Submissions to MPI – July 2014

These were our submissions to The Ministry for Primary Industries (MPI) on proposed options for the sale of raw milk to consumers back in- July 2014.

The Ministry for Primary Industries (MPI) was seeking public submissions on a consultation document that outlines options for the future sale of raw milk to consumers.

The consultation document can be found here

The closing date for submissions was Tuesday 8 July 2014.

If you would like your submission to be included on this page, please send us a copy to wapf@frot.co.nz

The NZ Ministry of Primary Industries, and their subsidiary NZ Food Safety, have recently replied to those of us who sent in submissions for their Nov, 2011 discussion paper, “Proposals for continuing to legally provide for farm gate sales of raw drinking milk”.

Unlike in many other countries raw milk is NOT currently allowed to be sold in NZ shops.

It took MPI/NZFS almost a full year to reply to the submissions they received in Nov 2011.

A summary of the submissions was posted on the MPI website here

In July 2014, their policy options for the sale of raw milk to consumers, despite the apparent encouraging initial response of Dec 2012, were NOT very favourable for the growing urban consumer population.

“The Ministry for Primary Industries invites all interested parties to make written submissions on the issues raised and options presented in this consultation
document. MPI is particularly interested in receiving feedback on the practical implementation of each option.”

We understand that the raw milk supply farms are operating very hygienically but they are often under the MPI/NZFS radar, so please keep details of your supplier anonymous or your supply could suddenly be stopped altogether!

Thanks for taking the time to send in your submissions.

Back in 2011 we got a selection of submissions and posted them here

2014 Submissions on Proposed options for the sale of raw milk to consumers

If you would like your submission to be included on this page, please send us a copy to wapf@frot.co.nz

Cedric Backhouse

Cory Gully

Deb Gully

Ian Gregson

James Bellamy

John Martin

Karyn Redfern

Rachel Rose

Raw Milk Producers Association of New Zealand

Stephen Blackheath

Susan Galea

Wellington Chapter of the Weston A Price Foundation

Cedric Backhouse

I disagree with Section 2 – the assumption that milk produced for human consumption by raw milk producers is automatically of a higher risk is not borne out by my experience. The paper on the risks associated with raw milk depends on 80 samples from Fonterra supply of unknown (to me) origin probably ordinary factory supply milk and not destined for human consumption as raw. The paper also uses simulation and modelling and I do not consider that is a suitable mode of appraisal as it is totally ignoring the experience of New Zealand raw milk drinkers.

Section 3 The Problem The real world situation seems to indicate different outcomes with many people reporting increased health benefits such as disappearance of Exzma from young infants fed raw milk, when they were previously very ill due to pasteurised milk of all shapes and sizes and types. There is a Massey study into this and maybe that should be available before any decisions are made in New Zealand on regulations and restrictions on availability of raw milk specifically harvested for human consumption.

I grew up on a dairy farm in the 1950’s and always drank raw milk and I am now in my 60’s and still had no cause for concern. My two sons were also brought up on raw milk exclusively and one of them had a severe congenital heart condition from which he nearly died. He is in the best of health now and plays soccer and he swears that raw milk is one of the reasons for his good health. The other son is now a city dweller and continues to obtain raw milk at great effort because he knows the truth about the effect it has on his health. He spent some time in Korea where he was plagued with stomach problems , but on his return he drank raw milk again and improved immediately. My wife has been to India and contracted a severe bout of food poisoning, on return to New Zealand with no other intervention but raw milk and raw milk kefir returned very quickly to full bowel health.

In Section 3 it is also noted that nutritional value is not changed by pasteurisation. There are many studies that show the denaturing of the proteins and enzymes and an increase in allergic and histamine effect of pasteurised milk far outweighing the benefits of destroying what, with good methods of harvesting would be a minute amount of pathogenic material in the milk.

What is also ignored in the pasteurised milk is the possible contamination by GE, pesticides, hormones and other like melamine that will be in the milk delivered to any factory in New Zealand if it is not Organic. These substances all have risks associated with them for human health. Some may take much longer to reveal themselves but are definitely present and likely to affect milk drinkers. Until this is cleaned up by promoting more Organic milk in New Zealand MPI should not try and dictate terms to raw milk producers who are Organic.

Section 6 Background. Shiga toxin and some other pathogens are not destroyed by pasteurisation and in fact some pathogens like listeria are introduced by pasteurisation or processing facilities. There have been major concerns internationally due to the botulism scare in pasteurised product, this was not just a case in Fonterra product but has also been found elsewhere in the world.

Section 7.3 Considering the huge demand for raw milk and the many new consumers in New Zealand in the last few years the cases that have occurred that can be demonstrated to be directly associated with raw milk are really very insignificant as to be just by chance. These figures as MPI suggests should be getting huge, like 10 times increases per year, but they are not. Also MPI includes data (unverifiable by us mere citizens) that is about factory produced milk to be sent to be pasteurised and in workers on farms who should be much more aware of the illnesses of the cows around them and according to MPI not so immune depressed.

