://news.liverpool.ac.uk/2013/01/16/vaccination-responsible-for-dramatic-fall-in-salmonella-infections/
… but the U.S. government decision in 2010 was not do it, despite the number of illnesses caused by salmonella and that it would cost pennies per bird. – at http://www.nytimes.com/2010/08/25/business/25vaccine.html .
““We have pretty much eliminated salmonella as a human problem in the U.K.,” said Amanda Cryer, director of the British Egg Information Service, an industry group.”
Marietta,
Thank you for the reply. Maybe I’m missing something, but my understanding is that OPDC has had negative salmonella tests for years, but now has had 2 positives in a row. I might have missed that CDFA has recently changed their methodology to generate these positives. My apologies if I missed this. Hence, my (hopefully helpful) ideas about getting back to negative.
In my mind, one way to keep salmonella out of milk is to put the milk in a bottle and seal it with a cap. I just cannot see how having eggs on the same truck can be an issue. So, not allowing the eggs in the truck didn’t lead to a second negative. Now the test itself is the issue, it seems.
Nope. In my mind salmonella bacteria are getting into the milk somewhere between the teat-end and capping the bottles.
In my mind, complaining about the test doesn’t lead to negative tests in the short-run. The test indicates contamination, and the system demands it be addressed by ‘sanitizing’ milk harvest and packaging.
Yes. I’m a germ-theorist, but I’m by no means alone. The North American food system has evolved to ensure microbiologically ‘safe’ food, recognizing this will result in a population with some susceptibilities. The thing is, once you establish this, it becomes an enduring requirement. Maybe this is the wrong approach, but I don’t think this is for me to judge. You don’t like it, fine; and you have the freedom to not participate. Mark, however, is in the public food business and has no choice but to meet their demands. Part of doing business.
John
John, you sound like a RAWMI raw milk farmer! I’m not sure your background, but I’m guessig food safety and science. Anyway, these are the questions that farmers certainly ask when trying to figure out root cause of an unfavorable milk test…whether it is elevated coliform or SPC, or in this case, a low-level presence of a pathogen.
And yes..”poop in milk” is typically the first question. That is the easiest issue to correct to be sure…the proverbial “low hanging fruit.” Its when you are certain there is no poop-in-milk, and your tests are still not right, that it becomes quite a game of Sherlock Holmes and can be quite frustrating. Its when we often call on our helpful Phds who can help us think out of the box and explore other means of contamination.
And of course, one of those out-of-the-box questions raised is this case is testing methods. I’ve had the privilege of working with PhD researchers on my farm this year, and one of the things I have learned is that testing is not nearly as simple and straightforward as I’d imagined. So it doesn’t surprise me that this is also being considered. In any case, no one is more motivated to figure it out than the raw milk farmer, I can guarantee you that.
John,
Simple question….do you agree that the national standards used by all labs in the USA is the Standard that should measure the detectable presence of pathogens? That Standard is called the FDA BAM or AOAC approved methods. Do you agree with that premise?
If you do then….OPDC does not have salmonella in its raw milk!!
CDFA misled OPDC that it uses nationally approved and validated lab sampling and testing methods and standards. CDFA claimed it used FDA BAM. After investigation, it was revealed that since 2007, they have used Moore Swabs ( illegal for use on foods and only approved for use in sewer water ) and its own hybrid protocol of unvalidated processes. Their own lab Phd admitted that CDFA does not use FDA BAM methods.
No court of law would allow these methods for standard processes as evidence. The state of Pennsylvania has at least 150 raw milk permitted dairies. They all use the AOAC FDA BAM methods and even allow private labs forvtesting. Just like OPDC and its private FSNS lab. All of these tests are negative.
Now….ask yourself the question again. Does OPDC have a contamination issue?
This is huge news in my book. But…..because I must work with my regulators, I can not bite the hand that signs my creamery processing permit.
Justice has its way of working through karma. We have not been shut down….there have been zero illnesses. They have only recalled certain date codes and left others alone and on the shelves. Obviously…not a food safety issue.
