American battleships burn during Japanese sneak attack on Pear Harbor Dec. 7, 1941.As HR 2749 moves through Congress, there is a growing sense of unease among raw milk advocates that the new legislation, being driven by growing panic over foodborne illness, could be used to ban raw milk. Once enacted, all the pieces would be in place for what I would term a sneak attack to rid the U.S. of raw milk, once and for all. Consider:

— The authority. HR 2749 provides the FDA with amazing authoritarian powers, which have been well discussed around the Internet. There’s a less well considered section of the legislation entitled “Performance Standards,” under which the Secretary of Health and Human Services is authorized at least every two years “to identify the most significant food-borne contaminants and the most significant resulting hazards. The Secretary shall issue…science-based performance standards (which may include action levels) applicable to foods or food classes, as appropriate to minimize to an acceptable level, prevent, or eliminate the occurrence of such hazards.” Pasteurization would certainly seem to be a candidate for a “science-based performance standard” that would counter the raw milk “hazard.” (Another candidate: irradiation of vegetables and meats, but that’s a story for another time…and don’t want to give them too many ideas.) The fact that data from the U.S. Centers for Disease Control shows raw milk causing an average of 50 to 100 illnesses annually will be an easily ignored detail.

— The will. The FDA has shown itself to be rabidly anti-raw-milk. It isn’t a huge stretch to imagine Dairy Czar John Sheehan, head of its Plant and Dairy Division, declaring raw milk as one of “the most significant food-borne contaminants and…resulting harards.”

— The track record. Over the last three years, whenever a major state has cracked down on raw milk producers—New York, Pennsylvania, California, Michigan, Ohio—the FDA has actively involved itself, encouraging the local authorities to be super aggressive. FDA agents have gone along on raids of raw dairy producers in Ohio and Pennsylvania. They helped Michigan authorities investigate Richard Hebron in the state’s sting operation. The FDA inspired two suits against Mark McAfee and Organic Pastures Dairy Co. in California.

— A record of failure. Despite its aggressive tactics, the FDA is losing its battle as ever growing numbers of Americans flock to raw milk, and many dairies can’t keep up with demand. When government enforcers encounter failure, they often become desperate, seeking surprise knockout punch enforcement actions. Required pasteurization of all milk would fill that bill.

The Farm-to-Consumer Legal Defense Fund is increasingly worried that a ban of intrastate raw milk shipments could soon be in the offing if HR 2749 makes it through Congress and is signed into law, its director, Pete Kennedy, tells me.  And given that the FDA doesn’t recognize the legality of herdshares, seeing them as a way to skirt state laws designed to prohibit raw milk, they could be swept up in the pasteurization requirement.

Because of the hysteria over food-borne illness—and there really is hysteria—the legislation appears on a fast track to move through Congress. And mind you, I haven’t even discussed the broad authorization HR 2749 gives the FDA to quarantine entire areas of the country, and to introduce traceability of all food. (implementation of the National Animal Identification System)

The only problem with this scenario, from the FDA’s viewpoint, is that the agency, via required pasteurization, might at long last touch a serious enough nerve as to finally prompt serious outrage from consumers. Then it might have real problems on its hands.

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There’s a seductive video on YouTube of what may be the nation’s largest dairy farm, with 25,000 cows. The video suggests that the friendly factory farm represents the future of agriculture in the U.S.—highly sanitized, humane, and green. Unfortunately, there’s a lot left unsaid (about cow nutrition, hormones, antibiotics, etc.). See what you think.

Related, there is mention in today’s lead New York Times story about antitrust concerns in a number of industries, that the dairy industry is one with problems. Just because prices paid dairy farmers are fixed by a few large processors—that’s an antitrust problem?