We are a family from Ukraine and New Zealand residents. We have been drinking raw milk for all our lives as one of the most healthy and tasty products.

We'd like to describe a situation in Ukraine about raw milk and our own experience.

In Ukraine raw milk is absolutely legal product and can be sold as well as bought from local markets 6 days per week. Of course, there are laboratories at the markets for testing milk and other products, so buyers can be sure that these products are safe to consume. Also farmers have to provide papers from vets that their cows are well. At the markets there are specially equipped places for selling raw milk and a special sanitary unit supervises these places to be clean and hygienically safe.

Our people prefer buying raw milk, especially for children, and mums have the opportunity to buy fresh milk, cottage cheese, cream, sour cream for their children. Despite the fact that our children became weaker after Chernobyl, we don't have such a big amount of food allergies as in New Zealand, USA, Canada and other developed countries.

During the summer some mums prefer to spend holidays in villages enjoying fresh air and drinking raw milk. And it is obvious difference between these children and those ones who spend summer in the city consuming products from supermarkets. We have a friend who works at the children's hospital as an immunologist and told us this fact in private chat.

When we came to NZ we were disappointed that we can't buy all essential products just from farmers at the markets. In NZ the nature is so perfect and clean (thanks to MAF who does the best for protecting it from foreign contaminants) so it's just a pleasure to drink and eat fresh food.

Than we were so happy to meet the real organic farmers. They invited us to visit their farm so we got acquainted with cows, saw conditions they live in, paddocks, equipment, the way how the farmers treat the cows. The farm does have farm days and we can go whenever we want. Primarily we are interested in whole nutritious food for our family. We have had the risks of drinking raw milk explained to us but we also know that they have their milk and cows regularly tested.

Now we have our milk delivered to us and it's so convenient because we are not able to go to the farm every week.

I am a city dweller living in Auckland. As a qualified naturopath-nutritionist and medical herbalist that has studied Food Science at the University of Otago, and in more recent years, graduated with a Bachelor of Health Science, I consider myself very well qualified to offer my thoughts on MAF’s proposal regarding raw milk. Incidentally I passed the Microbiology and Immunology degree paper with credit. I am also a mother and I work part-time privately as a health practitioner as well as in a retail store as an in-store natural health consultant.
I do believe that it is safe to give my family raw milk and to make raw milk products in our home. I would consider making raw cheese but it is time consuming and I live a very busy life so instead I currently purchase raw cheeses imported from Italy and France for our family as well as some organic albeit pasteurised cheese.

I was brought up on a dairy farm in the southern Hawke’s Bay for five years of my formative years where drinking raw milk was normal. My mother may have occasionally had to pick out a blade of grass or two but none of us in our household were ever sick from consuming raw milk nor was anybody whom I attended school with locally. In our district raw milk wasn’t even considered an issue, it was just what we all did and it is what my mother had done for at least the first 25 years of her life, having been brought up in the next valley where everyone had at least a house cow for milking purposes, supplying each home. She then moved to a city and raw milk might well have continued to be part of her everyday normal life during the 1940’s – I don’t know as we never discussed that and she’s now deceased.
Reasons why I advocate the use of raw milk...

The initial reason, since living in Auckland, why I chose to seek out a supply of raw milk was that I knew from my many years of studies that pasteurisation damages raw milk. It denatures proteins1, and destroys enzymes1, such as lactase and lipase naturally present in the raw milk and which help with the digestion of lactose and fats. Pasteurisation damages if not almost completely destroys any vitamin C2 and some members of the vitamin B Complex2 present, and damages minerals making them less soluble rendering the end product difficult to digest and a stress to the body.

Internationally, studies demonstrate that pasteurised milk, and other dairy products made from pasteurised, milk often pose a very debilitating health risk to many humans3.4.5 who consume such products. That’s not to mention peoples pets6 or livestock who might be fed cooked milk6 or milk powder products too.

There is evidence that an increasing amount of people are “dairy intolerant” 3.4.5 – that is, having reactions, to lactose or casein or other milk constituents. I would like to mention that our daughter was one of those people who is lactose intolerant on pasteurised dairy but once switched to raw milk, and raw milk products that I make at home, she has thrived.
Many people are now consuming the very unhealthy soy milk alternatives which contribute to deterioration of their health, contributing to such conditions as thyroid disturbances, hormonal issues, digestive problems, malnutrition etc. Other milk substitutes such as watery rice milk is often fortified with additives including vitamins, such as toxic to humans Vitamin D2, is abhorrent and a disgrace when we have some of the best quality raw milk in the world.
It is ridiculous that here we are living in a country that is blessed to be able to graze animals year round on green pastures producing some of the best quality cow’s milk in the world, only for the majority of it to be altered and processed into products not optimally fit for human consumption here, or abroad.

Raw milk is readily available in many overseas countries and is available to buy from supermarkets7 and health stores and even vending machines 8.9.

When living on the farm we witnessed lambs being fed powdered cow’s milk, a common practice then and probably still now, and often they would die from the scours – or at least that was the word I remember being used for diarrhoea and the resulting malnutrition. Imagine what formula does for humans – that’s another issue.

I understand that organic dairy farmers leave their calves to feed from their mother to at least gain access to the all important colostrum and then once removed from their mothers are continued to be fed raw milk. This no doubt gives them the best start in life.

Between 1932 and 1942, Francis M. Pottenger, Jr., M.D., conducted what is now known as his classic ten-year, multi-generation nutrition study on cats and which is recorded in a concise book called Pottenger’s Cats: A study in Nutrition6. The essence of the study demonstrates the dangers of trying to survive on an entirely cooked diet when in fact we and the animal kingdom are designed to consume foods raw and still in their natural state – milk is one of these foods.

Obviously there aren’t many humans who consume an only raw diet but those who understand the biochemical constituents of foods prepare them, if cooked, in such a way as to preserve the foods integrity and maximise the nutritional content. As milk is primarily mammal’s first food it is, as you know, in a raw state which maintains its integrity and nutrient profile. It has been found that when a baby consumes mother’s colostrum10.11.12 and mother’s milk10.11.12 it’s gut flora is greatly different and better in composition of beneficial microflora to that of a baby who is raised on formula11 – there is nothing that can replicate the delicate nature of raw mother’s milk and its beneficial microflora and the rest of its nutrient profile – as mentioned above cooking, or pasteurising milk for the purpose of human consumption, damages the milk and destroys naturally present probiotics, that is beneficial bacteria, rendering it often a nutritionally lessened damaged food for whoever consumes it.
Many formula companies are now adding probiotics to their formulae in an effort to try to replicate the original product, raw milk. Formula and milk powders aren’t intended to be discussed here but there are valid reasons why it is illegal to market infant formula on television and why our medical fraternity generally promote breast feeding instead.

Speaking of micro-organisms, which is part of MAF’s concern, it’s therefore appropriate to comment about food borne illnesses from pathogens that might be present in milk either through contamination or otherwise.

To be fair to this discussion, I do want to mention, that in the late 1960’s near to where I was living there was a dairy farm that had had its herd put down due to an outbreak of Brucellosis. However, I must add that the murmur amongst the surrounding districts farmers was that they were not surprised as they could see quite easily even from a distance that the farm was over crowded and “dirty”. It was considered shameful in the manner in which the farm had been run so as I said people were not surprised but very disappointed that something like this had happened in their farming region.

Also, since then there have been advances in technology, for example, the use of stainless steel vats and enclosed lines lessening the chance of contamination.

This brings me to agreeing with MAF’s proposal to remove the need for a Risk Management Program – I support this as it is very costly to producers - however instead I would support something along the lines of a cheaper peer-reviewed Code of Practice being instigated. I’m sure MAF, together in consultation with Federated Farmers and dairy farmers could jointly create such a code that would ensure safe farming, safe animal health and safe food hygiene practices.

would contribute to the closure of many producers because to only be able to sell 120 litres per day wouldn’t make it economically viable so this upper limit is impractical, and unnecessary, especially if a COP was applied.

As a person who has worked in the food and hospitality industry I strongly endorse some kind of safe food harvesting and handling certification program for raw milk producers and their staff being compulsory similar in other food production industries.

However, speaking of raw milk farm practices, the raw milk sellers “at the farm gate”, that I am aware of realise the delicacy of their product and treat the animals, farm and the milk accordingly. They obviously know that raw milk is perishable, as does any dairy farmer and thus take utmost care during the harvesting, in the post-harvest need to refrigerate it at the appropriate temperatures, and the handling of it very carefully so as to not contaminate it. I have not heard of anyone being sick from consuming raw milk in New Zealand in the time that we have been consuming it during my adult years. As mentioned as a family we have being consuming it for the past five years.

I understand that by limiting quantities of raw milk, to the urban community, it is intended to lessen the volume related chances of a food borne illness being transmitted. This is contradictory, when one casts one’s mind back to recalling a tragic case in New Zealand, Nelson I believe, a few years ago, where a pregnant woman lost her twins, who were still born, due to her contracting, I think, Listeria whilst still pregnant from poorly handled raw mussels. That of course was a terrible case and I recall that the company concerned was charged with some kind of civil neglect yet my point is that today we can still buy raw mussels from most supermarkets throughout the country with NO restriction on quantities per day, per customer or having to drive out to the mussel farm to pick them up!

So to impose an upper limit and to have to drive and pick up for only one family at a time is an unreasonable proposal. It would be far more fuel efficient if the trips were shared.
In fact, with regards to the New Zealand Food Safety Authority relaxing the laws regarding the importation of raw milk cheeses in 2007, the then principal public health advisor commented about the importation of the French raw milk product, Roquefort cheese: “NZFSA principal advisor of public health Donald Campbell said while the cheese was no more risky than a number of other foods, such as raw shellfish, it should be avoided by expectant mothers and the elderly.”15

So he actually says that it is no more risky than raw shellfish. I haven’t heard of any mother losing twin babies due to consuming Roquefort cheese or any raw milk product in New Zealand yet shell fish have and they are still allowed to be sold.

