This was our first submission on raw milk from back in 2011

Submissions to MAF – Nov 2011

Submissions on MAF Public Discussion Paper No: 2011/11- “Proposals for continuing to legally provide for farm gate sales of raw drinking milk”

The document we were making submissions on is available for download HERE

A Summary posted by Emma Abrahams in November 2011 is online HERE

The Ministry of Agriculture and Forestry (MAF) has since been renamed the Ministry for Primary Industries

We received a reply from the Ministry for Primary Industries, in December 2012. They received 1685 submissions, of which 1561 supported the continuation of raw drinking milk sales.

Here is their reply:

Thank you for your submission on proposals for continuing to legally provide for farm gate sales of raw drinking milk.  The Ministry for Primary Industries (MPI) received 1685 submissions on the proposals.

After considering the outcome of consultation, the Minister for Food Safety, the Hon Kate Wilkinson, decided that farm gate sales of raw milk will continue to be allowed, and that the amount that can be purchased is likely to increase in the future. The Minister has also decided that farmers will be exempt from the current requirement to have a Risk Management Programme for farm gate sales of raw milk and will instead need to adhere to certain animal health and hygiene requirements.

The Minister has also asked MPI to undertake further scientific and policy work to investigate increasing the limit that consumers can purchase and whether raw milk can be sold off the farm in a way that balances managing the risks to public health with consumer choice.

MPI will also look at how consumers can be provided with information on risks associated with raw drinking milk at the point of sale so they are able to make an informed choice when they purchase raw drinking milk. 

MPI will consult on any new regulatory proposals relating to the production and sale of raw drinking milk, including the animal health and hygiene requirements, any limits on the quantity that can be purchased and sold and any proposals for sales of raw milk outside of the farm.  Your name has been added to the mailing list so you will be advised of consultation on this issue.

In the interim, the current legislation applies, and if people wish to consume raw milk they can buy up to 5 litres of raw milk from the farm gate for their own personal use or to provide to their family to consume.

A summary of the submissions has been posted on the MPI website at:

http://www.foodsafety.govt.nz/elibrary/industry/farm-gate-raw-milk-sales/index.htm

Information on safe food practices in relation to raw drinking milk these can also be found on the MPI website at:

http://www.foodsmart.govt.nz/food-safety/high-risk-foods/raw-milk/rawmilk.htm

Once again thank you for your submission. 

 Yours sincerely 

Hilary Eade

Food Policy Manager

Ministry for Primary Industries

Submissions by

Alina Bordukova

Caroline Marshall

Claire Taylor

Debbie Betts

Deb Gully

Karen Williams

Gretchen Ledington

Ian Gregson

Leo Ramakers

Margaret Elford

Mary Byrne

Pamela Booth

Sherry Elton

Susan Galea

Stephen Zanetti

Viryam Robertson

Alina Bordukova

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.

We propose that MAF:

1) Treat our direct supply of raw milk from our farmer to ourselves as a

distinct food supply as opposed to any other milk for processing.

2) Allows our farmer to obtain a Code of Practice licence of some

description including the ability to transport in a refrigerated van.

3) Allow us to take responsibility for consuming raw milk as suggested and

any volume that we wish to obtain.

4) Publish results of raw milk testing for all providers on their MAF web

site.

Yours faithfully,

Alina Bordukova

Raw Milk Consumer

Caroline Marshall

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.
Some history
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.

Micro-organisms
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.
Limiting farmers to a maximum of only 120 litres
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.
Milk groups
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.

Another matter regarding nutrition and the health of the nation
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

Claire Taylor

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.

Yours sincerely

Claire Taylor

Debbie Betts

I am a classical homeopath and a mum of four children living in Devonport, Auckland.  Of the 6 people in our family, 4 are lactose intolerant, which means that drinking the milk available in supermarkets is not that ideal for our bodies.   Raw milk however, is able to be digested without the negative health implications that processed milk has.    When my children were younger, I managed for a few years to source raw milk for my family.  During this time our family enjoyed the flavour and the health benefits of consuming this delicious food.  Since purchasing supermarket milk two children have developed Asthma – I believe that at the raw milk made a positive difference in their health here.   Currently the travel / time / costs / limits imposed to purchase direct from the farmer is just a huge barrier for me to be able have this food on a daily basis for my family. This to me is frustrating and ridiculous.  I am an advocate for Raw milk to be freely available to all in New Zealand.