The outbreak in Timaru was not directly linked to the dispensing machine herd and in fact at the time other town water drinkers were getting sick too who did not drink the raw milk, and yet this is being used as a raw milk outbreak and apparently the health department have been instructed to link as many cases of illness as they can to raw milk with no proof and with protestations from the subjects who know that the cause is dirty public pools or water or just other food.

Section 8.2 Certain international cases have been totally omitted from the document. There are many millions of people who drink raw milk in the third world countries. Of course they have illnesses as well but we can be certain that if they thought that raw milk was the culprit they would be welcoming Fonterra with open arms and they are not. In fact reconstituting milk from milk powder in those countries would give them a really outrageous risk due to the contamination of the water itself. They have micro dairies which provide most of the milk to the people for a very reasonable price often with no refrigeration or filtration processes. Some people from these countries now live in New Zealand and they are demanding access to the same milk they grew up on and they cannot understand the worry about the temperature of the milk. They know that the best way to consume raw milk is to sour it naturally to a yoghurt and then to a cheese which enable the digestive system to assimilate it more easily in to the human body. Logically the science states that campylobacter reduces with time, and listeria increases even in the cold so how will keeping it cool help even if these pathogens are present. It has been found that the warmer the milk is the more chance the listeria is destroyed by other things in the milk like listeria innocua.

Section 10 Options I do not agree with the Options proposed by the MPI document. Restrictions on the sale of other foods are not imposed such as fast food restaurants. An individual consumer can go to a fast food restaurant and eat as many hamburgers as they want to. This is safe? These consumers are not informed at the door by a sign or label that to eat in this or that restaurant can endanger their health due to Campylobacter or similar pathogens or past performance of such an eating/food place.

Instead I believe that with a safe handling and harvesting regime in place any amount of raw milk should be made available in any way that suits the farmer/consumer network. It could be said that some farmers may want to reduce competition and agree with what MPI is proposing, so that some farmers are forced to drop out as MPI suggests may happen. I, however, for the sake of consumer’s health, would prefer that there is competition and that lots more safe raw milk is available. This would preferably be produced from small certified Organic farms so that other potential contaminants mentioned earlier are not in that milk.

Section 11 Detail of proposed requirements – I disagree with MPI’s proposal that only delivery to consumer’s private homes should be allowed. I wonder why any monitoring is necessary with such a perfect product. The temperature is not an issue if it is the consumer will be on the spot to collect if they know the ETA as a usual occurrence. Other potentially harmful foods are not monitored all the way home from where they are purchased so why is it necessary to regulate this for this food?

I do not consider that MPI needs to know every raw milk producer. It should be up to the consumer’s choice to determine what they are doing to their own bodies as it is with drugs, legal highs and alcohol. Furthermore we do not limit the choice of consumers to go to certain stalls in a farmers market to buy the produce that they determine to be best for themselves. People are allowed to make mistakes and learn from them in terms of sugar, white flours and so on. Sugar has now been deemed to be a poison and to be avoided. MPI should do something about that first. The science about fats and sugars has done an about face in the last few years and maybe the same will be found with raw milk produced for human consumption. Perhaps MPI need to promote some experimental science relating raw milk drinkers to the facts of their health or illness rather than using data derived from milk production not intended for raw consumption.

I think that performance based results should be taken into account when determining the amount of testing to be performed. Once a consistent record for APC and Coliform count has been established by a producer, MPI should accept once a month random testing to confirm continuing low levels. Pathogen testing also once a month should be acceptable. The pathogens should be determined carefully to be those that are found only in the conditions that the farm is farming in. E.g. e coli 157 testing is unnecessary unless a herd home is being utilised. The test results should be made available to consumers.

Similarly farmer competence and experience should be taken into account with regard to training requirements, auditing, vet visits and other inspections. Higher standards of handling and harvesting of raw milk for direct to human consumption should be normal procedure for the farmer including farming organically i.e. healthy soils, pastures and animals. Dairy shed cleanliness, actual milking procedures (refer NZCP1), bottling or bulk dispensing and on farm storage of raw milk for human consumption combined with an acceptable level of milk test results should satisfy MPI on food safety issues.

My experience with various raw milk producers indicates that there is little to no risk that can be attributed to this product.

Cedric Backhouse

Cory Gully

I have been consuming raw milk for about three years for its health and nutrition benefits. I own a herdshare and pick my milk up from a drop off point. As I don’t have a car, I want to keep doing that.

Your discussion document fails to differentiate between:

Milk that is intended to be consumed raw, and has been carefully produced to be safe and nutritious, and
Milk that is intended to be pasteurised, so doesn’t have the same care taken

I believe that the legislation needs to distinguish between them, and the primary objective of the legislation should be to protect the public from the possible dangers of Type 2, while giving free access to Type 1.