A thought that often comes to mind, if the dairy industry was interested in promoting more dairy consumption locally then they would be wise to consider raw milk and raw milk products, as indicated back in a TV3 2008 article16. My experience shows that drinking raw milk, and making raw milk products like kefir and raw milk cheeses, is a growth industry as indicated by an article on TV3’s Campbell Live17 on Thursday, 14th April – if you scroll along to 10 minutes and 10 seconds into the program you can view the coverage.

MAF and NZFSA I’m sure are aware of these articles and I would welcome MAF’s and NZFSA’s input, together with raw milk producers, to ensure that this would be the future for raw milk production in New Zealand.

As mentioned it concerns me that people are resorting to consuming cow’s milk alternatives such as the imported, costly non-nourishing ultra heat treated (UHT) rice and soy milks, and other UHT milks made from oats, almonds and even hazelnuts, when our New Zealand farmers produce some of the best cow’s milk in the world, that would be more fit for more people’s consumption if there was a raw option.

To have the opportunity, like many people in Europe and many states of the United States of America do, that is to be able to easily purchase raw milk from supermarkets, would be ideal – the technology obviously already exists and to be able to access raw milk from vending machines8.9, as already mentioned as in Italy and other European countries, would be tremendous progress for our dairy industry and the local population.

Imagine what the tourists would think – they would love it. I work part-time in a retail setting as a natural health consultant and often come across Europeans looking for real raw milk. They are often baffled as to why when leaving store bought milk out on the bench to “clabber” it goes rotten; they are also confused about why they can’t make kefir successfully from store bought milk like they used to back in their homelands. So I explain that our milk is cooked, and that the nutrients necessary to make their products, which are often staples of their diets, are destroyed by the compulsory pasteurisation of the milk sold in retail outlets.
As a consumer, I also understand that it is a perishable product, more so than its dead relative the pasteurised products incorrectly called fresh milk, so I also take particular care of it once I have picked it up, as I do when picking up raw fish or raw oysters from a fishmonger.

With regards to picking up milk – as a health practitioner I often recommend to patients to move to consuming raw milk as I believe it to be one of the most nutrient dense foods that can offer people and their family’s benefits that pasteurised milk and expensive pharmaceutical drugs can never provide. In fact people don’t have to be my patients for me to recommend the use of raw milk – it often comes up in conversation particularly when health issues are discussed in social situations.

So to be able to source raw whole milk more easily, ideally in a retail environment would be the ideal situation and something New Zealand’s dairy industry should aim for rather than limiting milk consumption.

To suggest that consumers each drive to a farm, pick up only 6 litres despite the fact that some may want to make kefir, yoghurt or even cheese in their own home, (and we know that it generally require 10 litres of milk to produce only 1 kilogram of cheese), and share it with other family members, is absurd, impractical, obviously uneconomical and a waste of peoples time and energy.

Many people, whom I recommend raw milk to, are unwell and others can often be full time workers, usually with families who are simply too busy to be expected to drive to a farm especially more than once a week, let alone once a week.

This dilemma crossed my mind when I first started getting raw milk, so I telephoned the NZ Food Safety Authority and asked a woman about accessing raw milk and possibly picking up for others. I was told over the telephone that it was alright to transport on behalf of others. The woman almost sounded surprised that I would ask such a question – her tone was “yes of course” with an almost whisper of why ever would you think that it couldn’t be done.
All the people I know who are buying raw milk from farms are intelligent, and often tertiary educated, many even with Masters degrees however we know one doesn’t have to have a Masters degree to know that milk, whether raw or pasteurised, needs to remain chilled especially during summer whilst being transported long distances such as those from a farm to home.

So to be able to develop raw milk groups at this stage seems like a sensible option – one member could pick up on behalf of others and maybe they would take turns. I personally would like to take about 10 litres per week from a farm so as I don’t have to drive to the farm twice a week – I can store it safely, keeping it well chilled for the duration of travel and storage at home.

However, this matter I believe could become a viable commercial operation by way of suitably certified refrigerated vehicles, with a suitably certified driver/operator that could bring raw milk13.14 from a farm to city dwellers just as other chilled foods are transported around the countryside. They could either drop it at retail stores if already bottled and/or deliver to people’s homes or both.

New Zealanders have over the years reduced their intake of saturated fat containing foods such as whole dairy milk, as found in A Focus on Nutrition: Key findings from the 2008/09 NZ Adult Nutrition Survey, a recent report from Associate Professor, Winsome Parnell18.19?, of the Nutrition Department at Otago University. This has been in the belief, amongst others, that by reducing the consumption of saturated fat one would become thinner. The findings of the survey, in fact, found people to be heavier now than they were before they reduced saturated fat intake.

I want to mention this because it relates to the health of the nation – for many years people in many parts of the world drank raw whole milk and maintained healthy weight and strong robust bodies18. Many cultures have been doing this for well over 1,000 years and they didn’t have the health issues that are today common place in developed countries worldwide – obesity, cardiovascular disease and cancers. When studied in the 1930’s there were people who were still eating as their ancestors had done for many generations which included consuming raw milk and raw milk products, and they were not suffering from Tuberculosis, compared to people of the same groups, who had in fact adopted the diet of “modern civilisation”, and were succumbing to such illnesses as their immunity was being undermined by refined foods of industrialised developing nations – sugar, white flour and similar nutrient devoid foods - not by consuming raw milk.

Parnell’s report covering the findings of the 2008/09 NZ Adult Nutrition Survey demonstrates that as New Zealanders have reduced their consumption of dairy products, and other saturated fat containing foods, their consumption of the very important and essential fat-soluble vitamins A, D, E and K have consequently declined. This in my opinion also reflects a correlating decline in the general health and well being of the New Zealand population and is a threat to the well being of future generations.

So to allow people easy access to healthful foods, such as raw whole milk, is a right that we as a dairy producing nation should consider normal not a criminal act.

It is my opinion and no doubt many, many thousands of people around the world that consuming raw milk has such a minimal risk that one would prefer to drink raw milk rather than perhaps cross a busy road on foot – the raw milk risk is minimal – I’m sure that there are many other sources for food borne illnesses that are commonly consumed every day – food from salad bars, delicatessens, takeaway food outlets, etc etc.

If there are any organisations that should be limited from selling their products one might want to consider starting with tobacco companies NOT well intending raw milk producers.
I thank you for the opportunity to submit my thoughts regarding the proposals for continuing raw milk sales at the farm gate.

Kind regards,
Caroline Marshall BHSc

References
1. http://www.ncbi.nlm.nih.gov/pubmed/8844253
2. http://www.ncbi.nlm.nih.gov/pubmed/3103547
3. US Census Bureau, International Data Base, 2004 (online) available at: http://www. wrongdiagnosis.com/f/food_allergies/stats.htm
4. 5. Haynes AJ. The effect of food intolerances and allergy on mood and behaviour. In: Nutrition and Mental Health: A Handbook. 2008. Pavillion Publishing (Brighton).
5. Haynes AJ. The Food Intolerance Bible. 2005. London: Harper Collins.
6. http://www.ppnf.org/index.php/about-ppnf/about-drs-price-and-pottenger/dr-pottenger
7. http://www.healthbanquet.com/raw-milk-vending-machine.html
8. http://www.prometea.it/?changelin=ENG
9. Baranovski A, Kondrashina E. Colonic dysbacteriosis and dysbiosis. Saint Petersburg Press (Russian). 2002.
10. Harmsen HJ, Wideboer-Veloo AC, Raangs GC, Wagendorp AA et al. Analysis of intestinal flora development in breast-fed and formula-fed infants by using molecular identification and detection methods. J Pediatr Gastoenterol Nutr, 2000 Jan, 30(1):61- 7.
11. Lucas A, Brooke OG, Morley R et al. Early diet of preterm infants and development of allergic or atopic disease: randomised prospective study. Brit Med J 1990;300:837- 40.
12. http://www.prometea.it/?service=latteria&cat=Mobile
13. http://www.prometea.it/default.php?service=gallery
14. http://www.3news.co.nz/Raw-milk-products-dangerous-to-health-say-NZ-Food-Safety-Authority/tabid/423/articleID/55893/Default.aspx#ixzz1fcJgpVlW
15. http://www.3news.co.nz/Food-Safety-regulator-wants-to-relax-rule-on-raw-milk-cheeses/tabid/420/articleID/66234/Default.aspx
16. http://ondemand.tv3.co.nz/Campbell-Live-Thursday-April-14-2011/tabid/59/articleID/2576/MCat/73/Default.aspx
17. http://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=10752703
18. http://www.health.govt.nz/publications/focus-nutrition-key-findings-2008-09-nz-adult-nutrition-survey
19. http://journeytoforever.org/farm_library/price/price3.html

I am writing to request that you reconsider your proposal to limit raw milk supply.

Raw milk is one of the most amazing foods. It is a whole food and contains nearly all the nutrients that a growing family need to ensure healthy development.

In these times of overly processed foods, there are few natural choices available to provide good nutrition for our children and raw milk is one of those rare, amazing foods that our bodies really need. As a responsible parent, I feel it is my duty to feed my children the best food I can source, so that they grow up healthy, strong and are less susceptible to ailments.

I appreciate that people have freedom of choice and I would not force raw milk onto anyone that didn’t want it, but by the same token, somebody that doesn’t appreciate raw milk should not limit my supply. We live in a democracy and not a nanny state.

I do not force people to stop eating or limit the supply of overly processed white sugar, white flour, soy, TVP etc, all of which have been proven to be bad for human health, people have the choice and can eat it if they want to. By the same token, I should be able to drink and eat products made from raw milk if I want to.

All the reliable research into raw milk proves it is a wonder food and as a species we actually need it. We have a good supplier and my children thrive on this milk. I do not want to have to change my children back onto overly processed, pasteurised milk, which gets rid of all the beneficial enzymes (which are then sold to us in tablet form as ‘pro- biotics’ – why take tablets when I can get these enzymes naturally?). Why can’t we just have a natural food from a natural source without interference?

