Mark McAfee of Organic Pastures Dairy Co.

Is raw milk a scalable business? In other words, can a single dairy keep increasing production to meet growing demand, without limits?

As a number of people have argued here, it could well be that the E.coli O157:H7 problem that, yet again, reared its ugly head at OPDC, is the result of exceeding the natural limits of raw milk production.

The more I think about OPDC’s current problems, the less comfortable I am. Its current legal problems, which Mark McAfee alluded to in a recent comment following my previous post, are apart from the matter of scalability. If you have people getting sick from pathogens in your milk, you run a significant risk of encountering legal problems, whether you have a scalability problem or some other problem.

On the matter of scalability, I’d like to think that simply adhering to a strict set of safety guidelines, such as developed by the Raw Milk Institute (RAWMI), can ensure unlimited production. Unfortunately, OPDC has, over the years, experienced enough pathogen findings, recalls, and now, more illnesses, to create uncertainty.

This isn’t the first time a large California raw milk producer has run up against scalability problems. Alta Deena, an operation of several thousand cows and the major raw milk supplier for California and the country in the 1970s and 1980s, encountered any number of state-ordered shutdowns because of illnesses traced to the dairy.

It’s admirable that Mark McAfee of OPDC is assuming responsibility for the latest illnesses, and not engaging in denial. But the hypothesis that the E.coli pathogens in the current outbreak found their way into OPDC milk via a new route, directly from within one or more shedding cows, is difficult to accept.

Credible literature on dairy cow pathogens suggests that, while the E.coli O157:H7 may have come from a particular cow’s udder, the source was likely an udder infection caused by the surrounding environment. This overview of “environmental mastitis” says that “sources of environmental pathogens include manure, bedding, feedstuffs, dust, dirt, mud and water. Bedding materials are a significant source of teat end exposure to environmental pathogens. The number of bacteria in bedding fluctuates depending on contamination (and therefore availability of nutrients), available moisture and temperature.”

McAfee in my previous post allowed that the very wet December in California may have played a role in creating conditions for E.coli O157:H7.

Why does it matter? For one thing, suggesting that the E.coli O157:H7 got into OPDC milk spontaneously from the cow, and for the first time known to science created an outbreak, creates a new source of anxiety for producers and consumers about raw milk—that there is a potentially unpredictable means of spreading serious illness. Such a theory also deflects concerns about the likelihood that OPDC has simply exceeded the limitations of scale for raw milk production.

The ongoing problems at OPDC also give ammunition to the raw milk abolitionists. Just read a few of the comments following a recent Food Safety News article about the OPDC illnesses, and you’ll appreciate the growing focus on Mark McAfee, and the personalization of the argument that is increasingly taking place.

I don’t want this to come across as an anti-OPDC/Mark McAfee piece. Mark has done immeasurable good for the raw milk movement via OPDC and RAWMI. But he is dealing with an inherent conflict of interest, on several levels.  By virtue of trying to extend the scalability of his dairy, he is putting at increased risk the credibility of the entire raw milk industry.

Separately we saw late last year the inherent conflict of interest at work when the California Department of Food and Agriculture issued new regulations requiring all raw milk producers to have dairy milk permits.

This action amounted to the possible launch of an enforcement campaign against hundreds of California herdshares that have sprung up over the last half dozen years or so, and which have operated in a regulatory gray area. McAfee commented here that the herdshares had brought this new and questionable state regulation down on themselves by failing to come to agreement with the CDFA during several years of discussions about possible regulation of herdshares. Because it’s in McAfee’s business interests to limit competition from herdshares, his comments were automatically going to be suspect, almost no matter what he said.

Take the whole line of thinking further, and it’s clear there’s an inherent conflict of interest in having the owner of the largest raw dairy in the country running a nascent raw milk safety standards organization. As long as there are no illnesses from a RAWMI member, everything is fine. But once there are illnesses, and they are caused by the dairy owned by RAWMI’s leader, the conflict of interest becomes painfully obvious.

Reducing and eliminating these conflicts of interest is doable, if difficult. There are other ways for OPDC to continue growing aside from adding more and more cows. It could be that RAWMI needs to be led by someone without ownership of a raw dairy.

I think RAWMI would be best advised to work to further the interests of small raw milk dairies that want to learn how to produce a safe and nutritious product, rather than expending so much effort on furthering the interests of a few large dairies. Let’s focus on a model that works to produce safe milk, an improved environment, and community economic benefits, to name just a few.