For milk that is intended to be consumed raw, minimal legislation is needed. I would want to see:

The guidelines set by the RMPANZ (rather than law) which might include:

How the animals should be raised, housed and fed – outside in fresh air, in the sun, being mainly fed grass

Required testing and veterinary care

Hygiene practices for harvesting the milk

How milk is stored and transported

Educational material made available to customers

Subject to there being a direct relationship between the farmer and the consumer, if a farmer is certified by the RMPANZ as having met their guidelines, they should be free to:

Take orders in person or online

Sell as much milk as they have available To whomever they want to At whatever location is suitable for them both: The farm, Farmers markets, The customers own home, or A central drop off point for each area

Be paid however they choose, including online banking or cash collected at the drop off

Keep records only to the level required for taxation purposesMilk that is intended to be pasteurised, and doesn’t meet the RMPANZ guidelines, does need to have more stringent legislation. This is the milk that could potentially (but, even then, not necessarily) cause illness. The minimum legislation for this type of milk would be that display notices should be up at the point of sale, explaining that the milk is intended to be pasteurised, and what risks the buyer would be subject to.

Cory Gully

Deb Gully

This discussion paper appears to be based on the assumption that raw milk is inherently dangerous and needs to be regulated to within an inch of its life to protect people. This is a biased premise, based on the assumption that because milk has been pasteurized for approximately 100 years, that must mean it needs to be.

For centuries, people consumed only raw milk and when it went sour, they still safely consumed the clabber. Pasteurisation was brought in when cows were brought into cities and kept in unsuitable, unsanitary conditions. Then it did become dangerous.

Raw milk is inherently safe if it is:

From healthy cows, kept in suitable conditions (outside, in the sunshine, feeding mainly on grass) and given appropriate care when needed
Which leads to the milk being much higher in nutrients, including those that combat toxins
And harvested in a hygienic way, with the intent that it will be consumed raw

It becomes dangerous when:

It comes from cows that do not have a suitable lifestyle eg factory farming, not being outside in the sun, or not being mainly grass fed
And / or the milk is harvested with the intent that is will be pasteurized, so the same stringent care isn’t taken

So in answer to Q1, no, I do not agree that the principal problem is that drinking raw milk is causing some people to get sick, especially infants and young children, and that this incidence is rising. Rather, the problem is four-fold:

The current regulation is over restrictive, and restricts peoples freedom of choice
Your apparent desire, in this instance, to be over-protective of people’s health –– leading to proposed regulation which is still over restrictive
Underlying both of the above, the failure to differentiate between high quality raw milk (usually safe) and poor quality raw milk (potentially, though still not necessarily, dangerous)
The tendency to blame raw milk for any illness, without testing either the milk or other possible sources. This is leading to increased numbers of reported illness where raw milk MAY BE a risk factor, without any proof. This possible correlation (which is rising as more people drink raw milk) is then used to substantiate your claim that illness from raw milk is increasing.

Your job is to protect people from the poor quality milk while allowing freedom of choice. The solutions are:

Allow the RMPANZ to set the guidelines for safe practices, which will ensure high quality raw milk. Membership of the association would be subject to following their guidelines, which might include:
1. How the animals should be raised, housed and fed
2. Required testing and veterinary care
3. Hygiene practices for harvesting the milk
4. How milk is stored and transported
5. Educational material made available to customers
Remove all restrictions on quantity (purchased or sold), and remove restrictions on where the farmer can sell to the customer. The only regulation I would suggest is that the customer buys directly from the farmer, rather than through shops. That way they have a relationship with the farmer. If the farmer is a member of the RMPANZ, they know they are following suitable guidelines. If they are not members, then it is the buyer’s responsibility to check the farmers practices themselves.
Allow people their freedom of choice in what they buy – in the same way that people can choose to buy alcohol, cigarettes, sugar, and many other substances that are much more harmful than raw milk.

Over regulation in this area will only drive the whole market back underground. There are two main disadvantages to raw milk being part of an underground economy:

First is that people might be so desperate to get their raw milk that they will buy from whoever they can get it from, including the unsafe sources as previously discussed. Loosening the regulations will enable people to easily find a certified source. But many of the measures in this discussion paper will unnecessarily make the regulations too onerous, and difficult to comply with.
Loss of government revenue from tax

If the above simple yet effective measures were followed, there would be no need to answer each of your questions in detail, however I would like to comment on some of them anyway.

Questions

Q2. My objective is to see everybody who wants raw milk to be able to easily buy raw milk that is nutritious, safe and intended for consumption raw. I do not want to see the market go back underground, as that is what puts people at risk. Although it isn’t on the list of objectives, you have openly stated in other parts of the document that one of your objectives is to stop the increase in consumption of raw milk. Please remember that you (MPI) work for us (the citizens of NZ), and restricting our freedom of choice for no good reason is not acceptable.