By restricting the supply of raw milk, you are restricting my personal choices and presuming that I am not able to make my own decisions. I am an intelligent lady. I have done my research and my conclusion is that we need raw milk in my family’s diet. To enforce a policy that restricts that freedom is oppressive in the extreme.

Surely the health and hygiene aspects of a product which is a food for human consumption should have a comprehensive Risk Management Programme??

There is plenty of worldwide evidence and research in favour of the health benefits of raw milk. Please consider that raw drinking milk ought to be available to the people of New Zealand, especially a natural food product which is in such a clean,green,no additive state, we - our children, need that choice.

Thankyou

Regards

Debbie Betts Dip Hom

Classical Homeopath

Devonport

Deb Gully

Submission regarding availability of natural (unpasteurised) milk

As a consumer, I have been drinking natural milk for a number of years with no ill effects. I was unable to drink processed milk without ill effects.

I am a Nutritional Consultant and Chartered Natural Health Practitioner and in this role I see many clients who have severe, chronic reactions to processed milk. However the majority of them do not have the same reactions to natural milk.

As a representative of the Weston A Price Foundation, I am often asked how to source natural milk.

In all of these roles, I have associated with many people who are drink natural milk. To my knowledge, none of them have contracted any food borne illnesses from it.

Definitions of terms

Natural milk is milk as nature provides it, and as it has been traditionally consumed for thousands of years – from cows fed on pasture, not pasteurised, not homogenised, merely chilled and bottled.

Processed milk is milk that has been pasteurised, ultra heat treated and/or homogenised.

WHY natural milk should be freely available

1. International availability of natural milk

Raw milk is sold in most countries throughout the world – New Zealand, Australia, and Canada being notable exceptions. Countries where raw milk is widely sold include:

• The entire European Union (EEC) where all raw milk products are legal and considered safe for human consumption, and can be sold without any price, variety, or quantity restrictions.

• France where raw milk and raw milk cheeses are considered the standard for high quality dairy products. Many traditional French cheeses have solely been made from raw milk for hundreds of years.

• Germany where raw milk is sold widely in all health food stores, large supermarkets, and delicatessen sections of department stores. Raw milk is legally sold throughout the country.

• Italy where raw milk is sold from vending machines, as well as from shops and farms.

• The United Kingdom where raw milk is legal in England, Wales, and Northern Ireland. About 200 producers sell raw, or "green top" milk direct to consumers, either at the farm, at a Farmers' markets, or through a delivery service. The Queen drinks raw milk from her own herd, and has it delivered to other members of the royal family.

• Asia where milk is usually unpasteurised. Laws prohibiting raw milk are nonexistent or rarely enforced.

• Russia where raw milk is sold from vending machines in the street, and delivered to schools by truck.

• Slovenia where raw milk is available from Mlekomats (Raw Milk Vending Machines) throughout the country. Homogenized milk has been widely discussed in the Slovenian media so most people there are aware of its artery-damaging effects.

• The USA where raw milk is legal in 31 out of 50 states, and if states which permit the sale of raw milk for animal consumption are included, the total is 35 out of 50 states. (Cow shares or raw milk sold for “animal consumption” enable sales in many states where retail for human consumption is prohibited)

2. The health benefits of natural milk

For thousands of years, humans have domesticated and milked cows, goats and sheep. This concentrated source of protein and calories often enabled a family or community to survive when they might not have been able to source enough high quality food.

Until approximately one hundred years ago (depending on the country), this milk was natural, apart from the traditional forms of fermentation that were used to make cheese or various yoghurts.

These milk products were valuable sources of protein, essential fats, vitamins and minerals. The majority of people were able to digest and utilise the nutrients in these dairy products, as the milk contained a variety of beneficial enzymes and flora. One of these is the enzyme lactase which helps digest lactose.

In the early parts of last century, many reputable doctors and clinics used natural milk to cure chronic illnesses. Many people are now finding that when they switch from processed to natural milk, long standing illnesses such as allergies and digestion problems completely disappear.

3. The health dangers of processed milk

When milk is pasteurised, a number of undesirable things happen to the milk, including:

• The lactase is destroyed, which means that unless a person is producing enough of their own lactase, they cannot digest the milk.
• Other enzymes are destroyed. This includes phosphatase which assists with the assimilation of calcium, meaning that we are unable to fully utilise the calcium in the milk
• Histamines are produced, which can contribute to asthma
• The beneficial flora are destroyed, the effects of which are discussed below

4. Risks of natural milk compared to processed milk

This submission strongly disagrees with the statement made in section 3.2 that the risks associated with natural milk are too great to be managed, and instead contends that the risks are actually extremely low, and easily managed.

In clean milk from healthy cows, the beneficial flora referred to in items 1 and 2 have a role to play in keeping milk safe. When pathogens are introduced to natural milk, they will neutralise the pathogens over a period of time. Mark McAfee of Organic Pastures in California performed a laboratory study where he introduced salmonella, e-coli and listeria to three batches of his grass fed natural milk. He measured the levels of the pathogens and found they all died.

This is why the reports of food borne illness from natural milk are extremely low, much lower than those from other foods. Even those that are reported are seldom confirmed to be from the milk.

If cows are kept in unsuitable, unsanitary conditions, the milk won’t be wholesome and can be dangerous. But if a suitable set of animal care and safe handling guidelines are incorporated in any new law, this will reduce a small risk to one that is negligible.

On the other hand, when milk is contaminated subsequent to being pasteurised, there is nothing left in the milk that can fight the pathogens, and it WILL make people sick.

5. Freedom of choice

Many families are choosing natural milk over processed milk as they can see the improved health that results. It is a basic human right to be able to choose what we want to eat. There are many foods and recreational substances that are freely available when it is widely known and documented what there dangers are. This includes food high in sugars, foods high in additives, alcohol and cigarettes.

But there are other foods that are basically nutritionally sound, such as chicken or spinach, which have become contaminated and caused illness. These foods are not restricted by law, while natural milk, with a much safer history, has been.

As well as denying our rights, any law which proposes restrictions on the availability of hygienically produced natural milk is illogical and unscientific, as there is no proof of the alleged risks.

HOW it should be made available

Of the three options listed in Section 5, option 3 appears to be the most suitable, with some provisos.

It is not appropriate to place restrictions that may interfere with a person’s ability to source the food they want to feed their family. It is not always possible or practical for a person to go to a farm to buy milk. And it is patently ridiculous for a number of families to drive to a farm for collection, when the farmer can supply many families with one vanload. It is a waste of resources both for the family and the planet as a whole. Therefore firming up the law, so that people must pick up from the farm, is not an acceptable option.

I submit that there should be NO restriction on the amount of natural milk that a person can buy, or that any farmer can sell, and that there should be no restriction on where or how it is sold. But given that the discussion paper states that milk being sold on a commercial scale is not an option at this time, I suggest that there be no restriction on the amount or place, but that the restriction be that there be a direct relationship between the farmer and the consumer, which might include pick up from the farm, but also buying clubs, ordering online from the farmer, or the customer registering with the farmer but able to pick up from other locations.

However, it should be noted milk that is produced with the intention that it be pasteurised is different from milk that is produced specifically to be consumed natural. So what would be beneficial is a set of standard practice guidelines. They would cover:

• What cows should be fed (ie pasture)
• Hygiene guidelines for the milking shed
• Ensuring the milk is chilled quickly
• Storage guidelines
• Testing requirements

The standard practice guidelines should be developed by a group of experienced farmers, who know how to ensure that milk is produced of a suitable quality for being sold natural.

I submit that any farmer who has an RMP or similar in place that ensures the guidelines are kept to have no restriction on where or how they sell their milk, or who to (subject to the direct customer relationship suggested above).

Where a farmer doesn’t have such an RMP in place, it’s slightly greyer. But if they are the only farmer that a family can go to, they should still have the right to purchase. My recommendation is that in this case the farmer be required to advise the purchaser in writing that they don’t have an RMP in place, and that the purchaser is a) purchasing at their own risk and b) entitled to inspect the farm. This would be additional to, or part of, the requirements already listed in section 3.4.

Deb Gully

Nutritional Consultant, Chartered Natural Health Practitioner, and Representative of the Weston A Price Foundation

Janette Perrett

I am a born and bred New Zealander and my family and I have been involved with the dairy industry for five generations. On one side we have been the cheese makers and the other the primary producers and care takers of the land.

I have followed in my ancestors footsteps being involved in the latter.

In all these years as contributors to our countries agricultural income we have never seen or heard of anyone becoming ill or incapacitated from the consumption of raw milk.

Today we have a health system that is struggling to coup with a continual stream of sick New Zealanders and all we look at is the curing and banishment of their symptoms, with very, very few professionals searching for WHY the symptoms are there in the first place.

While drinking raw milk is not for everyone, it has been consumed in its raw state for centuries. It was only because of extremely poor sanitation and the milking cows ingesting by products from the whisky distilleries that pasteurisation came into being.

Today’s world is very different from the 1950’s when this legislation was first introduced. I have personally been dairy farming for 40 years and I can still recollect the walk through milking sheds with the buckets and cream cans that transported the milk by horse and cart to the cheese factory. I recall my grandfather coming in from the cheese factory in his white overalls and hat, bringing with him the smell of stale cheese. My husband’s first job was placing the cheese in their hoops when aged 15 years and his father also worked in the factory when the farming scene was on a down turn. That was in the 1960’s and 70’s.

There are three areas which concern me about the supply of raw drinking milk:

1 Animal Health

2 Hygiene Regulations

3 Organic Milk

1 Animal Health

It is common knowledge that what goes in the mouth of a ruminant is the basis with which the milk is produced in the animal’s mammary glands. In NZ we have a very wide range of ‘fodder’ being fed to our bovines, and so we are not dealing with the conventional grass pasture as 10 years ago.

Milk is the composition of the food given to the cow which is then passed through her unique stomach to produce the milk we harvest. She is gathering all the herbs and grasses with their rich mineral sources into her body to blend into ‘white gold’.

A lot of the grasses she devours are not palatable by humans so she plays her part in processing them into a substance that we can consume.

