As long as we’re on the subject of natural feeding, you’d think something as simple as “pasture fed” would be easy to define, and pretty straightforward to carry out.
But when everything related to food and agriculture needs to be sized, adjusted, and regulated to accommodate an industrial system, well, things get complicated, much like adding formula into the infant-feeding mix.
I’ve just been learning over the last few weeks about the ongoing controversy about U.S. Department of Agriculture standards defining what grass-fed means—something that’s been going on since 2005, and came to a head late last year, when the agency issued standards. It’s akin to the controversy over defining “organic.”
I can’t pretend to be an expert on these matters, because they get very involved (there were 19,000 responses to the USDA’s development of grass-fed standards, but the pattern seems to be that the standards not only get watered down, but that qualifying for an official stamp of “organic” or “grass fed” becomes expensive because of all the regulatory record-keeping, paperwork, and audits required.
There’s now even an association, The American Grassfed Association, which is fighting the USDA’s standards, arguing they allow feedlots to feed animals forage, while also giving antibiotics and growth hormones…and label them “grass fed.”
All this becomes important, of course, because it’s gradually becoming accepted that, surprise, milk and beef from grass-fed animals is healthier. And once that claim can be made, then there are “business” considerations that enter into the whole equation.
So it’s not a huge surprise to learn that there’s research to develop genetically modified pasture. The business/marketing wrinkle is that it’s supposed to reduce the methane cattle put out, and thus be environmentally attractive.
Expect to see many more such “solutions” to food and energy “problems”—solutions that wind up creating ever-bigger problems. (Thanks to Lisa Imerman, a Michigan lawyer, for the info on the GM pasture.)
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The California Assembly’s Appropriations Committee unanimously passed SB 201, which substitutes HACCP (Hazard Analysis and Critical Control Point) plans and pathogen testing for the current coliform testing of raw milk. Mark McAfee, owner of Organic Pastures Dairy Co., reports there was only one opponent to the legislation–a representative of the state’s Finance Department, who testified that enforcement of SB 201 would cost the state $450,000 annually. The argument obviously didn’t fly–the state’s two raw milk dairies are paying to develop the HACCP plans–but it indicates that opposition to the new approach lurks within the state’s bureaucracy.
The legislation’s next step is a vote before the full Assembly in a few weeks, followed by a vote in the California Senate, and a signature by the governor–all likely to be completed sometime in September.
Mark also reports that California’s Department of Food and Agriculture resumed testing for coliforms the day after the temporary restraining order expired in mid-June, It also put into play four tests done during the time the TRO was in effect, two of which OP had failed. While OP’s milk passed the June tests, Mark notes the state’s results differed slightly from those he had done privately by a state-certified lab.
Finally, Mark says he’s had no luck getting officials of the CDFA to sit down and discuss with him implementation of the HACCP requirement due to pass shortly. "I want to get their input on how we should proceed. But they’ve been mute."
A cow or other ruminant will gather up the sprayed materials and concentrate them, most likely in the animal’s fatty tissue and butterfat. The sprayed pesticide (its legal definition) may even disrupt the microbial ecology of the ruminant’s gut. It is lethal to some forms of aquatic life.
When I questioned California officials about this they told me that sprayed organic pasture would continued to have the government’s seal of Organic approval and I should not worry. But my customers don’t see it that way. They don’t want to consume the spray collected in pasture no matter what the government says. That spells putting our ranch out of business.
The CDFA and the USDA originally planned to spray urban areas but the uproar, lawsuits, and outright threats against the airplanes made them revise plans to spray only agricultural and remote areas.
Following the money trail through the corporations and officials reminds one of Raymond Chandler’s "Chinatown." It’s going to be a battle.
We weren’t asked and did not have a choice. We live within the city limits.
I thought the HACCP was a control program for sanitation for the cows and environment?
HACCP for large operations, and common sense cleanliness and experience for small farms are the best ways to do it correctly, step by step, so that you don’t need a fix-it-all "kill" step of final inspection (i.e., pasteurization). As I understand current thinking of the FDA’s top dog, built-in quality is the preferred way of doing things, which is probably simply consistent with the opinion given by Dr. Harris and Ted Beals, MD and others when they endorsed HACCP in the Senate hearings in California in April. The careful production of raw milk and raw milk products ought to be a poster-child example for the FDA’s message about improving food safety by emphasizing built-in quality. I’m not holding my breath, but stranger things have happened.
HAZARD ANALYSIS AND CRITICAL CONTROL POINT PRINCIPLES AND APPLICATION GUIDELINES
http://www.cfsan.fda.gov/~comm/nacmcfp.html
"More than one control measure may be required for a specific hazard. On the other hand, more than one hazard may be addressed by a specific control measure (e.g. pasteurization of milk)."
"In the application of HACCP, the use of microbiological testing is seldom an effective means of monitoring CCPs because of the time required to obtain results."
HACCP is fairly generic concept:
"Hazard Analysis and Critical Control Points (HACCP) is a systematic preventive approach to food safety and pharmaceutical safety that addresses physical, chemical, and biological hazards as a means of prevention rather than finished product inspection. HACCP is used in the food industry to identify potential food safety hazards, so that key actions, known as Critical Control Points (CCP’s) can be taken to reduce or eliminate the risk of the hazards being realized."