Q7. Members of my household (all adults) consume raw milk, and have done so for about 10 years. None of us are pregnant or with low immunity.
Q8. I want to buy raw milk as pasteurized milk is associated with many chronic illnesses, and raw milk is not. Raw milk is also more nutritious and easier to digest.
Q10. We wouldn’t usually buy more than 5-6 litres per week, but would like the option to buy as much as needed, when needed.
Q11 & 12. I live in an urban area, and milk is delivered to me.

Q13-15. Covered in my overview above

Q18. Evidence of effects on raw milk of pasteurising see www.raw-milk-fact.com . At least the enzyme that enable people to absorb the calcium in the milk is destroyed also the histamines are released into the milk. Pasteurised milk needs to be standardised to be labelled and sold in New Zealand. That results in manipulation of milk solids in the milk, which is nothing like raw unadulterated milk.

Q19. I agree with not pursuing a total ban. I agree with no sales at retail outlets because I support sales direct from farmer to consumer for reasons stated above. But farmers markets could still be a suitable outlet, as the farmers could display educational material, and their certification by the RMPANZ. (Or the milk could be pre ordered to stop opportunistic sales, though I personally don’t think that is necessary).

Q21. For all Options: New Zealand’s reputation as a supplier of safe food has been detrimentally affected by the Fonterra scares of the last few years. We do not believe that raw milk (which is a very specific food for NZ consumption only) would jeopardise our reputation even if there are outbreaks.

Q22. A combination of Option 1 for small farms and Option 3 for larger herds (especially if they are also supplying for pasteurization) could be suitable, subject to the following:

Requiring detailed sales records to be kept for 4 years is unacceptable – no other food requires such records to be kept
Home delivery should be extended to delivery to a depot or other place designated by the customer. The current practice of dropping off to central locations where customers can pick up at their convenience works well, and needs to be able to be continued. If the perceived problem with this is just a matter of temperature of the milk, surely this is better, as there would be less collection points to monitor than private addresses. If it is a private area that the milk is dropped to, only authorised people will know of it and so only preordering people will collect. Temperature is easily kept low in chilly bins or fridges and can be monitored with electronic equipment if necessary.

Q23 It is yet to be proved that outbreaks of illnesses are definitely associated with raw milk. So how can anyone demonstrate that any of these regimes will reduce it?

Q25. As a minimum yes.
Q26. There is very little TB in milk so 5 years should be plenty; there is even doubt as to whether Bovine TB can be transferred in this way to humans.
Q27. No

Q28. Yes.

Q30. Yes, of course. Proper hygiene indicators should be used and it must be grass fed. Also the ways it is produced should be superior. (Ideally, it should be a superior food in other ways, e.g. GE free, Organic and higher in nutrients).
Q31. Yes, and then be treated the same in terms of sales. Other dairy products do not require consumer’s details to be kept for 4 years or delivery to their homes.

Q32. It should not be necessary if a recognised laboratory is used for the milk testing.
Q34. The reward for good performance is loyal consumers. So recognition is not necessary, but less frequent testing might be appropriate.

Q37. Labelling is one option. But less onerous, and still suitable would be notices up at the farm and point of sale, newsletters, and information pack when first becoming a customer.
Q38. No – other foods do not have that information on it or near it.
Q39. No
Q40. No
Q41. No
Q42. See above

Q45. Any Raw milk advocacy group, such as NZARM

Deb Gully – Certified Natural Health Practitioner

Ian Gregson

In my previous submission in November 2011, I provided details of my own raw milk consumption and the health benefits I have gained from it.

Knowing the large number (1685, of which 1561 supported the sale of raw milk) submissions that the MPI received in 2011, I was surprised by some of the suggestions that the MPI have come up with in the discussion paper.

It seems to come from a starting point of incorrectly assuming, with no evidence to back this position up, that raw milk is inherently dangerous and needs to be strictly regulated.

What I want to see is new regulations set by the Raw Milk Producers Association (RMPANZ). These are the people who understand raw milk production and know how to design effective regulations.

A critical change required to make any legislation effective is the removal of all restrictions on quantities (both purchased and sold), and removal of all restrictions on where the farmer can sell to the customer.

Oppressive regulations and any additional unworkable bureaucracy like keeping long term customer records, will only drive the entire market further underground, and potentially result in lower hygiene standards.

Here is the content from my 2011 submission that covered my personal background and the points I still want to make:

I am a nutritional supplement retailer www.naturefoods.co.nz and representative of the Weston A Price Foundation, I have been studying nutrition and natural therapies for over 12 years and have overcome a serious health problem (3.5cm brain tumour diagnosed in 2002) 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. I consider raw milk an essential health food, but would never consume pasteurised 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 pasteurised 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 barely had a single cold or flu – I generally just don’t catch those things even if exposed to them. When I used to drink pasteurised milk I “caught” a cold about once a month.