You do the math…
Its kind of like running in a race and finishing first….but one of the race judges that is only assigned to you…has a different stop watch and it runs slower…so you never can win, even though everyone in the crowd saw you come in first. Feel like Jesse Owens in front of Hitler.
Mark, that is very strange, that CDFA would follow different testing standards than FDA, and not say anything about it….or maybe not so strange. It wouldn’t be the first time they have quietly changed the rules without telling anyone (as in the coliform standard years back). My question: Does CDFA apply these new standards to other food producers? To other dairy producers?
David,
I think you should call up CDFA and ask them just that question.
Ask them if they use Moore Swabs on pasteurized milk for detection of salmonella.
Also ask them why they do not use the FDA BAM or USDA FSIS AOAC methods ?
I look forward to hearing what they say….you should also confirm with Penn State what test they use and if it is FDA BAM AOAC compliant.
Be careful Mark not to put too much faith in any one test. Is this RAWMI’s recommended plan of action… pull product from the shelves and search for a solution while at the same time arguing the validity of the test that implicated the product to begin with?
With respect to the Moore Swabs, FDA BAM or USDA FSIS AOAC, all are viewed as valid testing methods with each method appearing to have its limitations. It has been noted in certain articles that using “multiple methods” in conjunction allows for the detection of a “greater diversity of bacterial isolates”. In their attempt to stay ahead of the complex web of bacteria in food not to mention the more relevant chemical and drug residues such as, acrylamide, benzene, chloramphenicol, ephedrine alkaloids, fluoroquinolones, and melamine etc. etc. etc., the FDA and the Departments of Food and Agriculture certainly appear to have their work cut out for them. An endless effort indeed, like a dog trying to keep its head above water while at the same time chasing its tail around in circles.
Bill Bryson correctly states, “Because we humans are big and clever enough to produce and utilize antibiotics and disinfectants, it is easy to convince ourselves that we have banished bacteria to the fringes of existence. Don’t you believe it. Bacteria may not build cities or have interesting social lives, but they will be here when the Sun explodes. This is their planet, and we are on it only because they allow us to be.”
Good point, Ken. You hate to always hear whining, “Unfair!” as the explanation for why pathogens were found in your product. Basically, when you sign up with the regulated system, whether in California or Pennsylvania, you are committing yourself to its “system,” and to the ongoing changes and shifts in its requirements. It’s only natural that the regulators are looking at multiple testing methods, and more “gotchas”–that’s their bread and butter. The more testing, the more gotchas, the more work.
Two points:
1. The “system” should be the same testing methods for all foods, not applying one testing method to raw milk and one to everyone else.
2. Not every consumer wants the commitment and extra work involved in joining a private food club or herdshare. They want to pick-up raw milk when they do the rest of their grocery shopping, if and when they need it. This involves, yes, being “regulated.” It also respects consumer demand, and for that, Mark deserves kudos.
Bill, in response to your #1: The CDFA essentially says it can use whatever testing method it desires and, moreover, it doesn’t recognize any private lab methods or approaches. See this article in Food Safety News, where Mark McAfee made his argument about different test methods, and CDFA responded. From what I can see in searching online, Moore Swabs are a recognized testing standard/methodology.
http://www.foodsafetynews.com/2016/05/raw-milk-producer-says-states-testing-method-is-problematic/#.V19u1ldFK_w
#2: I never meant to suggest that raw milk consumers should seek out private sources of milk (or, for that matter, public sources). I’ve always been an advocate of choice, that people should be able to obtain food either way. I’ve pointed out that public producers commit to playing by the public rules, the rules dictated by the regulators and legislators. That’s not to say public producers shouldn’t lobby for changes to rules they don’t like. But when all is said and done, public producers have to do what they’re told by the regulators. You are correct, OPDC has done well to survive in the hornet’s nest of regulations they must deal with.
David,
You are incorrect. Moore Swabs are not recognized by anyone as an approved method to test any food.
They are only approved to test “environments”. BAM is very specific about this.
None of their test methods use FDA BAM. Check again… That’s why CDFA would not answer that part of he question.
