bigstockphoto_Red_Fox_In_Winter_Coat_2460742.jpgIt’s looking ever more likely that SB 201 will make its way through the California legislature and be signed by the governor—probably within the next month or two.

I know I should be exulting, along with Mark McAfee and California’s raw milk drinkers. On the level that it prevents a collapse of Organic Pastures Dairy Co. and Claravale Farm, and keeps the milk flowing, I am relieved.

But there’s a part of me that’s uncomfortable about what is happening in California. I haven’t been able to fully articulate my discomfort, aside from the fact that I have known the legislative effort reflects more expediency than anything else. It’s trading an impossible set of standards for different guidelines which must be better because they’re not impossible.

My discomfort clarified itself after I read carefully the latest version of SB 201, and then read Dave Milano’s comment about the underlying weakness of the medical community’s reliance on research, following my previous post.

When you read through SB 201, you realize that the California Department of Food and Agriculture retains a huge amount of discretionary authority over raw milk production going forward. This wide latitude may help explain its low-profile role in the debate thus far.

Essentially, if the CDFA doesn’t approve of a HACCP plan, it can shut a dairy down. One of the reasons it can use in shutting a farm is quite revealing.

“The department, in consultation with the State Department of Public Health, may suspend or revoke its approval of a Hazard Analysis Critical Control Point {HACCP} plan without prior notice if the department finds…the plan poses a public health risk due to changes in scientific knowledge or the hazards present.”

I don’t think there’s a lot of disagreement that the CDFA would much prefer that raw milk not be available in California. Given that reality, you don’t have to be a creative genius to come up with any number of scenarios an unfriendly CDFA could concoct to argue that “scientific knowledge” had changed to enough of an extent that all the existing HACCP plans were no longer adequate.

Supposing some new “research” comes out that suggests raw milk contains larger volumes of pathogens than previous research. Or there’s an outbreak somewhere else in the country that is blamed on raw milk? As Dave Milano puts it, “Look into the microscope, see a microbe, note that an individual or group became ill after contacting that microbe, kill the microbe. Case closed, fee collected, go home. ”

Yes, I know there is a well defined hearing process included within SB 201. But we all know how skilled bureaucracies are at exploiting such processes to delay and harass over long periods of time.

I don’t want to be a stick-in-the-mud here, and rain on everyone’s parade. I appreciate that there isn’t much choice in this situation. The germ-a-phobes need to be satisfied. I just have a hard time imagining life post-SB-201 going smoothly when the fox is guarding the chicken coop. The price for expediency can be very high.