A bovine’s stomach was only designed to eat grass and leaves. It was not designed to eat maize grains or palm kernel. By adding these to their diet we are introducing the wrong fungus and bacteria into her stomach that over time places the cow’s health out of balance. When her internal metabolism is out of balance she becomes ill. This leads to a milk product absent of the valuable vitamins and minerals we require. The milk product is as ill as the cow herself.

America is seeing Johnnes Disease in their dairy herd affecting young boys through the pasteurised milk and milk products they consume. NZ has Johnnes in the national herd but it is not ‘rearing its ugly head’ yet. As an increasing number of cows are fed grains we will also see the consequences. All grains contain a compound called phytic acid which blocks the absorption of zinc, calcium, iron, magnesium, and other minerals leading to a mineral deficiency in the animal. The gut of the bovine becomes more acidic and the wrong type of bacteria begins to thrive within the cow. Again her produce does not provide the consumer with a wholesome food.

We also have the sprays to contend with. No maize crop is sown without the original round up blanket spray, nor the insecticides and herbicides that follow germination to keep weeds out and insects from eating the crop. All these are detrimental to the final product and create a toxic menu for cows to consume and then pass on to us as we are the final link in the food chain.

Antibiotics are another area of concern to me. While there are stringent tests and huge fines for these being found in the supply, they do get into the main milk supply and are passed on to the consumer. Antibiotics can disrupt the animal’s ability to enhance their own immunity, and this is passed on to any offspring. Humans are suffering the same consequences. The antibiotic destroys good bugs as well as the bad bugs in the body. As far as the bovine is concerned the value and benefit of humans drinking the milk from this animal is greatly diminished. By consuming this meat and milk it encourages fungi and bacteria to evolve with immunity to penicillin – super bugs.

The farmer today uses a variety of tools to keep their animals alive and remain part of the modern milking herd. Bloat remedies contain petroleum by products and are used to treat the herds. This is administered orally to the cow on a daily basis for three to four months. Facial eczema is also another health issue and is treated by adding quantities of zinc to the cow’s diet for four to five months during the milking season.

Both of these additives are added to the cow’s system and consequently they are also added to the milk we drink and feed our children.

Bovine health has a huge reliance on the pasture they are fed. Farming today has incorporated the use of urea to force the grass to grow. Urea is a petroleum by-product and yes it is ingested by the cow and yes it does get into our food! Urea leaves the pasture short of nutrients and fibre, two very important ingredients the cow requires to produce nutrient dense milk.

2 Hygiene Regulations

During my farming career, I have witnessed a huge change in the way milk is harvested, from aluminium to stainless steel and from open chiller and filter areas to enclosed plate chillers and filter socks. In fact nowadays the milk doesn’t see daylight or make contact with any area open to contamination! Our milking regime has become as clean as our home kitchen (in some cases cleaner) as we have come to realise we are harvesting food, not just milking the cow. More females have also taken on the role of milk collectors which has helped to keep the Dairy’s more hygienically clean.

As a farmer I do not wash the cow’s teats unless there is excessive wet dirt on them as research has proven that once water is applied to the udder a lot more unwanted ‘soil’ is disrupted and then drips down the inflation as the animal is milking. If soil is a problem each teat is wiped clean using the towel before the cups are applied. The bovine’s milk is collected at 23C and then chilled to at least 12C before it enters the bulk storage vat. This wasn’t possible forty years ago. The milk tanker collects the milk at 7C or colder. Modern technology harvests and stores the milk in a substantially greater hygienic state in 2011 than ever before.

3 Organic Milk

I have several reasons for putting this scenario in with my submission and the most important one is I have considerable concerns for the health and well being of our future generations because of the above mentioned practices of today’s farmer. I have been farming biological with a BioGro organic certification for 6 years.

I was an industrial factory farmer but I have seen the ‘light’ as I have witnessed too many of our friends suffering ill health and needing medical intervention. We were not meant to dwell on this earth in pain and as the farmer is a primary producer we need to start looking at what he is introducing to the food chain.

By only allowing organically certified milk to be sold as a raw product we don’t get any of the pre-mentioned herbicides, insecticides, fungicides, antibiotics, and non mineralised milk in the food chain of those New Zealanders who are searching for the nutritious alternatives.

The Organic farmer has gone down that path for the betterment of our nation and environment and because they are following their hearts, not their wallets! They have incredible respect for their animals as well as the food their herds provide for men, women and children.

An organic product can be traced right back to the soil it was created from and the seed that was planted. In the case of milk, a trace back can be made for the day it was collected, to the paddock the cows were grazing and the manure that was applied to the grass that was consumed. Everything introduced to the organic product is environmentally friendly and 100% free of any man made chemical or fertiliser. The animals are healthier with a lower stocking rate per hectare and only homeopath or organically certified remedies are given. No artificial additives are passed on to the consumer via the milk

Summary

As a conclusion, can I express my understanding of how clinically clean we need to be to safely harvest milk. Our two year old grandson has been consuming raw organic milk from our herd since he was 2 months old. His beautiful skin, bright shiny eyes and having never seen a doctor are testaments to how important good nutrition is and how serious we, as farmers take milk hygiene. He participates in the “Growing up in NZ” survey and during his 2 year old interview the interviewer commented about the huge number of babies and toddlers having asthma and eczema. At this early age we are already raising a generation who are reliant on our over-worked Health System. I personally think we need to take a long hard look at our food pyramid, the farmer, horticulturists, dairy, sheep & beef and fisheries. They all play a part in our health.

Let’s give our grandchildren a life worth living.

Janette Perrett

Te Awamutu

Jayne Marie Gale

My family has been drinking raw milk now for years. It is delivered by refrigerated truck to our nominated drop-off point in Wellington City. We have had no illness as a result, while many other health issues have improved.

Firstly the consultation paper makes it clear that the current position, while working currently for our family, is not ideal on a number of grounds and it would be helpful to have some parts clarified, in particular the requirement for farms to prepare a risk management assessment. Where we take issue is the proposals to limit the amount that can be sold from the farm gate, and to require each consumer to physically be present themselves at the farm gate every time they want to purchase, rather than have it delivered in a refrigerated truck or any other shared delivery arrangement.

This effectively prevents families such as ourselves who live in an urban area from having any access to a product that we consider vital to our health and wellbeing, and have researched and chosen deliberately, simply because we are not rural-based. This is despite the fact that the consultation paper can identify absolutely no negative health effects under the current system that we have been using for years, and the stated intention that the current supply should be able to continue. The proposals will clearly make it extremely costly, difficult and increase the risks both from not using a refrigerated vehicle to transport the milk and also the greater exposure to road safety risks for every extra kilometre we would have to travel weekly to obtain our milk. What a waste of human endeavour: time, petrol, money, and placing lives at risk on the road.

The issues paper prepared by the Ministry presents a very unbalanced and biased case that overstates the health risk of raw milk, based on

old data that is no longer relevant under 2011 hygiene treatment,
irrelevant anecdotal evidence (the incident with a school trip in 2009 is so different to the system the paper intends to regulate, for example),
how it compares in outcomes to, and why it differs from the risk of, other foods freely and commonly sold raw (eggs, chicken, meat, fish)
the many international counter examples, where raw milk is freely available to consumers yet life expectancies exceed New Zealand’s.

The paper also fails to discuss in a balanced way any issues of consumer choice, fails to acknowledge the negative effects of cooking milk on the delicate molecular structures of proteins (such as enzymes), fats and glyconutrients in raw milk, and is completely silent on the major health benefits of milk in its raw unprocessed state compared to cooked milk. The impact calculations thus ignore the (large) benefits and only consider the (small) risks.

This lack of balance in the paper makes for a less than open minded policy process; it raises the issue of whether the paper has already framed the issues in terms of narrow premeditated solutions, and hence does not constitute true open consultation. If a consultation paper does not present a balanced position and open minded solutions, it becomes a candidate for judicial review of the policy process.

Overstated Risks of Raw Milk

We all carry countless bacteria on our skin, in our gastrointestinal tract and in our bodies. Despite hand sanitizers, deadly bacteria right now live on our hands. Health is not microbial; the presence of bacteria is not in itself life-threatening. If that were the case the human race would have died out long ago. People are exposed to countless bacteria every day, and there is indeed evidence that people that are not so exposed to “dirt” are less robust than those that are. A healthy functioning immune system, a health promoting balance of nutrients, the integrity of our cells skin and gastrointestinal tract, and a system well-supplied with good bacteria and pre- and pro-biotics are far more important than exposure to bacteria and viruses. As Louis Pasteur himself said towards the end of his life, about the pasteurisation process, “the microbe is nothing; the terrain is everything”.

Since nomadic herders crossing the steppes, for thousands of years, the human genome has developed alongside the drinking of raw milk. Through natural selection, the human genome is designed to deal with this food (unlike Cheezles). That is why there have been no “outbreaks” from the farms supplying raw milk, rather than that there “must be underreporting” (which unsupported assumption again reveals the bias in the consultation paper).

In the meantime, there are regular outbreaks of campylobacter, salmonella and e. coli from selling chicken eggs and other meats, than ever from raw milk. Indeed I saw a statistic that more chickens are sold that carry these bacteria than without! The question is why discriminate against a product sold only to a small group of well informed, highly intelligent, health oriented, choice-based consumers, where you can find no examples of illness, while continuing to sell products with a proven track record of gastrointestinal disease? There are even no warnings on raw chicken that you should cook it! I would have to say that I often put a raw egg in my morning smoothie; there is nothing legal preventing me from doing so, and I have read about, and take the risk, knowingly as do many others and with no ill health effects.

I am not calling for the banning of raw chicken or raw egg sales, far from it. I am simply querying whether the risks outlined in the paper are being overstated when compared to other risks that consumers regularly take. The proposals here, which effectively prevent us from purchasing raw milk, seem hugely overblown compared to the cavalier treatment of risks from these other foods that are readily available to all.