I would like to be able to buy raw milk in health food shops, in cafes, from chilled vending machines, and directly from farms, but mainly to have it delivered straight from the farm to urban collection points.

I drink 3.5 litres a week myself, so obviously I don’t think there should be any restrictions on quantity. I know people personally who drink over 6 litres a week, so I regard 5 or 6l pick up 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 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 after 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.

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 anomaly in that respect, and according to WHO statistics, NZ has the worst overall health ranking of any first world country.

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 The Ministry for Primary Industries 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 generates even more unworkable regulations, it will push the whole trade in raw milk further underground and reduce the safety standards.

Either way raw milk sales will continue to increase. Ironically, with each call for submissions, the MPI triggers a further 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 committee 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 far better than here in NZ.

NZ made raw cheeses currently rival the quality of many top French and Swiss chesses which sell here 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.

Ian Gregson

James Bellamy

http://issuu.com/jamesbellamy1/docs/government_raw_milk_review/0

John Martin

First of all, let me say that I am a vendor of raw milk.

I have read the document front to back 5 times. This has given me a good overview of options, where MPI is heading, how it relates to me and what I feel is the influence that opponents have to date been advancing.

The strongest impression I get of the background is concern by the Health people about what they profess ‘could’ happen, the cost to the country if somebody is off work because they are sick and the dairy companies who advance the spurious argument about NZ’s overseas reputation. My god, Fonterra should talk! And I am a Fonterra supplier; I have every intention of remaining so because I believe in the co-operative principle.

New Zealand’s reputation “‘should there be major illness outbreak”

If I was wanting to sell you something to consume and telling you it was good for you the first question you would ask is, “Do you consume it yourself?” The answer to that from the dairy company perspective – always assuming of course that they are being overtly frank – would be, “Oh no, we don’t trust it, we have to pasteurise it because it will contain pathogens which will make you sick.”

I drink raw milk, have done so for the whole of my life, my mother drank it before, during and after her pregnancies, my wife did the same so I have faith in my product; it’s a pity of huge magnitude that the dairy companies can’t also have the same faith – though one must accept that they have to contend with a broad range of quality issues; I will address that issue further on.

Any milk related illness – and one must remember that milk will always get the blame regardless of whether it is responsible or not – will be of no consequence to anybody other than the media who will want to create a story.

NZ’s reputation is far more in danger from what can come in from overseas via travellers or importers; I respect the dedication and efforts of our biosecurity officials in that regard. Any raw milk related illness will be small and isolated and internationally of no consequence whatsoever. Because the circumstances are totally different to any exported milk product the argument that NZ’s reputation is at stake or will be affected is ‘stretching reality.’

should be encouraged.

I would have thought that with the build-up of resistance to antibiotics that the Health Department would be wanting in increase people’s immunity, not promoting more of the same which has led to reduced immunity Already we read of people dying of seemingly insignificant illnesses when they have no ‘underlying health issues.’ That is only going to

Dairy companies – because 90% of N Z’s milk is manufactured into a product which will last so that it can sustain the time lag between harvest and sale – operate under an entirely different situation to raw milk sales and to claim that there is a relationship between the two is spurious

Health issues

The Health professionals will say it should not be allowed because it contains pathogens that will make you sick and the only way to make it safe is to heat treat it.

Unfortunately they have for years been promoting that attitude and that has led to urban folk having less than a fifth of natural immunity to rural pathogens. We can’t do anything about those pathogens – they are ubiquitous and we have to live with them. That raises a simple question: should we live in a metaphorical glasshouse of sanitation with the result that we become over-sanitised with no resistance or should we endeavour to keep our immunity up? The child in the sandpit deciding whether to eat the worm or not is actually doing itself a huge favour – think of the dirt and pathogens it is consuming! If the consumption of raw milk helps to keep one’s immunity up then rather than being denigrated it become more common.They don’t tell us how many hospital wards keep getting closed because of an outbreak of something that is difficult to control! And they don’t tell us about the wrong drug prescribing which goes on! I have had a hip replacement and the official line now is that before a visit to the dentist I should have an antibiotic (which I have never taken) and when the dentist was espousing the reasons for the antibiotic I asked him, “What about the probiotic?” He said to me, “What’s that?”

We read how there is an obesity epidemic and they keep trotting out the low fat high carb drivel; none of the people getting my high fat milk are overweight!

We also have a diabetes concern. If you have diabetes the first thing a doctor in this country will do is to put you on statins but they don’t tell you about the registered side-effects of statins: loss of mental acuity and diabetes; doesn’t occur in every case of course but often enough for CDC to be forced to admit to them as significant matters. I presume that you are aware that CDC doesn’t do any testing of its own – it only reviews the data supplied to it by the manufacturer and that data can be ‘massaged’ so that the drug gets approved. It took CDC 2 years of pressure before they finally admitted to the two aforementioned side –effects to statins, a drug that has made more billions for the drug company than any drug that has ever been developed.