Your preferred proposal which in summary:

Milk could only be sold directly to the person/family who will drink it

• would limit groups of people from cities to car pool and collect – huge cost to individuals

Dairy farmers could sell only 6 litres per person per day

• again as above, and restricts amount carried per vehicle

Dairy farmers could sell a total of only 120 litres per day

• As above, only allows 20 people to buy from farmer what about farmers herd size?

Milk must be picked up directly from the farm dairy

Milk cannot be sold from local stores or farmers’ markets

• Many products are distributed via this method providing quality produce that is fresh and cheaper (bypass middleman) why not for “milk”

Reasonable animal health and hygiene requirements would need to be met, but the need for a comprehensive Risk Management Programme will not be required nor enforced.

• 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

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 4th 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

Sherry Elton

INTEREST AND INVOLVEMENT:

I am a practicing nutritionist and Weston A Price chapter leader for Southland

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.

MAFs proposals:

My considerations about your preferred Option 3 are:

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.

Reasoning:

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.

I feel this is an unfair restriction with no sound reasoning behind it.

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.

3. Dairy farmer restricted to selling a maximum of 120 litres per dayI ask that you remove this per farmer per day restriction.

Reasoning:

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.

Raw milk from a 6-cow herd is no safer than raw milk from a 200-cow herd.

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

There is no sound reasoning behind this requirement.

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

4. Raw milk must be picked up from the farm by the consumer.

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

Each city dweller may have to travel for well over an hour to get their 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 would clearly be ridiculous.

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.

Let’s give our people the right to choose raw milk freely.

There is no sound reasoning behind this discrimination.

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

6. Further suggestions

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.

Raw milk is an inherently safe food.

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.

From www.realmilk.com PROTECTIVE COMPONENTS: Raw milk contains numerous components that assist in:

• Killing pathogens in the milk (lactoperoxidase, lactoferrin, leukocytes, macrophages, neutrophils, antibodies, medium chain fatty acids, lysozyme, B12 binding protein, bifidus factor, beneficial bacteria);
• Preventing pathogen absorption across the intestinal wall (polysaccharides, oligosaccharides, mucins, fibronectin, glycomacropeptides, bifidus factor, beneficial bacteria);
• Strengthening the Immune System (lymphocytes, immunoglobulins, antibodies, hormones and growth factors) ( Scientific American, December 1995; British J of Nutrition, 2000:84(Suppl. 1):S3-S10, S75-S80, S81-S89).

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.

USDA/FDA STATISTICS: Based on data in a 2003 USDA/FDA report: Compared to raw milk there are 515 times more illnesses from Listeria monocytogenes due to deli meats and 29 times more illness from L-mono due to pasteurised milk. On a PER-SERVING BASIS, deli meats were TEN times more likely than raw milk to cause illness ( Intrepretive Summary – Listeria monocytogenes Risk Assessment, Center for Food Safety and Applied Nutrition, Sept. 2003, page 17).  

In summary:

I cannot help but believe that you have no intention of making it easy for people who choose to use raw milk and its products, but are paying lip service to this issue to try to keep the “masses” happy.Offering to increase the volume of milk sold per person per day by one litre is a very weak attempt at this.

I have to conclude that your real agenda is to stop this increasing demand for raw milk in its tracks, and control it as tightly as you can. There has to be a financial agenda, because there is certainly no ‘danger to health’ agenda that could be attached to the use of clean raw milk from clean healthy cows grazing a clean chemical-free farm.If you really want a happy nation of healthy people, something has to change. Let’s start with our food.

Yours faithfully,

Sherry Elton

Nutritionist

Weston A Price chapter leader for Southland

www.thecroft.net.nz

Susan Galea

1.2 Scope

The scope has been defined as farm gate sales. It would be more helpful to redefine the scope as being direct farmer/producer to consumer sales, as that is what is referred to later as one of the conditions of such a sale.

We submit that the scope of these proposals be generalised to any sale of raw milk direct from a producer to a consumer. This is a key condition of the sale of raw milk and it also fits with the definition of commercial farming, which is producing with intention to sell to a wholesaler or retailer.

The definition of commercial is not fully documented here but that would surely be any sales not directly from farmer to consumer with a middle man so that fits with our submission above.

1.3 Reasons for Review of Farm Gate Sales

What is in question here is not the right of farmers to sell milk, but the right of consumers to buy and consume a natural whole food. There is growing consumer demand for raw milk and there needs to be provisions to allow them this choice.