Compare the life expectancy in New Zealand to European countries that allow raw milk; raw milk does not lead to worse health outcomes in those countries. In the New Zealand health statistics, look at the leading causes of death in New Zealand. Some of the top fatal, food-related causes of death include diabetes, heart attack, stroke, cancers of the gastrointestinal tract and liver. Consider the impacts on these deadly diseases of “non-foods” like sugar-laden soft drinks, potato crisps (with acrylamides, trans fats and salt), burnt barbequed meats, vast quantities of cheap alcohol, and cigarettes. All of these non-foods have much higher health risks than raw milk but are completely legal for consumers to purchase anywhere and anyhow, without warnings. For balance, look at the complete lack of fatalities in New Zealand from the current methods of purchasing “farm gate” raw milk, which includes the so called “raw milk clubs” and the farm deliveries by refrigerated van. This irrational witch hunt against raw milk, which is legal in most countries in the world, has to stop.

Benefits of Raw Milk

When I was a La Leche League leader I learned the properties of human breast milk. For example, lactoferrin transfers iron from the milk through the gut wall, enabling the baby to absorb more iron from the milk but more importantly, depriving the very bacteria that you are concerned about from iron in the gut, starving them of a key nutrient. Lactoferrin, a delicate protein, is damaged by heat. Like the white of an egg under heat, proteins change shape and being like a key in a lock, they thus lose their function.

Mothers have to stop feeding bottle-fed babies (on pasteurised milk or formula) when they get a gastro-intestinal disease. Such babies lose weight, in some cases dangerously so or even fatally. They have to stop because without lactoferrin and the mother’s antibodies in raw milk, iron in the milk stays in the gut, providing fertile ground for bacteria to breed; continuing to feed prolongs diarrhea and is also life threatening. A breast fed baby on (raw) mother’s milk can continue to feed, grow and thrive through the very same infection, never being at risk of death. Cow’s milk also has lactoferrin, when raw.

There are countless examples of delicate enzymes and other proteins that are cooked and thus ruined by heat treatment. This is not acknowledged in your paper, putting only one side of the story. Why would someone seek out raw milk, when cooked milk is so easily available? Because the consumers in this case are usually better informed than the usual consumer and as such, should be respected.

Before I started drinking raw milk, I had had a heart attack, which is rare for young, pre-menopausal women. Milk has been implicated in heart attacks in several ways. Since starting on the raw A2 milk, my blood lipids have improved, my hs-CRP has reduced and I have lost weight and reduced blood pressure. My teenager’s mental health issues have improved remarkably.

Heart attacks are just one of the health issues raised in the debate over beta-casomorphine in A1 milk. One of my brothers, a biochemist, working at Fonterra, backed up the risks of the A1 milk strain; my other brother, an IT specialist working with universities, knew the chief executive of the A2 corporation. Both these highly intelligent and well informed men consider that A1 milk is implicated in serious health issues. The raw milk that we purchase is from a herd of A2 type cows.

Lack of Evidence about Health Issues of Current Supply Arrangements

The consultation paper notes that the intention is to maintain the existing levels of raw milk supply, but there is no health problem with the current system. The proposal to restrict purchase to those lucky consumers that live within a short distance from the farm gate, definitely does not maintain the status quo for our family. It will deprive me and mine from a product that has I believe saved my life and made a major positive difference to my whole family’s health and quality of life.

If the Ministry had been able to find any solid evidence at all of ill health resulting from the current system, it would have been in the consultation paper. This lack of evidence to back up the position to dramatically curtail the current level and process of raw milk sales is a serious flaw in any piece of Government policy development. Having no solid evidence to back the preferred position that is being recommended to the Minister again raises the question of judicial review.

Conclusion

In summary, I would support Option 3 provided:

customers can continue to pay by internet and need not be physically present every time at the farm gate to collect ‘their’ milk
farmers with a refrigerated van can deliver milk to customers preferred drop off points
farmers could sell raw milk at farmer’s markets provided it is labelled as raw milk.

Yours sincerely

Jayne Marie Gale

Karen Williams

We are a family privileged to be able to make informed choice about our health and nutrition.

My husband is a Doctor and I am a Registered Nurse.

We are also delighted to be able to purchase raw milk from the farm.

All people of NZ should be able to make choices pertaining to food preference and source and therefore we request that we be able to continue to purchase any quantity of raw milk we require for our lifestyle.

Thank you for your consideration to this matter.

Karen Williams

Gretchen Ledington

I am a supporter of raw milk consumption as drinking raw milk has had a number of health benefits for myself as well as others I know who also drink raw milk. I understand the proposal is only regards farm gate sales and not looking at sales on a larger commercial level. Reading the current proposal – preferred option 3 it doesn’t seem anymore practical for people getting raw milk from farms.

Recommend making sale limit on a “per week basis” rather than per day - Reason for recommendation: It is inefficient to think people will drive out to a farm on a “per day basis”. I have in the past needed 10L milk per week – to make 2 trips to the farm is just wasteful, and what is the difference in risk between collecting it once a week and twice a week? If anything, it seems like more chance of some sort of contamination doing it twice than once.The “per day” approach seems a deliberate attempt to make it difficult for people to get raw milk in the hope of stopping them do it.

Recommend accommodating collection of milk by individuals in a group/carpool. I.e. a person in a group of four collect milk every 4^th week, they all take turn about.Reason for recommendation: This again a more efficient practical way for people to get the milk, allowing people to take turns going out to the farm and picking it up for the individual, an overall safer way to go (fewer handling milk, on the road etc.).I can tell you now I am well informed about the pros and cons of drinking raw milk and I choose to drink raw milk, and will continue to regardless of how hard you make it, and the harder you make it the more likely you are going to find people will stop trying to obey the rules you set and just go get the milk anyway.

The number of people wanting raw milk is increasing, at some point in the future greater consideration is going to need to be given to this to ensure governance is keeping up with the times and community needs, including reflecting on why raw milk was processed in the first place. Human milk is unprocessed and unanimously championed as the best food for our young. There is real similar benefit to our health in drinking raw cows milk too and we are an advanced enough society to find a way to make it safely happen.

Gretchen Ledington

Ian Gregson

I am a nutritional supplement retailer www.naturefoods.co.nz and representative of the Weston A price Foundation, www.wapfwellington.org.nz

I have been studying nutrition and natural therapies for over 10 years and have overcome a serious health problem (3.5cm brain tumour diagnosed 10 years ago) using nutrition and natural treatment methods.

As a representative of the Weston A Price Foundation I have visited dairy farms all over NZ, looked over the farms and sampled their milk. All the organic farms I have seen were impeccable and I have never had any problem drinking any of their raw milk. The milk quality is excellent, with far better flavour and cream content than the non organic farms supplying Fonterra.

As part of my whole food diet I consume around 500mls of organic raw milk every day and have done for the past 8 years. I consider raw milk an essential health food, but would never consume pasturised milk.

As a teenager I had an ongoing problem with excess mucus in my nose and throat, and frequent lung infections. I drank a lot of pasturised milk. One day after drinking a large glass of milk I became unable to breathe and started clogging up with mucus. For the next 20 years I never drank any milk, and had no further breathing problems, so was amazed to find that drinking raw milk actually improved my breathing.

Since I've been drinking raw milk every day I have not had a single cold or flu - I just don't catch those things even if exposed to them. When I used to drink pasturised milk I "caught" a cold about once a month.

I would like to be able to buy raw milk in heath food shops, in cafes, from chilled vending machines, and directly from farms, but mainly to have it delivered straight from the farm. I drink 3.5 litres a week myself, so obviously I don't think there should be any restrictions on quanity. I know people personally who drink over 6 litres a week, so I regard 5 or 6l limits as completely unrealistic.

A household of four people who all drank 3.5L each a week would require 14 litres a week. I eat around 500 grams of raw cheese each week as well - equivalent to another 5L of milk a week. That theoretical household of four people consuming the same amount I do would require 34L of milk per week if they made their own cheese.

A return trip to the farm my milk comes from would take over 3 hours, would cost approx $60 petrol, let alone wear and tear on my large thirsty car (approx another $40), and lost earning time would cost around $150. So the total cost to me of driving to the farm to pick up milk would be in the region of $250 per trip. And to tell the truth there is no way I would want to do that even if I was paid $250.

Not once in eight years of drinking raw milk from a wide range of sources have I ever become sick from it. If i did have a stomach upset the first thing I would reach for is a glass of raw milk to help fix the problem.

I am aware that NZ is one of very few countries in the world (along with Australia and Canada) that restricts the sale of raw milk. The entire European Union (EEC) considers raw milk products legal and safe for human consumption, allowing them to be sold without any price, variety, or quantity restrictions. In fact almost all countries allow raw milk sales - New Zealand is an anomalie in that respect.

In England where raw milk sales are legal the Queen drinks raw milk from her own herd, and has it delivered to other members of the royal family.

I regard access to raw milk as a basic human right protected under the treaty of Waitangi as the rights of natural healthy food production and consumption fall within the Treaty as a sovereign right for all New Zealanders.

At this point MAF has a unique opportunity to improve the standard of the raw milk sold in NZ by implementing workable hygiene regulations, but if it instead further enforced the current unworkable regulations, it could push the whole trade in raw milk further underground and reduce the safety standards. Either way raw milk sales will continue to increase. Ironically, by calling for submissions, MAF has triggered a massive increase in demand for raw milk.

I believe there needs to be a basic and affordable certification that any farm can obtain if it's up to standard. This needs to be set by a commitee of experienced raw milk dairy farmers. Once certified, a farm should have NO RESTRICTIONS WHATSOEVER on their raw milk sales - this would be just as it is done in Europe where almost all the health statistics are better than here in New Zealand.

NZ made raw cheeses currently rival the quality of many top French and Swiss chesses which sell in NZ for around $80/kg. But the existing regulations prevent these cheeses from being sold in shops, so this potential export and domestic trade has been regulated underground.

Thank you for the opportunity to make a submission on this vital health food that should be made freely available to all New Zealanders.

Yours Sincerely

Ian Gregson

Nutritional Supplement Retailer

Raw Milk Consumer

Representative of the Weston A Price Foundation

Leo Ramakers

My name is Leo Ramakers. My wife Sarah and ten year old daughter Lily have been drinking raw milk for over four years. My belief or otherwise in the dogma surrounding natural milk health are irrelevant to this discussion. As representatives paid by the taxpayer such as I, you have neither universal consent nor universal mandate from we your employers to impede my access to locally grown produce in any way.