You may feel I am digressing and none of this is of real relevance to raw milk sales; I beg to differ. If the health people are going to endeavour to dominate an attitude towards raw milk then they should be held to account over some of their activities and that is why they get mentioned; they should not be allowed to pontificate with impunity when some of our present health issues can be claimed to have been created by them.

In NZ prescription drug use is increasing at around 6% a year in most Health Board areas.

A child born in 2000 has a 1 in 3 chance of developing diabetes.

In 2006 – 2007 there were 1.125 million prescriptions written out for depression – the mind boggles!

New registrations for cancer increased 21.2% from 1995 to 2004.

Are we getting healthier? Are we getting fitter? It can be argued that we are living longer – statistically that is correct but in reality it could be argued that we are being kept alive by modern drugs; heart ailments are occurring as often as they ever were. Mankind has been living into his 70’s and beyond for hundreds of years!

Have you ever read any of Bill Bryson? If not I recommend him. I particularly refer to “I’m a Stranger Here Myself” – notes on returning to America after 20 years. In it there is one chapter entitled “Drug Use.” where he describes the extent of drug advertisement with the result that people go to the doctor and say, “I want …… for this condition. Are we not seeing exactly the same type of thing occurring in NZ?

Every night on T V- at least every night that I was watching – there is the Health Diary and for a while we had the attractive Jude Dobson sitting very properly in her chair with her hands neatly folded on her lap introducing some item and it was followed by, “Have you got …..? You could need…… Ask your doctor if .… is right for you.” How often do we get a pamphlet/booklet advertising pills for various conditions through the mail or dropping out of the Listener?

If prescription drugs were as great an answer as they are claimed to be – and there is no doubt some are very useful – then America would have the best health of any nation in the world but the average Cuban lives longer than the average American. Spare a thought for the thousands of unfortunate American children who have their minds all addled because of Ritalin.

And we are expected to just accept without question some of the utterances from the health people? Sir Brian Barrett-Boyes didn’t eat egg yolk because it was high in cholesterol – and that’s another myth; it’s a symptom of a problem, not a cause of one.. One has the utmost respect for Sir Brian’s dedication to surgery and his competence but that doesn’t mean to say that his attitudes were always right and in his attitude to egg yolk he was well astray.

It is interesting to note that Selfridges in London put in a raw milk vending machine and the howls from the health professionals were identical to what we hear in NZ. I presume the machine is still there; perhaps Selfridges are just too big to hammer with emotion when all that is happening is that the people are making an individual choice of whether to use the product or not. It will be a sad day when people are denied the opportunity to make choices of their own – just look around the world and be grateful for the fact that we live in NZ.

This issue of availability of raw milk is about choice: the option for people to make their decision for themselves versus being frightened out of being able to make a free choice by industry segments that are desperate not to lose their dominating position..

Now that I’ve had my introductory spiel I hope I’ve made my position relatively clear and will now address the questions in your discussion document. I am in no doubt though that there do have to be standards, there do have to be guidelines, there do have to be protocols; it’s a matter of finding the right balance.

Question 1

Are you sure that poor animal health and hygiene is being practised by the farmers selling raw milk? The answer to that is critical because you certainly come across as having a belief that such is so and I am not convinced that such is so. I am very conscious of the need for good practices. I know – as a dairy farmer myself – that there are some farmers who don’t have the necessary empathy with quality controls that are necessary surrounding raw milk sales and there is no place for them whatsoever!

5 The objectives

Reduce illness from the consumption of raw milk. People are going to get sick from many causes and to pick on raw milk as a substantial culprit is totally unfair. “Oh but illness is a cost to the taxpayer!” What about smoking and alcohol and bad driving. And that’s all legal!

Protect New Zealand’s reputation as a supplier of safe food. We don’t export raw milk! We are allowing our own people to make choices for themselves, we are showing that we have faith in our own product, to claim that NZ’s reputation is at stake is the biggest load of spin doctor imaginable.

7.1.1 Food Act 1981

You give reasons around raw milk availability scenarios at that time. Don’t forget that at that time of history penicillin was still a wonder drug of unparalleled efficiency and the scientists and doctors who had access to other drugs which were coming on to the market gave us to believe that the new modern way which they knew about would reap all things wonderful for us and we were on the verge of health scenarios from which we would never look back.

There is no doubt that we have gained a lot over the last 50 years from improved hygiene , sanitation and drugs but there are also losses: loss of immunity to some of nature’s pathogens and the fact that the bacteria which we were able to dominate are now fighting back.

Question 3

I only know that there are a lot of vendors and their volume varies depending on the number of cows they have.