3.2 Food Safety Risk Associated with drinking raw milk.

“Bernard is right; the pathogen is nothing; the terrain is everything.” — Louis Pasteur’s deathbed words

New Zealand Public Health Surveillance Reports provide information on disease outbreaks over each period. (Available on www.surv.ers.cri.nz )

The Reports on the site go back to 2004, at which time the rate of Campylobacter cases was up to 431 cases per 100,000 per year, a total of over 16,000 people affected. The number of cases last year was 155 cases per 100,000 per year, a total of over 6000 people affected. This shows that over the last six years while raw milk drinkers increased 50 fold, the rate of Campylobacter actually went down to a third of the original.

MAF states in their report that from a list of potential raw milk pathogens only Campylobacter has been observed, and the evidence raw milk was responsible for this one outbreak is weak. The strain of Campylobacter in the stools of those affected was not identical to that found on the farm. The outbreak also occurred 13 days after the farm visit. There could have been other vectors causing the outbreak.

It would seem that the information in 3.2 is obtained from overseas sources and does not necessarily relate to the New Zealand environment as stated in the report by MAF.

3.3 Origin and intent of Law about Farm Gate Sales

The intention stated in the first paragraph “maintain the traditional right of consumers to purchase raw milk for drinking” is probably better restated as “to allow people to choose and decide what food and drink to consume and to allow reasonable ways to make such foods available”. The intent was more about freedom of choice than about actually going to a farm and physically obtaining the milk.

At the time (1950) raw milk had up until then been the only milk that people drank. This was giving them a way to choose to continue with what they were used to. At that time there were a multitude of small farms producing milk, unlike the current scenario of fewer larger farms producing milk. In addition many of these small farms were within reasonable access of urban dwellers whereas now the farms have retreated further from population centres. For instance: in the 1950’s there were farms in Lower Hutt whereas now there only a few in Whiteman’s Valley which is much further from urban areas.

The idea that a large increase in the sale of raw milk is unacceptable because it would “expose the community to potential food borne illnesses on an unacceptable scale” is not borne out by the Reports quoted above (New Zealand Public Health Surveillance Reports).

There is no competent data to determine the prevalence of pathogens in the New Zealand Dairy Herd. So, to draw the conclusion that the more people that drink raw milk the bigger the risk is an extrapolation which is not based on any facts. Since milk sent to processors is not tested for these pathogens on a regular basis and has not been tested for each individual producer there is no reliable information on pathogens in the New Zealand dairy environment.
To determine that transport and storing of raw milk would increase the number of pathogens in raw milk requires information on what pathogens are in the milk to start with. If raw milk has been tested and shown to be pathogen free then as long as milk is transported and stored in new, sealed bottles at less than 6 degrees C, no new pathogens can be introduced to the milk, and there will still be zero pathogens present.

Conversely, if it is known that the milk contains pathogens the milk will continue to contain pathogens no matter how it is stored and transported and if such milk is not chilled to acceptable levels while stored and transported the pathogens can multiply, but they will be the same pathogens with the same potential to infect the consumer, even if they had collected at the farm gate.

3.4 Current Legal requirements in New Zealand

It is interesting to note that the law states that if anything is removed from milk in processing the resultant liquid cannot be called milk. This means that all standardised milk is wrongly being labelled as milk.

3.7 The Approach of other countries to Raw Drinking milk

There are also countries where the culture or religion dictates that the people should drink raw milk. Many people from those countries have come to live in New Zealand and would appreciate an up to date rational and balanced approach to raw milk availability.

Many other countries allow raw milk to be freely available including America, many states it is legal, England (the Queen drinks it and always has), Italy where they have raw milk vending machines in the street, European countries, other Asian countries. America has around 9 million raw milk drinkers and only 147 cases of illness resulting from raw milk since 1987.

4.1 Requirements for RMP for raw milk sales

We know of two farms with an RMP which includes the provision of raw milk sales on the farm. One is Bio Farm and the other is Hohepa farms. As long as the milk is tested from time to time for a range of pathogens, and is stored at all times at or less than 4 degrees C and that evidence can be shown for both of these, there is no added risk of increase in pathogens by storage or transport of milk.

The consumer should be made aware of risks associated with raw milk. It is not valid to say that it is not traditional consumers who now want raw milk when traditionally everyone drank raw milk. Pasteurisation is really the non-traditional method of dealing with milk. Also some of the recent increase in demand for raw milk is from newcomers to New Zealand from countries where it is culturally and traditionally accepted to drink raw milk.

As above we believe the intention of “farm gates sales” per se was primarily to enable consumers to have freedom of choice about the milk that they consume.