This is not an issue about raw milk evidential science, this is an issue about the rights of a sovereign inhabitant of this land.

As father and educated caring parent I am very angry that those in positions of self appointed power have removed my free choice in this matter. As a sovereign inhabitant of this land, I have the right to make educated choices around food, and make my own decisions on what I feed myself and my family. Therefore I STRONGLY request that MAF remove any barriers which allow us to take our own responsibility for consuming raw milk or any other foods that we so choose.

Your stated intention is to close up the loopholes, so people cannot buy raw milk anywhere other than the physical farm gate. To take such a posture amounts to a betrayal of the rights of your fellow New Zealanders, and I tell you now that YOU DO NOT HAVE MY CONSENT TO IMPEDE IN ANY WAY MY FREE CHOICE IN ANY LOCALLY GROWN FOOD SUPPLY PROCESS.

The days of the wider population submitting to the loss of their natural and rightful freedoms are coming to an end, as any casual perusal of the World news will show. We in New Zealand justifiably consider ourselves to be among the most peaceful and caring societies in the world, a position we take by standing on the shoulders of our forefathers who fought bitterly to achieve that renown. We elevate our country and our heroes upon the world stage with justifiable pride.

This bullshit about you telling me that I cannot take raw farm milk is a treasonous betrayal of our predecessors sacrifices and those traits we all value so highly. I demand that you cut it out.

Leo Ramakers

Margaret Elford

I think that it is important that all New Zealanders should have the choice to choose what they would like to eat and drink. I am particularly interested in real whole foods that have not been processed and these foods form the basis of our diet. The more reading that I do and information that comes to light about how we are adulterating our food the more I believe that it is our food that is making us sick and overweight.

The Weston Price Foundation has done much validated research on these very topics, and it now beginning to be picked up by more mainstream researchers.

See links to further information at http://www.frot.co.nz/wapf/milk.htm

With this in mind I believe it is choice that consumers need to be able to have. I would like to have the choice to purchase raw milk, in quantities that suit my needs. I like to use whole unpasturised milk to make cheese. On the days that I make cheese, I need to use at least 10 litres of milk. Restricting my purchasing power to just 6 litres a day is taking away my freedom of choice. To have to return to the farm on more than one occasion to collect my milk, will be using valuable oil resources and increasing my carbon emissions. Carpooling to collect milk is another way of working together in a community and also reducing our carbon footprints. Restricting each person to collect their own milk will discriminate against those who can’t drive or who live in urban areas.

I believe that sales shouldn’t be therefore restricted to just farm gate sales. Farmers’ Markets and small retail outlets should also be considered. Once again when I was a child there were dairies in town that were just that. A dairy selling milk products from their dairy farm directly to the customer.

As a child I was brought up on raw milk. We never got sick from this milk. Testing of milking herds has made milk probably safer than when I was a child.

There are many other foods out there that cause people to become ill such as listeria from mussels and campylobacter and salmonella from chickens and these foods are not being restricted. Potting mix has caused deaths from legionnaires disease and we haven’t banned the use of that product.

We don’t need to be a nanny state. The public needs to be able to manage their own risk. I don’t see raw milk being harmful. In fact I believe that that health benefits far outweigh the risks.

Pasturising destroys the enzymes that enable you to absorb the calcium.
The Queen drinks raw milk from her own herd, and has it delivered to other members of the royal family. The Queen is 85 years old, and her mother died at the age of 101.
The main increase in heart disease has been since we started adopting low fat diets. Many studies have shown that those people who eat most saturated fats have the least heart disease.
Many other countries around the world including the entire European Union legally allow raw milk sales and use. Many thousands of people use raw milk every day and there are not thousands of sick people in those countries.

I wish my views to be taken into consideration when this bill is being debated. We all should have the right to make our own choices about our food – especially that that is in its natural state.

Margaret Elford

Mary Byrne

Dear Food Policy Team members

Re: Access to Raw Milk

My family and I have been drinking raw milk for the past 4 or 5 years and we have never been healthier.

I discovered 4 years ago, at the age of 42, that the reason I had suffered from asthma since I was five years old, was that I was gluten intolerant. By stopping all gluten I was able to completely stop all my daily medication. I had been taking ventolin daily since I was 5 and becotide daily since I was 16. It has been fantastic for me to not have asthma anymore but it does limit my food choices. Therefore, having access to the raw milk has been really important.

I normally have a raw milk smoothie every morning for breakfast instead of toast or cereal. If I couldn’t have raw milk I would not have smoothies as the pasteurised milk has far less lactase which I believe could end up giving me asthma since a lot of asthmatics are lactose intolerant so can’t handle milk that dose not have the lactase which balances out the lactose.

No one in the family has ever been sick from drinking the raw milk, and in fact, I believe we have all been healthier.

I would like to continue collecting my raw milk from a convenient drop off point in my neighbourhood.

I strive to have as healthy a diet as I can. I have read extensively on the topic of raw milk so I know that raw milk is one of the healthiest food choices I can make. I feel it would be absurd for any government agency to restrict my and my family’s right to this very nutritious food especially when alcohol, tobacco and a huge amount of junk food is readily accessible to everyone. Also, supermarket delis are known to be the most risky food choice when it comes to acute food poisoning, yet health agencies do not close these down but, rightly so, tries to educate the public so that people know of the risk to small children and pregnant women.

It would be a complete anomaly to legislate against raw milk.

Please do not advocate any change in the law as in reality there a is no problem in this country from people drinking raw milk, only an increase in health for the people consuming it.

Yours faithfully,

Mary Byrne

Fluoride Action Network

www.fannz.org.nz

Pamela Booth

We are raw milk consumers. A family of two working adults and three children.

We are concerned at the proposed restrictions your document suggests placing on our already difficult access to raw milk. Raw milk is consumed by us, without any negative side effects - in fact we have experienced only positive results since drinking only raw milk, and using it to make our own yogurt and cheeses.

We had previously had suffered from acute lactose intolerance and dairy allergies that aggravated chest, nose and ear infections particularly with the children. Since being on raw milk we no longer have such problems, and in fact we now consume much more milk that we had previously but we get much sick less often, and have good immunity and overall health now.

It is our human right to be able to choose what food we eat and where we source it from.

We want to be able to continue to access and supply our own needs with the nourishing food that raw milk is - without financial penalty.

If you are worried about foods that make people weak and sick, perhaps you should look closer at the supermarket shelves, the trickiery of labelling to hide the rubbish ingredients used, or that the local takeaway store and fast food outlets that provide people that do not know any better with highly processed, non-nutritious food that weakens their immunity, makes them overweight and allows them to burden our health system.

We want to be able to continue buying raw milk from our farmer. As hard working citizens who make a large contribution to society in the form of taxes and public service, we demand the right for convenient access to this natural, unprocessed and healing food. It is not practical for us to be able to drive for over 1 hour each way and pick up from the farm gate each week.

We are fully informed of the apparent risks of raw milk - but we are well educated and capable of handling, preparing and storing many forms of healthy, unprocessed foods.

We are yet to see any real evidence of anyone ever becoming sick in NZ as a direct result of consuming fresh raw milk, supplied from the farm. More people get sick from the food court I am sure! Our experience and research shows that the real risks of raw milk are much, much lower than your discussion paper suggests!

In terms of your paper, we prefer your option 3 BUT with some changes!! We submit that the farmer with a suitable Code of Practice (eg a refrigerated van) be permitted to deliver milk to his customers like us at our preferred drop off points. This currently saves my family time and money, and conserves resources.

A suitable Code of Practice would also cover hygiene practices and suggested testing protocols. The results of the tests could be on the MAF website, allowing all consumers to make informed decisions about which farmer (if any) they might choose to buy from.

Please take our submission, and those of other raw milk users, into serious consideration and represent the interests of the people, real NZ families, not the financial interests of industry.

Yours sincerely

Pamela Booth

Milk Consumer

I have been drinking raw milk for three years and also buy it for my children and grandchildren. None of us has ever been sick from drinking raw milk. While drinking pasteurised milk I suffered severe exacerbation of arthritis and allergy which stopped me from drinking milk for a number of years. Since being introduced to natural, raw milk, I have found that I can use it without allergy and without exacerbation of arthritis. Symptoms that I experienced with pasteurised milk were depression along with fear and anxiety. This was such a permanent state of mind that I had begun to believe that feeling peaceful and happy were abnormal. I study allergy but did not suspect the milk until first I eliminated it and then later found that natural milk did not create the problem.

I am aware of the supposed dangers of drinking natural milk, and have access to the farm where my milk comes from, if I want to inspect at any time.

As consumers, I and my family believe that we should have the right to make educated choices, and make our own decisions on what we eat. I have done my own research on the risks and benefits of unpasteurised milk and I believe it is a much safer food than many processed foods that are freely available in the supermarket. I request that MAF allow us to take our own responsibility for consuming raw milk or any other foods that we so choose.

The role of MAF is to protect NZ citizens, not to penalise them. So I submit that any regulation should be aimed at ensuring that there are suitable guidelines for the treatment of raw milk, not at limiting our rights as consumers. A suitable Code of Practice would be drafted by experienced raw milk farmers and cover animal treatment, hygiene, storage and transport guidelines. I am satisfied that the farmers are already carrying out the code of practice that you are planning.

Your stated intention is to” close up the loopholes”, so people cannot buy raw milk anywhere other than the physical farm gate. This is unfair and clearly designed to prevent people from access to such milk. I am a very satisfied consumer of raw milk, and this is absolutely unacceptable. I want to able to buy my raw milk from any farmer that I choose, and be able to pick it up at a location that is suitable. I am not able to go to a farm every week and consider it an inappropriate use of my own and New Zealand resources, when one vanload can service many families.

There should also be no restriction on how many litres can be sold by any farmer, or can be bought by any consumer.