Question 4

I am a current vendor.

Question 5

I deliver to depots and people collect from there.

I make three deliveries a week going to a third of the depots each delivery day – I only go to each depot once a week.

Averaging out the total volume supplied over the number of customers the amount per household would be 5 litres; but – of course – per household it varies from 1 litre to 20 litres.

1 litre – $3.20, 2 litres – $6, 10& 20 litre pail – $2.50.. litre

Getting five enquiries a week is not unusual but not all continue to purchase.

Questions 13 -15

Though I accept that there has been an effort to provide open and neutral questions the fact remains that they have a bias that raw milk is a grade 3 hazardous substance; I note that wording has not been used in this discussion paper unlike its wide use in the previous submission process but the feeling is still there.

One-off cases

…particularly in the case of food with a short shelf life.

As milk ages it doesn’t rot like pasteurised milk it merely goes sour. Still perfectly safe to drink but we N Z’ers don’t like the taste unlike some Europeans who let it sour deliberately. And, as raw milk ages campylobacter reduces – once again, unlike pasteurised milk. Provided the fridge is working properly raw milk will stay sweet for 12 days easily but I wouldn’t go anywhere near chicken of that age. In my experience when milk doesn’t last the answer is always with the fridge temperature. That being so raw milk can be regarded as ‘the canary down the mineshaft’ because other foods too (delicatessen meats and chicken for example) will be being affected and – of course – you won’t know. But raw milk will get the blame!

Studies have been done of fridge temperature and they have shown that during the weekend when the teenage boys are home and always going to the fridge to see what there is to eat they can have the door open so often that there is no cold air left so that highlights the value of having raw milk as a ‘canary.’

International approaches

My wife and I follow the dietary guidelines of the Weston Price Foundation – WAPF and one of their aims is the increased availability of raw milk. Needless to say CDC is vehemently opposed.. If a fraction of the reportings of CDC activities, with the result that law enforcement officers act, are to be believed then we should be very grateful we live in NZ. – at least we don’t have armed raids on raw milk producers and I am 100% confident in saying that won’t happen here.

There is a major difference between NZ farming practices and overseas practices; NZ cows are outside all year grazing grass in the paddock though I do concede that is changing in some areas with herd homes and stand-off feed pads. In my opinion there is no doubt that concentration of cows in a confined area for a length of time leads to greater udder contamination so providing raw milk from those cows would require greater attention to pre-milking techniques. Equally having a herd in a herd home means that the cows are not in direct sunlight and that is also a concern to me as I feel that the role of the sun in animal health can be severely underestimated. It might be a radical thing to suggest but perhaps raw milk from cows not grazing outside all year should not be permitted

Questions 19 & 20

It is a fact that raw milk sales will increase – if not legally then a blackmarket will develop and monitoring compliance will be ridiculously expensive. Do you remember the days when roadside stalls could only sell the produce grown on the property? It was ignored to such an extent that the rules had to be changed to come into line with reality.

However my opinion is that – at the moment – N Z is not ready for sale at retail outlets and/or farmers markets. One day that may be the case but before then the general public will need to upskill itself on knowledge about differences between raw and pasteurised milk with consequent home management techniques.

The public also has to come to grips with reality about germs – germs that have always been with us and will continue to be with us; a study has shown that there are more bugs on the keyboard than there are on the toilet seat and what about the infatuation with cellphones?; I’ve for a long time had this sort of thing in my mind and smiled when I read the front page of DomPost on Thursday 26th June – ironical timing!

Regardless of what guidelines we might be given on sanitation the question of what we do about bugs on the likes of cellphones and keyboards is not going to be solved by disinfectants – we are far better to live with them and ensure that our gut is populated with beneficial bacteria. On the same day the Dompost has an article on the cost to the country from obesity and diabetes and the involvement of sugary drinks; that is a problem of significant relevance and on a scale of relativity with those issues I would suggest any claimed raw milk illnesses don’t even rate! We also read in the same article that on a BMI rating Richie McCaw is obese!

Options under consideration

I will only address option 3 as that is the one that directly affects me. I’m not saying that other options should be discarded or eliminated – it’s just that option 3 is of the most relevance to me and I am leaving discussion of the other two options to those directly affected.

To endeavour to make it home delivery only and not to a collection depot is idiotic and not at all well researched – on first read it seems to me as though it is an underhand way of cutting down availability to the wider public: a way of denying the public a chance to make a decision for themselves. The benefits of a continuation of that scheme are:

The milk can be pre-ordered and paid for.

* It is an easy way to ensure chilling is maintained till the person collects. How will that be achieved with home delivery if the recipient is not at home?

Because of the pre-ordering and necessary list of who gets what at each depot records are available.

It is time and fuel efficient for the recipient

The only persons getting the milk are those who have made a conscious decision to have it – freedom of choice in other words.