We submit that visiting the dairy farm does not give consumers the ability to fully assess the hygiene of the farm. Having qualified inspectors is the only way to assure the hygiene of the farm is acceptable as the process of attaining the milk has many important steps over a long period of time that should all be monitored. So a consumer visiting cannot make a full assessment. This makes the requirement to actually visit the farm to collect the milk irrelevant.
In the current environment many farmers would consider it a potential biohazard to have consumers coming into the cow shed to see what the hygiene is like.

We submit that a large part of the original intention of allowing farm gate sale was to give the public the choice to consume what they believe is a more nutritionally beneficial product, while assuming responsibility for any health risks (however small they may be). Pasteurisation is one option for eliminating that risk, and may be appropriate for the large scale operation of a company like Fonterra. However, regular testing for pathogens is an equally effective method and may be more appropriate for smaller scale non-commercial farms that provide milk direct to consumers who demand the higher quality of raw milk.

There is a direct expectation and demand from consumers of raw milk for raw milk producers to provide a high quality product; otherwise they would buy the standard commercial milk. Consumers know exactly where and when their milk was produced so there is a high expectation on the farmer to produce a reliable and safe product. And the raw milk farmer cannot hide behind the politics and bureaucracy of a large corporate

5. Options for farm gate sales of raw milk

Option 3 seems the most sensible option

The limit of 120 litres a day is rather arbitrary and if one goal is not to limit consumer choice then it should be higher than that. In any case, if it is limited to direct farm to consumer sales, no volume limit would be necessary to avoid commercial sales since according to the definition as previously stated in 1.2, it is non-commercial irrespective of scale. If each farm had to record who was obtaining milk from the farm that would eliminate any negatives of providing a larger volume.

However we submit that:
There should be an Option 4 which provides for another type of RMP specifically designed for the production, storage and transport of raw milk all in one document.

This Option should be available for Organic and Biological farms only. There are other risks associated with non-Organic milk like HGP (Hormone Growth Promotants) pesticides, antibiotics and other substances (like palm kernel ingredients) being in the milk.

Non organic conventionally farmed dairy cows, specifically the modern dairy cows breeds, bred for high milk production, are under considerably greater physical/hormonal stress which increases undesirable secretions of pus into the milk, the milk then being higher risk and treatment being more justifiable.

This Option should be available for smaller farms of less than 300 cows. This would also promote healthier cows and a healthy system rather than larger herds.

We do not consider it necessary for the consumer to visit the farm every time that they obtain their milk, but maybe they should visit the farm from time to time. As stated previously, the assessment of the health of the cows, the way the cows are treated, and hygiene levels requires a more in depth investigation than is possible by a visiting customer Therefore we submit that it is not necessary for the collection of the milk to be on the farm. Having to collect their milk from the farm each time would also take away the freedom of people to choose the consumption of raw milk which impacts basic human rights.

We submit that the transport and storage of the bottled milk should be according to rules. That is that the temperature of storage and transport be below 6 degrees C. That this should be monitored daily at the truck or the refrigeration stations. The refrigerated truck should be inspected and approved by an independent assessor. The truck or van should be cleaned internally. Also, daily samples of the bulk milk should be taken that could be tested if a monthly test is positive for any pathogens. We submit that transport does not increase risk of pathogens in raw milk. See submission at 3.3 above.

A simple label with a date stamp and the origins of the milk should be applied to the bottle.
Literature about raw milk should be made available to raw milk drinkers wherever they collect the milk.

In terms of the Animal Health and Hygiene requirements:
A TB free herd is acceptable
Any sick animals should be removed from the milking herd for twice the withholding period of any medicine administered.
We agree with washing teats daily and testing each teat for underlying subclinical mastitis, as well as daily vat taste testing.
Other hygiene measures as per normal milk harvesting rules should be in place.
Containers for raw milk should be new not just “clean”.
The milk should be organic to ensure that there are no poisons, hormones or antibiotics in the milk.
Record keeping of each consumer collecting milk and dates collected is acceptable. We submit that the amount of milk collected is not overly important. The six litre limit can still be ambiguous if a car load of people arrive and each person takes six litres. For the farmers practicality it is probably going to be better if an ordering system is in place to facilitate the collection.

It is interesting that Listeria innocua is mentioned in the report on the survey by Fonterra. This strain of Listeria isn’t harmful to animals or humans, in fact it has also been found to produce antibodies to other strains of Listeria, thus inoculating the milk and the drinkers against harmful strains of Listeria.
The survey of Fonterra would have been conducted on the bulk milk tank.
We submit that it is stated in this Appendix that “there is a lack of information on the levels of microbiological pathogens in raw milk in New Zealand”
In the case of M. Bovis the following dismissal of the cause of bovine TB in humans should be taken into account.

