Wisconsin dairy farmer Scott Trautman, who is seeking to developing a set of safety and quality standards for raw milk.Why should we care about raw milk producers abiding by some set of quality and safety standards?

A number of people raised that question when I reported a few weeks ago that an ad hoc group of raw milk producers and consumers, headed by Tim Wightman of the Farm-to-Consumer Foundation, were involved in drafting quality and safety standards. The worry that seemed most prominent in the many comments was that any independent group or organization involved in setting and enforcing standards could very well be co-opted by government agencies.

I think the events out of California’s Humboldt County over the last few days can safely put those fears to rest. No government agency that I can think of would want to be associated with raw milk standards, now that the U.S. Food and Drug Administration, which funds so many state public health and agriculture agencies, has sought to put the kabosh on standards.

In the same document I quoted from in my previous post about the FDA’s weird effort to deny illnesses from pasteurized milk, the agency repeated its tired old theme that raw milk can never be produced safely: “FDA does not believe that HACCP [Hazard Analysis and Critical Control Points] can ensure raw milk safety. The sanitary procedures described in a food safety plan under HACCP might help to reduce the probability of raw milk contamination but they will not ensure that raw milk is pathogen-free.”

Of course, no HACCP plan for any food can “ensure that (it) is pathogen-free.” Anyway, as its prime (and only) example, the FDA pointed to Organic Pastures Dairy Co., which in the last four years has instituted a written safety plan (though not officially a HACCP plan). “HACCP ensures product safety through process control and not by finished product testing. HACCP has been considered possible for chemical and physical hazard controls in farm settings. However, HACCP is not effective or even possible in farm settings for biological hazards, including pathogens…HACCP simply does not work for pathogen control for raw milk production on the farm…”

On what basis does the FDA draw such a broad-ranging conclusion? The only possible evidence it cites is this: “Organic Pastures is an example of a raw milk producer with a HACCP plan whose milk has been found to contain pathogens.” The FDA then refers to examples of illnesses attributed to Organic Pastures in 2006 and to discovery of listeria in its cream in 2007, even though Organic Pastures didn’t have its current written safety plan in place then.

As I said, the FDA has no interest in raw milk safety standards or plans, since in its twisted logic, standards can’t possibly work.

So back to my original question. Why should we want raw milk safety and quality standards? For two main reasons:

1. To ensure consumers have access to safe high-quality milk, thus reducing the chances of illnesses;
2. To protect producers from legal and regulatory problems.

By inspiring community confidence in producers’ commitment to quality and safety, adherence to realistic standards reduce the legitimacy of arguments such as the one being made by the FDA. One practical way standards can become important is in the event of government-inspired legal cases against raw dairies. Safety and quality standards, in the absence of illness, help make the case that not only do producers care, but safe raw milk is a reality. Otherwise, raw dairies won’t stand a chance in court cases, such as that involving Michael Hartmann, against government agencies waving their “data” about illnesses and disease in front of uneducated judges.

One other thing: there’s nothing that says we need a single set of standards for everyone. What’s wrong with two, three, or more sets of standards? I raise this because Scott Trautman, a Wisconsin dairyman who has advocated voluntary standards for raw dairies, is having a gathering at his farm this coming Thursday to discuss a set of standards he’s been working on.

Among those due to be present: Michael Schmidt, the Canadian dairy farmer, who will be assessing standards in place at the Trautman dairy. “I’m setting myself to be in the lead,” he told me. “Not necessarily a leader…We’re going to talk about what we do at my farm.” He has an account on his blog of how he came to his current viewpoint, along with an invitation to others who might be interested in participating in the discussion on Thursday.

The relationship of all this to Jewish laws on kosher food is intriguing. While essentially a set of biblical dietary restrictions, in practice the laws on kosher, or “kashrut,” are a set of standards that Jews follow to varying degrees. In my home, the only restriction we observed was on eating pork products. I had relatives, though, who were so strictly observant about the various restrictions that they would bring their own food when eating in my family’s home. One key point is that the standards are voluntary. No government enforces them, even in Israel, a Jewish state. (Here is some excellent background information on the laws.)

Jews who strictly observe the laws on kashrut do so for any number of reasons, including health and safety; for example, they avoid pork because pigs have long been seen as unclean animals that can carry disease. Even though pork is no longer an especially dangerous source of illness, these Jews still worry because at one time in history, pork was dangerous. Sound familiar?

I don’t want to take the comparison too far, primarily because there is no religious component associated with establishing voluntary standards for raw milk. Indeed, the opportunity is that the standards on raw milk are being established now. There’s no need to rely on the Bible. ?