If MAF were truly concerned to improve the health of New Zealanders It should turn its ttention to the A1 A2 issue concerning milk and diabetes and also provide warnings on the artificially coloured foods that are known to exacerbate autism, ADD, asthma and infections.

Firstly I wish to thank you for creating this opportunity to comment on Raw Milk Gate sales.
I have been actively Dairy farming for 32 years and was raised on Dairy farm prior this.
During this time all my family members and others I know consume raw milk without any ill
effects. In fact my fathers severe reflux problems disappeared once I suggested he return to
raw milk and stop drinking pasteurised milk he had started on simply for convenience.

In my submission I will encourage MAF to utilize modern knowledge and practices, and not
revert to 60 year old reasoning and increase prohibition because history tells us this just
creates underground activities. I do not believe MAFís preferred option will meet the intent
of Clause 9 of the APA and therefore encourage MAF to work ìWITHî the Raw Milk
community to design a program that is modern and works well for all parties. Much of your
document has assumptions which are not based on anything substantial at all.
There is sound science available on this subject, it just needs to be utilised.

In your document you acknowledge the growing consumer demand for better access to Raw
Milk. However I donít believe you fully understand the level of demand, both current and
growing. If you care to observe current changes in our society you should note significant
growth in getting back to basics activities, with things like gardening and cooking knowledge
back in huge demand. You say the increase in demand is from people who ìmay
aware

For people to stop buying milk from the convenient supermarket shelf or local store, and
arrange collecting and storage of something completely different tells me they have done
their homework. These people are not buying on the spur of the moment, and like many of
their other purchases they are searching for them outside the comfort of the supermarket. I
agree they may not know farming practices, and how could they simply by being forced to
visit the cowshed anyway.

This whole movement (or shift in society), is gaining momentum exponentially, therefore
MAF can choose to either bury its head in the sand or find the best way possible to manage it.
Your preferred option is a form of prohibition (your own words), and history tells us
prohibition never works. I suggest there is a better way!

Therefore I wish to broaden the extent of my submission beyond what you have asked for.
You state that the ìwider scale sale of raw drinking milkî was covered in the 2008 and 2009
consultations.
I contest that any consultation relating to ìwider raw milk accessî for the general
public at that time is irrelevant, because the consultation documents were about Raw
Milk Products, NOT wider scale access to Raw Milk.

You state within the document ìthat should information become available that shows raw
drinking milk can be produced safely on a commercial scaleî then the current policy could be
reviewed.
I believe there is more than enough knowledge available to produce Raw Drinking Milk
as safely as all other foods. The time is right to utilize that knowledge.

A lot of the current assumptions are still based around the original 1950ís law and what it
might mean. Is that fair, when technology and practices have moved on considerably in the
intervening 60 years. The low incidence of Actual Proven illnesses cited in your paper and
the Massey Study paper commission by MAF are proof of that. In the one incidence you do
cite, was there an actual Proven link or was it simply that Raw Milk was one of the foods
children ticked on the Doctors questionnaire and report?
I therefore contend that the concerns of the time (1950ís) are now covered by the
intervening changes alone, and any further concerns can be easily managed through
some form of Managed Program or Code of Practice.

I agree with you that Milk is a potentially hazardous food, just like ALL foods including air
and water. I can see no reason why milk should be treated any differently to any other food. I
could provide proof that milk is actually safer than most other foods because of itís own
inbuild mechanisms IF it is produced and handled properly.
Not all milk is the same though and milk produced for further processing can be
completely different.

This discussion is about Managing the risk to the public who wish to access Raw Milk. MAF
is charged with managing risks to the public appropriately and economically.
I contend that your preferred option does not sufficiently satisfy clause 9 of the APA by
mitigating the risk, sufficient for the Minister to grant an exemption for the need for a
RMP.
I acknowledge that it will be easier for MAF and many of those wishing to supply Raw Milk,
but we all know that people have different standards of housekeeping. It is no different with
Milk producers, therefore allowing sales of what you deem an extremely hazardous substance
to be produced unregulated, and simply controlling potential illness by limiting the number of
potential illnesses, does not meet the intent of clause 9 of the APA in my view.

Do we really want these scenarios selling raw milk without any form of register at the
very least?;
1000 cow farm, using Palm Kernel, Maize, Urea, Antibiotics, Cidreís etc with no teat
washing system selling 120 litres per day to customers who self fill their containers
out of the Farm Milk Silo.

Or 5 cows being milked into a Plastic test bucket in the paddock under the hot sun
with only a kitchen jug of hot water for washing the equipment, selling the surplus.

Or 2 cows hand milked into an open bucket on a hot summers day with flies and all,
on a dirt floor, selling the surplus.

Potential Pathogens;
Mv
they
thatevelr
Here is part of Testimony by Dr Ronald Hull from Australia to the Superior Court in
California where he was accepted as an Expert witness for his experience with Milk and Food
pathogens and their control methods, along with HACCP programs.
Q. Read the first sentence into the record for us, and then
could you respond to that.
A. Yes, please. Thank you. Paragraph five says, "In the dairy
farm and milk-handling environment, the presence of harmful bacteria
in raw milk cannot be reliably controlled independently of sanitary
controls against all bacteria in general."
I disagree with that.
Q. You disagree why?
A. Because we know where pathogens come from in the dairy
industry. In the case of shedding cows, we know why they shed
pathogens, and we have procedures to eliminate those pathogens from
the gastrointestinal tract of those animals, and that's been
commercial practice now since -- in the poultry industry at least
since 1970. We're talking 38 years that's been knowledge, and it's
now practiced in other agricultural industries. So we can be assured
that our animals are not shedding pathogens. So we can be very
specific in our control measures for controlling pathogens in the
dairy herd and in the milking environment.

As you can see there is considerable knowledge now available about pathogens and their
control methods. Systems CAN and NEED to be put in place to ensure a safe and nutritious
product is available to those who ask for it. It is obvious that all milk is NOT the same and
the information gathered in the survey of Fonterra milk is only useful as proof of this. The
two products can be quite different.
We donít have to rely on chance anymore, we can put systems in place for milk just like
with all other ready to eat foods.
Even the risk of diseases like TB infecting raw milk have been largely controlled with the
national TB Free programme resulting in the majority of farms now having a ìTB Freeî
status. The move in the early 1970ís to stainless steel with its enclosed milking systems has
also eliminated the major risk of external sources of contamination from human and other
carriers. External sources were once the main sources of TB contamination of milk in the
early 1900ís when open buckets were used.

The ability to now refrigerate milk quickly and maintain low temperatures gives us far
more control over the quality of the milk and once packaged, just like with all other
foods, it can be managed.

MAFBacteriaduce
that
by
way
it
This argument is the same for all foods, yet risky foods like seafood and poultry are still
sold free of prohibition legislation.
Commercial Sales? es
standards
previous
some
framework
What do you define as more Commercialî? Your preferred option allows someone to sell
120 litres per day (unmonitored and unregistered) at the going commercial rates which vary
between $1.50/ltr and $4/ltr. At the upper price that is a potential $480 / day, or $3360 /
week, or $174,720 / year. The lower price is $65,520 / year. As you can see claiming farm
gate sales to be ìnon commercialî is not a logical argument and should not be used to
maintain ìprohibitionî.

Egg Example;
The example of eggs used in your discussion document has no similarity to milk I believe,
because the edible part of the egg comes prepackaged. And as long as they are sold within a
reasonable time period the risk is generally very low even at room temperature. Whereas with
milk the edible part needs extracting, handling and packaging, then cooled ASAP, all of
which have theoretical potential hazards.

Direct Sales;
I whole heartedly agree that all sales should be direct from the farmer, and no on selling
should be allowed. This provides a method of self regulation because poor quality or service
will not get repeat sales. I do not believe the intention of the original 11A regarding the
collection of milk from the Farm Dairy was to inspect the premises. Most customers at that
time would have ìknownî farming practices anyway. Instead the reason would have been
put in to collect the milk as fresh as possible because there was very little efficient cooling of
milk and refrigerators were not that common in the country until the 1960ís. Milk on most
farms at the time of writing the law was ìseparatedî into cream and whey for commercial
sale, therefore if anyone wanted straight Milk, there was no way of storing it in cool
conditions like there is today, and once collected it is the customers responsibilty.

With the demographics of our society changing greatly since the introduction of the Farm
Gate Sales law in the 1950ís, most of the population is now centred in cities and large towns,
meaning if the restriction on collection from the farm dairy is maintained with this massively
growing demand, our rural roads will come under increased pressure creating extra
maintenance as well as using up valuable carbon resources.
Iím sure the BioSecurity arm of MAF will also have concerns about numerous vehicles
entering farms across the country.
For farms on State highways many of them have vehicle access limits, so should any of them
be Raw Milk suppliers they will have the problem of breaking Transit NZ restrictions.

Many rural communities are also facing increasing security problems, which makes any
increase of ìforeignî vehicle suspicious and less desirable.

These concerns, combined with improved technology means that in some cases, a far
better solution would be to set up central collection points where the delivery and depot
(refridgerated) are all monitored under a suitable program much the same as any meat
or delicatessen food.

Quantity;
Many of these getting back to basics consumers also purchase many of their other foods
supplies direct from farmers at markets etc and wish to add to that things like their own
yogurt, butter and sometimes cheeses. Therefore 6 litres is hopelessly inadequate. If 6 litres is
deemed safe enough to supply ìsome of the public then why should any limit be placed on
it.
If all concerns can be managed, then is it right for MAF to be involved in Limiting
Commerce. Is it also right for MAF to be limiting the ability of people who take the trouble
to educate themselves and ìtake personal responsibilityî for their food.
Conclusion;
To conclude I believe Option 3 (MAFís preferred option) is woefully inadequate at
addressing the current and future issues surrounding Raw Milk availability and sales. It fails
to utilize current technology and knowledge to manage Raw milk sales throughout NZ,
putting some consumers at risk, along with the wider dairy industry. Without even a basic
register, how can anyone know if cows are TB free, basic hygeine standards are maintained,
let alone quantities are being observed.