This is taken from an article: The Risk of Bovine TB from Raw Milk Consumption with a Focus on Michigan. Written by Ted F. Beals, MS, MD. February 12 2008, ,hich is available at www.westonaprice.org/farm-a-ranch/risk-of-bovine-tb-from-raw-milk-consumption

Ted Beals, MS, MD, is a physician and board certified pathologist, who served on the faculty of University of Michigan Medical School. He is now retired after 31 years of clinical and administrative service in the Veterans Health Administration.

Bovine TB in Milk

Growth of the tuberculosis bacteria is extremely slow, even under ideal conditions. They are unlikely to proliferate outside of a living animal. And growth in milk is considered very unlikely. With our current understanding of the complexity of this disease, it has been shown in several rigorous studies conducted in countries where eradication programs are not in effect, that in large dairy herds with widespread infection, a few samples of milk do contain the bovine tubercle bacillus.8,9,10 This has been documented even when the milk was carefully handled to eliminate the possibility of contamination outside of the cow.
In one study in Tanzania,11 two out of 805 samples obtained from infected cows were confirmed to contain the bovine bacteria. In a 2003 study in Lahore, Pakistan, researchers were able to identify bovine tuberculosis bacteria in the milk from four of 16 cows with confirmed bovine tuberculosis.12 It is critical to note that all of the cows tested in the Lahore study were specifically selected because they were visibly ill, showing “low milk yield, emaciation, and anorexia, intermittent diarrhea, not responding to anthelmintic treatment, irregular febrile episodes, and stubborn recurring mastitis.”
It is also reported that cow’s milk can become secondarily contaminated from ulcerating tuberculous lesions on the teats of cows, as well as from milk-handlers who have active tuberculosis. These are incredibly rare circumstances. Milk-handlers in all regions of the world are much more likely to have human tuberculosis than bovine tuberculosis.
Critical analysis would conclude that the transmission of bovine tuberculosis from milk to a human would only occur under a set of extremely uncommon circumstances:
• If the infection originated in the cow’s milk, the cow would need to have active tuberculosis in the udder (i.e., tuberculous mastitis—an extraordinarily rare form of the disease and not to be confused with common mastitis), or tuberculous ulcers on her teats. Both conditions would be apparent to a vigilant farmer.
• A farmer with tuberculosis could contaminate milk during handling, but the farmer would need to have active disease and would likely be noticeably sick.
• It is theoretically possible for an uninfected farmer to physically contaminate milk with secretions from an infected cow, but those secretions would only contain the bacteria if that cow had active lung or throat disease.
• It is theoretically possible for milk to be contaminated in the dairy parlor from airborne particles originating from a cow with active tuberculosis, from either the cow being milked or from one that had distributed infected secretions in the parlor in the past.
• And theoretically it is possible for tubercle bacteria from a cow with intestinal tuberculosis shedding into manure to be the source of fecal contamination in milk.
All these circumstances are extremely unlikely, and to my knowledge not one of these theoretical cases has ever been documented. And finally, in all of these cases, the humans who ingested the infected or contaminated milk would develop tuberculosis in the mouth or neck lymph nodes, or in the intestine, not in the lungs.
I am unaware of any rigorous study that has shown that the infection of bovine tuberculosis in people in any region of the world can be traced to ingestion of infected milk. Furthermore, in regions where herd infection is widespread, the few reports of human infections with bovine tuberculosis do not describe lesions that would be associated with ingestion of milk. In a contemporary analysis in the United Kingdom, thorough clinical examinations were performed on 138 people who had close contact with herds infected with bovine tuberculosis or who drank raw milk from those herds. No cases of bovine tuberculosis were found in these people.

E Coli 157 – there is some concern in medical circles in America that administering Antibiotics to people suffering from E coli is actually causing their bodies to shut down and die not the E Coli itself

Industry Concerns

If there was an outbreak of raw milk pathogen infection via raw milk consumption in New Zealand surely like would happen in other countries Fonterra would reassure the international community by stating that all their export milk is pasteurised and therefore not affected. It is difficult to see that this would affect the export of product internationally.

Susan Galea

Stephen Zanetti

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

Viryam Robertson

I have been a Registered Nurse for 20 years, my father Tom Robertson spent most of his working life as a scientist working for MAF (lastly as the Director of Biometrics), and I am very familiar with issues of community health and food security. I have also studied nutrition, and traditional Indian lifestyle medicine of Ayurveda, which has advocated the drinking of raw milk for about as long as history has been recorded.
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.

Viryam Robertson

This submission was compiled by:  Wellington Chapter of the Weston A Price Foundation.