When the full history of the raw milk revolution is completed, one incident that will stand out as a low point will be the Georgia raw milk “pour-out”. That was Oct. 19, when dozens of consumers gathered at the farm of Eric Wagoner in Georgia, and carried out the order of the Georgia Department of Agriculture that milk they purchased in South Carolina be destroyed.

When I wrote about the milk seizure Oct. 15, one major unknown was the role of the U.S. Food and Drug Administration in the entire sorry episode. Thanks to the existence of video of the event and the Farm-to-Consumer Legal Defense Fund’s suit against the FDA challenging the legality of the interstate ban on raw milk, we now know much more than we did, and it turns out the FDA had an important role. The two sides are still arguing about how important it was, but at a minimum, we see that the FDA automatically gets a call when raw milk is involved.

The FDA felt compelled to release information about its role in the Georgia events because Eric Wagoner, manager of the food club that arranged the pickup and delivery of the milk in question, is a plaintiff in the suit against the FDA. The FDA is seeking dismissal of the suit, and part of its argument has been that it has not been enforcing the ban on interstate raw milk shipments on individual consumers transporting it across state lines for their own personal use; thus, it is seeking to explain that it had no active role in enforcing the ban against Wagoner.

What results is something of a he-said/she-said account.

According to the FDA’s account, a GDA investigator looking into allegations of illegal meat sales at an Athens, GA, farmers market, on Oct. 15, 2009, “noticed Eric Wagoner unloading gallon jugs of milk from coolers” on his truck and “inspected the milk jugs, and determined that they contained unpasteurized milk from South Carolina.”

The investigator “advised Mr. Wagoner it is illegal under Georgia law to sell unpasteurized milk for human consumption in the State of Georgia” and then embargoed the milk and “gave a Stop Sale notice to Mr. Wagoner and placed tags on each cooler.”

It was at this point that the deal for how the milk would be destroyed came about, and the FDA entered the scene. According to the FDA account, “Mr. Wagoner agreed to voluntarily destroy the Embargoed Milk. Because a place to destroy the Embargoed Milk could not be found, Mr. Wagoner asked that he be allowed to transport it to his home for destruction on the following Monday. This permission was granted by GDA.

“On Friday, October 16th, 2009, FDA received a telephone call from Peggy Gates, Director for the Dairy Division at GDA. Ms. Gates informed FDA that a meat compliance officer from GDA had placed an embargo on 110 gallons of raw milk intended for human consumption at the Athens Free Market. At no time on Friday or over the following weekend did anyone from FDA have contact with Mr. Wagoner, who had possession of the embargoed the raw milk. At no time on Friday or over the following weekend did anyone from FDA have any contact with anyone else associated with Mr. Wagoner or Athens Locally Grown.”

But there was much more than a telephone call. “On Monday, October 19, 2009, Ms. Gates and a GDA investigator drove to Mr. Wagoner’s residence. Marybeth Willis, a Regional Milk Specialist in FDA’s Southeast Regional Office, in Atlanta, Georgia, met Ms. Gates and her colleague at approximately 1:00 pm on October 19th, and the three then proceeded to Mr. Wagoner’s home.

“Ms. Willis accompanied the GDA officials to Mr. Wagoner’s residence to observe and collect information on behalf of FDA. After Ms. Gates, the GDA investigator, and Ms. Willis arrived at Mr. Wagoner’s residence, Mr. Wagoner voluntarily dumped the Embargoed Milk on the ground…At no time did Ms. Willis, or anyone else from FDA, order or otherwise direct Mr. Wagoner to destroy the Embargoed Milk or take any other action.

“While at Mr. Wagoner’s residence Ms. Willis answered questions that were directed to her by those congregated on Mr. Wagoner’s property. If asked about the requirements of federal law with respect to raw milk, Ms. Willis would have responded that federal regulations prohibit the delivery of raw milk into interstate commerce. Ms. Willis did not, however, issue any order or direction to anyone on this or any other basis.”

The FDA account suggests that Wagoner was cooperative, since he “did not challenge the embargo in court, as was his right under Georgia law.”

The account concludes, “The embargo described above was carried out entirely by GDA under the authority of Georgia law.FDA played no role in the embargo of the Embargoed Milk and/or the discussions with Mr. Wagoner leading up to his decision to voluntarily destroy the Embargoed Milk.”

The FTCLDF takes issue with the FDA’s account in several respects, beginning with the circumstances of the discovery of the milk and the seizure: “What actually happened was GDA inspectors entered Mr. Wagoner’s private truck without requesting permission and began opening closed coolers located within, again without Mr. Wagoner’s permission. This happened while Mr. Wagoner was helping growers unload products that did not require refrigeration elsewhere in the building.”

It also challenges the GDA’s assertion that the milk was embargoed because of Georgia law. “To the contrary, Mr. Wagoner did not sell any raw milk in Georgia and the GDA inspectors told him that the FDA ban on interstate commerce was the reason for the embargo.”

While the FTCLDF admits the FDA didn’t have any contact with Wagoner during the weekend between the embargo and pour-out, it challenges the FDA’s assertion that its agent didn’t mention the ban on interstate sales of raw milk. “Ms. Willis was asked about the requirements of federal law and her response was that the raw milk must be destroyed. Ms. Willis also acquiesced in the GDA inspector’s comment that changing the law required congressional action.”

A few lessons learned from all this:
* Without video of the pour-out, which identified the FDA agent, FTCLDF would have had difficulty challenging the FDA’s original assertion that FDA wasn’t involved in the episode.
* The importance of demanding a search warrant and otherwise challenging the state’s action; Wagoner allowed his truck and coolers to be searched without a warrant, and then didn’t take court action challenging the pour-out orders.
* The GDA’s first instinct when presented with a case involving raw milk was to call the FDA. You can be sure that is the first instinct of other state regulators around the country as well.

It’s clear that in many of these actions, the FDA is calling the shots with state authorities–they contact the FDA to clear their actions or get orders for different ones. It’s up to farmers and consumers to not simply roll over.