My preferred options would be a modified version of Option 2 , creating 2 paths similar to
this;
1, A register and basic Code of Practice developed with the Interested Community,
for Gates Sales of Raw milk with either no limit or perhaps a 20 ltr limit to better
reflect our changing society.
By having a register and Code of Practice developed in conjuction with the Interested
Community, these farms supplying Gates sales only would be subject to spot audits if
needed to ensure compliance to the COP. This keeps the costs and time low for both
the farmer and MAF.

2, For those wishing to supply to Central Collection Points outside of the farm gate, a
full RMP and COP can be developed with the Interested Community for Raw Milk
Sales. All sales will still be direct and milk will be pre-ordered. The RMP would
cover all points from harvest to collection including regular testing, just like with
other foods.

There exists an opportunity for MAF to work with the Interested Community and build
a robust system that satisfies the concerns of both, for now and for the future. We don't
have to live 60 years in the past.

Ray Ridings
Dairy Farmer

I have been sourcing raw milk for the past 20 years, and in my consulting work I have seen many health issues clear when people start to use foods in their natural, unrefined state. Many of my clients have had health issues resolve when they have begun to use raw milk and its products together with other real foods.

Introduction:

The increase in the incidence of chronic nutritional disorders including type 2 diabetes, high blood pressure, heart disease, obesity, eczema, allergies, asthma, ADD, ADHD, depression, anxiety, Alzheimers disease, gut dysbiosis and more has been phenomenal over the past 100 years.

The health of our nation has deteriorated markedly under the teachings and guidance of our government, and I prefer to take full responsibility for my own health. I choose to eat old-fashioned, nutrient-dense foods, including fresh, full-cream raw milk and its products, from healthy cows, grazing healthy pastures, grown with natural fertilisers and free of toxic chemicals.

I am 61 years old, and can count on my fingers the number of times I have been to the doctor in the past 20 years. During this time I have been using natural, unprocessed foods, with raw milk and its products playing a very important part. I wish to continue to do this without restriction and for it to be available around the country for all New Zealanders including my clients, many of whom I work with over the phone.

I have personally witnessed the complete recovery of people with Type 2 diabetes, Crohn’s disease, reflux and other gut disorders, “lactose intolerance”, allergies, eczema and asthma when their diets have changed to include raw milk. These cures will save our country a great deal of expense, as people eating real foods need far less health intervention and very few drugs. Drugs will never cure a chronic lifestyle-induced problem anyway.

1. Dairy farmer to sell direct to consumer.

I feel this is acceptable under the current proposal, although I would eventually like to see all citizens of our country being responsible for their own health and encouraged to think for themselves, with raw milk readily available to all through a variety of outlets.

I ask that you allow consumer demand drive the raw milk market.

2. Dairy farmer restricted to selling 6 litres per person per day.

I ask that you remove this per person per day restriction.

Some people wish to use 20 litres (or more) of raw milk each week to make yogurt and cheese, and/or for their family to drink as a natural, nutrient dense, probiotic food. It is impractical for those families to have to visit the farm four times in a week to collect this amount.

The restriction on sales being direct to consumers will naturally limit this to the amount a family uses weekly.

Milk carried in a 6-litre container is no safer than milk carried in a 20-litre container. Or if you prefer, 3 x 2-litre containers of milk are no safer than 10 x 2-litre containers of milk.

It therefore appears to me to be an attempt to restrict the growth of the raw milk market.

I ask you to allow consumer demand drive the daily per person raw milk volume sold. A family can only use so much raw milk.

Firstly: Demographics have changed in our country since the 1950s, and many consumers won’t be able to source the raw milk of their choice if the closest farmers to their city can only sell 120 litres each per day. Allowing only 140 people a week to buy milk from each farm, it would be impossible for sufficient numbers of farms to be located close enough to the cities for everyone who wants raw milk to be able to source it.

This ruling will discriminate against city dwellers.

I suggest rather than a volume limit per day, that the restriction be on maintaining effective hygiene standards, including washing and wiping all teats of all cows, taking the foremilk off at each milking and fair milk quality testing.

These requirements would be more efficiently monitored on several medium sized farms than they would be on hundreds of small 6 cow farms, (which is quite ridiculous when you look at it this way). Who is going to inspect all of these small blocks? How are farmers going to be able to afford to farm small blocks close to cities? Perhaps this is what you are hoping for, an impossible situation.

Safety of raw milk is related to the farmers’ hygiene practices and cow health, not to herd size.

It therefore appears to me to be an attempt to restrict the growth of the raw milk market.

This rule will prohibit a large number of people from being able to access raw milk.

This will be very costly in time, money and carbon emissions. It is impractical to expect each city dweller to travel independently to a source of a good raw milk supply.

How will housebound people, ill people, hospitalised people, non-driving and otherwise immobile people get to their milk supply?

Or if they want 20 litres a week and are expected to take 4 trips pick up 5 litres each day for 4 days.

This ruling will discriminate against city dwellers and immobile people.

I suggest that milk be transported to drop-off points for people unable to collect raw milk, with the farmer having to hold a certificate of “ Good Transport Practice” . There could be limits of time, distance travelled, temperature and storage of milk.

As the farmer can only sell directly to the consumer and consumers are not stupid, they will be able to choose which farmer they buy their raw milk from by visiting the property at least once.

They will also stop buying from a farm where the milk does not stay sweet for at least a week.

5. Milk cannot be sold from other premises. eg local stores or farmer’s markets

It is essential that raw milk be more freely available in the future, but I realise it is not on the agenda at this stage.

Our government allows the retail sale of party pills, alcohol, fast foods, diet coke, cigarettes, sugar, gaming machines and other items that destroy health and wellness. Our government repeatedly tells us these things will never be banned, and it is up to individual choice.

Each of the above listed ‘free choices’ cost our country far more money in damage control than raw milk ever could.

There must be financial reasons for this anomaly, as there is no other sensible explanation.

It therefore appears to me to be an attempt to restrict the growth of the raw milk market.

Working group: It is very important to me that going forward from here we are able to set up a working committee made up of raw milk producers, raw milk users, naturopaths and other healers and government representatives to work on raw milk availability for the longer term. This should include creating a sensible “Code of Good Practice” around the production and sale of raw milk, which is practical to use and affordable to implement and audit.

I have heard of cases of unborn babies dying due to infections from raw mussels. Raw mussels sales have not been restricted in any way.

I have heard of cases of food poisoning in restaurants and cafes. These restaurants and cafés are allowed to continue to operate.

I have heard of people buying a meat pie and becoming sick. Pies have not been removed from retail outlets.

I have heard of people becoming infected from eating chicken. ‘Fresh’ chickens are still available for sale in supermarkets. Buyer beware.

I ask that you also let people make the healthy raw milk choice.

The Safety of Raw Milk Raw milk does not “go off”, but rather becomes more sour over time as the natural lactic bacteria in the milk convert the milk sugar, lactose, into lactic acid. This milk is known as “ clabbered milk”. Some people stand their milk in warm conditions to “clabber” as they prefer to drink it this way, complete with enzymes that will help them to stay healthy.

PROTECTIVE COMPONENTS: Raw milk contains numerous components that assist in:

I could quote many studies that indicate the safety and health benefits of raw milk but would not expect you to have the time to read it all, so I offer just one reference here.

Offering to increase the volume of milk sold per person per day by one litre is a very weak attempt at this.

If you really want a happy nation of healthy people, something has to change. Let’s start with our food.

It is a basic human right to be able to choose what food I eat.

I want to be able to be able to buy raw milk from a known farmer with the understanding that I am taking responsibility for my health. I consider raw milk (from a suitable farmer) to be healthy and nutritious. I want the farmer to be able to deliver to me as this is the safest way of transporting the milk so that it remains cool / hygienic and is more environmentally sound than having people driving to farms.

Out of the 3 options, option 3 seems the most appropriate, but with a change. I submit that a farmer with a suitable Code of Practice (eg a refrigerated van) be permitted to deliver milk to his customers at their preferred drop off points.

A suitable Code of Practice would also cover hygiene practices and suggested testing protocols. The results of the tests could be posted to the MAF website to allow consumers to make informed decisions about which farmer (if any) they might choose to buy from.

Kind regards,
Stephen Zanetti

I grew up drinking standard pasteurized milk and always found it mucous-forming and difficult to digest. I largely became vegan until discovering raw milk which I have drunk intermittently for several years from several sources in Wellington and Otago, with no such problems, and have certainly never been sick from it. I'm aware of supposed dangers of drinking natural milk, and have access to the farm where my milk comes from, if I want to inspect at any time. I've done my own research on the risks and benefits of unpasteurised milk and I believe it is a much safer and healthier food than many processed foods that are freely available in the supermarket. I request that MAF allow us to take our own responsibility for consuming raw milk and any other foods that we so choose. As a consumer, I have the right to make educated choices around food, and make my own decisions on what I eat.

I submit that any regulation should be aimed at ensuring that there are suitable guidelines for the treatment of raw milk, not at limiting our rights as consumers. A suitable Code of Practice can be drafted by experienced raw milk farmers and cover animal treatment, hygiene, storage and transport guidelines. Your stated intention is to close up the loopholes, so people cannot buy raw milk anywhere other than the physical farm gate. As a very satisfied consumer of raw milk, this is not acceptable to me.

If it's safe to buy at the farm gate, why is it not safe to be delivered? Has there been any recorded instance where what is currently being done has led to any actual problems? I want to able to buy my raw milk from any farmer that I choose, and be able to pick it up at a location that is suitable. I am not able to go to the farm every week and consider it an inappropriate use of resources, when one van load can service many families. There should also be no restriction on how many litres can be sold by any farmer, or can be bought by any consumer, as this is a food quality issue, quantity has no relevance. If it is permissible and obviously safe for anyone (such as farmers themselves, family, friends, neighbors) to drink raw milk as they have done for time immemorial, then it should be permissible and obviously safe for it to be distributed more widely, unless there are proven issues.

If you would like your submission adding to this page, send copy to wapf@frot.co.nz and we may include it here. Thanks for your support.


	www.milk.org.nz