My concern rests on one thought….if a regulatory agency is going to publicly proclaim contamination and recall a product, they better be using a nationally recognized method and standard. Those standards must be current and validated.
CDFA does not use a recognized validated method or standard. Pennsylvania uses the same standard used by the OPDC lab. Our lab says there is no pathogens.
I am blaming no one….I seek equality and fairness.
To quote Dr. Pena, one of our vet experts and advisors said this….”.why would CDFA ever deviate from the Gold Standard BAX PCR to detect pathogens ? Moore Swab is not used for food ! “. “Just does not make sense. No one uses Moore Swab on any food “
Yet, it makes perfect sense if there is subterfuge involved. It’s no mystery that tptb want clean, farm-fresh milk to just “go away.” You, Mark, are making tptb in CA actually work
for a living instead of just rubber stamping industrial sterile “phood.” That takes a lot of
effort, thought, mindfulness! You are just a thorn in there side, and I wouldn’t put it past them to try anything in the “books” to get rid of such an irritant. JMHO.
Marietta,
Hugs to you!
There is so much going on….super busy. So busy and fascinating that I can not share yet. I have shared some of this with David and it is my hope that he can break some good and interesting news very soon.
As a family of humans that want delicious raw milk for all whole desire it…trust me on this one: There is breaking RAW MILK news quietly happening all over the place.
In the effort to share learning here are a few thoughts
Our Phd vet says….how do you find bacteria? ….start testing. You will find them.
We tested all of our cows at OPDC in sets of 20 cows to determine if some of our cows were shedding salmonella in their manure. 5 sets of 20 cows showed a detection of salmonella. We immediately tested those 5 sets of 20 cows in sets of 5.
The results,….totally stochastic !!! None of the cows were detected to have salmonella. Our vet says that during here testing of bulk tanks on conventional dairies and waste water across the San Joaquin Valley revealed that salmonella was literally every where.
Another way to view the CDFA test methods, that are not FDA BAM or validated by any recognized agency is this….the Moore Swab test can be worn as a badge of honor. We pass the un passable.
I would strongly prefer a fair and validated method that is current, recognized and validated by a nationally recognized agency.
Mark,
The 5 sets of 20 cows. Are these still manure tests, or milk? If milk, were these samples taken from cows during milking?
Thanks.
John
A SARE Grant:
Development of resources for small raw milk cheesemakers to conduct science-based risk assessments
http://www.nesare.org/Grants/Sample-Grants/Research-and-Education-Grants/2016-Research-and-Education-Grants/Development-of-resources-for-small-raw-milk-cheesemakers
John,
We took manure samples directly from the rectum in lock ups after milking. All samples of manure on second round of testing were negative. This was just seven days after the first round of manure tests showed 5 sets of 20 cows being positive in their manure tests.
As Dr. Cat Berge Says….extremely “Stochastic”. In other words…lots of variables in play and exceptionally difficult to predict outcomes.
We know that pathogens are naturally occurring in raw milk…it is just a matter of what levels they are found. Current detection methods detect based on threshold standards that are validated by the AOAC FDA BAM and USDA FSIS.
We know this because pathogens are also naturally occurring in raw breast milk as well. Pathogens are natures way of developing the infants immunity.
Mark, The use of the word pathogen is a misnomer for what is one of the most beneficial living things known to man.
Bacteria only become problematic (pathogenic if you will) if provided with the right conditions… Hence the solution is not to focus on and wage a battle against the microbe in an attempt to eliminate it, but rather to nurture an environment where we can coexist with it. The excessive use of toxic chemicals, drugs and hormones in agriculture, food production, personal hygiene and medicine etc. are what in essence, nurture the undesirable conditions that lead to illness. As I’ve stated before if we focus solely on the microbe and preoccupy ourselves with testing we’re barking up the wrong tree.
Unfortunately unless there is a change in this stereotyped, contemptuous attitude towards the microbe by tptb, (for which the use of the term pathogen is indeed a reflection of such an attitude), then humans are destined to continue to live in a fool’s paradise.