(http://en.wikipedia.org/wiki/Hazard_Analysis_and_Critical_Control_Points)
Any HACCP plan for a facility producing pasteurized milk would of course include CCPs related to the pasteurization process. A HACCP plan for a raw milk dairy would not.
It seems to me that a key concept in this whole discussion is that ‘raw milk’ is a different product than ‘pasteurized milk.’ Different products, different regulations.
What a concept!
In terms of the pathogen testing, I will be interested to see what tests they actually use. I don’t think there are any tests that will allow them to use a test-and-hold approach. As a result, the pathogen tests will confirm after the fact whether the HACCP is actually working and then the HACCP can be revised or updated if it’s not.
i doubt god did not have any kind of haccp in mind when he created cows.
If the environment (the pastures along with the milking areas/equipment) are contaminated, then the cows would have the potential for contamination.
I would think it’d be like doing surgery in an unsterile area. Same principal.
Although someone said HACCP is generic, it really isn’t in practice for food safety – there are volumes of details and extensive trainings mostly relating to processing/retail practices. On-farm HACCP would be breaking new ground, especially for a product like milk that has an established "kill step" (pasteurization – no I’m not going back to the silver bullet, don’t shoot the messenger – just relaying how this might be viewed on a national level by HACCP experts).
How can a "sterile" area for surgery be compared to a cattle pasture with manure? No matter how many times a few papers describing increased E. coli O157:H7 in grain fed cattle are quoted and over-simplified, they do not change the fact that E. coli O157:H7, Campylobacter, and Salmonella are also repeatedly isolated from cattle on pasture (no grain) including grass fed cattle from certified raw milk dairies. It seems unlikely that national HACCP experts would view eliminating fecal shedding and environmental contamination at the pasture level as a feasible critical control point. If there are others reading with more expertise in HACCP, please chime in. I’m curious about all the views.
One other point – I regularly buy and enjoy grass fed beef products and support local, sustainable agriculture. The discussion on the definition of grass fed is interesting – what about areas that don’t have year-around grass (or require water to irrigate in drought ridden locations)? Does grass fed include hay? I tend to agree with David’s comment "but the pattern seems to be that the standards not only get watered down, but that qualifying for an official stamp of organic or grass fed becomes expensive…" and would add political since it can be used as a marketing tool…
Would it be possible to get a copy of the HACCP plan for your raw dairy?
The potential for contamination is greater at the factory dairies than it is at the dairies that correctly pasture feed. When I say "correctly" I am envisioning so much land per cow- depending on the grass coverage, (any natural organic grasses fed to the cows), etc.
The factory dairies have the cows standing and laying in their own excretions consistantly. How could that be healthy for the cows? If the cows aren’t healthy, then I’ve no doubt that antibiotics and other chemicals are fed/injected into them on a regular basis.
If the environment isn’t taken care of, then the end product would require adulteration for human consumption. Yet that adulteration remains unhealthy for consumption.
When I referred to the "principle" I was referring to the basic way in which something works. You wouldn’t do surgery in an unsterile area and raising cows in an un-natural environment is no different. Both outcomes require actions that would most likely be unnecessary if the environment were properly cared for.
Cows in a natural environment do not stand and live on their poop 24/7,and they naturally eat grasses.
I didn’t say the environment need to be a critical control point. I believe the whole picture should be taken into consideration and the environment is a big part of that.
If the factory dairies had to adhere to the same standards as the raw dairies, they’d never pass.
Interesting how you use language to pump up your point of view and discredit an opposing one: you compare a "a few" papers on e. Coli in grain-fed cattle being "oversimplified," but "repeated" incidents of contamination in grass-fed cattle.
I would be interested in you providing source links for these "repeated" events.
It seems to me that one of the premises of a well-run raw dairy is that there really is no way to eliminate pathogens entirely, but the best way to keep them in check is to have a healthy environment so the good bacteria can thrive and overwhelm the bad ones.
As far as e. Coli O157:H7 is concerned, it my understanding that this strain of e. Coli as flourished in the guts of grain-fed cattle due mostly to the change in the pH in the stomachs that this diet causes. A grass-fed stomach is a more hostile environment for this pathogen than a grain-fed one is.
"Interesting how you use language to pump up your point of view."
Sorry if it seemed that I was trying to be biased with language. The point was not to be adversarial, but to share information and possible conflicts that could arise while working on HACCP plans. I’ve posted the links relating to E. coli O157 and grass/grain fed cattle here previously.
Are you or others aware of any studies showing that the grass fed rumen/gut environment is hostile for Campylobacter or Salmonella, which historically have caused more raw milk-related outbreaks than E. coli or Listeria? This question relates to the pasture issue, not hygiene while processing and bottling.
http://www.luciesfarm.com/artman/publish/article_85.php
I don’t recall anyone saying grass fed is a silver bullet, only that it is healthier for the cow and the consumer.
There have been studies that have shown grass fed was healthier for the cow and the consumer.
http://www.ag.unr.edu/ab/Extension/Cattleman/Cattleman2000/11.htm
http://aem.asm.org/cgi/content/full/71/12/7974
http://en.wikipedia.org/wiki/Grass_fed_beef