Of course the milk has to be kept chilled while on transport so a chiller van is required for when volumes grow – that is already happening and delivery to a depot where there is an investment in chilling facilities by the vendor is ‘a given.’ If chilling from harvest to pickup is the major concern – as it should be – then that is the best way to go. Small volumes from small vendors will be able to manage chilling requirements satisfactorily in ways other than having to have a chiller van. But what about the lack of chilling from pickup to home? Is that any different to anything else – supermarket chicken or delicatessen meats for example? A lot of people I have seen collecting come with a ‘cold carry bag.’

Questions 30 & 31

I agree that raw milk intended for consumption should be of a higher quality standard than can be accepted for milk intended for pasteurised milk products if milk intended for pasteurisation would incur financial penalties as determined by dairy company standards – note my change of wording to what you have written.

There is no doubt that regular testing of milk does ensure compliance with standards but testing should not be over and above dairy company testing if that testing provides an answer. E.g Fonterra tests daily for somatics, antibiotics and regularly tests for other things, as – I presume – do the other 25 dairy companies in N Z. Perhaps though putting into the testing regime a numerical value for Bactoscan could be considered; Fonterra only gives a value range: A+, A, etc so providing a numerical test would be more enlightening.

Questions 37 – 43

Labelling bottles is ridiculous and unnecessary – you see it in supermarkets but people judge what they want by the colour of the bottle top and the biggest wording is the name of the supplying company – advertising. Raw milk vendors are not into that sort of advertising; they can do it at a milk dispensing location or via a website. If done at the website before the public have even got around to considering ordering they have seen the information and have made a conscious decision to proceed – opportunism doesn’t arise like that. They can’t accidently pick it up from – say – a fridge in the store because ‘they didn’t realise’ – it won’t have a barcode so won’t get past the checkout!

I agree that there should be information provided in some form of labelling – in my case at the depot – and that would avoid any member of the public mistaking raw milk for pasteurised milk; hypothesising – once again – for example, that the depot was a fridge in a retail store. If the depot was only a house there could conceivably be an opportunist so provided information would not be silly.

Because people now don’t really read provided information – any wording should be minimal while still saying what needs to be said and should probably be of a ‘reasonable’ font size – people don’t read the small print!! That will limit what information can be provided. But referring back to the website, all information can be provided because people will then read it.

Some concluding thoughts

The document mentions somewhere about discarding the milk after 4 days. Nothing could be more ridiculous and unnecessary. I’ve had people take it away on holiday and it has still been good at 12 days. Some Europeans leave it out to go sour and then consume it. And – of course – I’ve already talked about ‘the canary down the mineshaft.’

Personally I like it to be at least 4 days old so that by then the cream has risen to the top and it can then be used for the plate of rolled oats at breakfast – very rich milk, a mixture of coarse and medium ground rolled oats cooked on a stove, no sugar and a resulting energy level till 1o’clock in the afternoon. You won’t get that sort of energy from highly refined porridge, or cornflakes which are devoid of any useful nutrient, or sugar laden cereals like CoCo Pops with advertisement aimed at the children in order to create sales,

Likewise Weetbix and/or the low density bread we have today which has to be spread with margarine – which is one molecule away from plastic – because if something very soft is not used the bread will just collapse.

TB: I believe that C5 should be an absolute minimum.

Conclusion.

There has to be standards, they have to be able to be monitored by regular testing but at the same time there has to be a balance between total idealism and reality. The reality is that good standards can be achieved and I fervently believe that if you look at what is being achieved instead of thinking that what is happening around milk that has to be processed to make it safe then you will be heading in the right direction; that won’t satisfy the health gurus of course but theirs is only one opinion.

Though I don’t agree with all the expressed ideas in the discussion document I think MPI has done a well researched job in bringing issues forward and I am very appreciative of your efforts. As I said earlier, there is an expanding raw milk market, both nationally and internationally and – as a consequence – guidelines for a consistent and sensible approach need to be promulgated and modern.

John Martin

Karyn Redfern

Hello. I have been consuming raw milk on and off for a few years. Over this time it has become apparent to me that I can digest raw milk without problems but pasteurised and homogenised milk causes fatigue and digestive issues for me.

I believe it is not necessary for many with a sensitivity to milk to be dairy free as raw milk contains the enzymes necessary to digest the lactose sugar in the milk but pasteurised and homogenised milk has had these enzymes destroyed through heat.

Bacteria exist in a balance in most ecologies and infection arises when certain bacterias dominate over others. Milk has beneficial bacteria in balance with other bacterias that are unhelpful when they proliferate. Heating of milk destroys all bacteria. The resultant milk has no beneficial bacteria to keep potentially dangerous bacteria from multiplying and thus renders processed milk more vulnerable to infections.

Sources of food poisoning are interpreted from a biased point of view that assumes wrongly that pasteurised/homogenised milk is protective when it is actually less protective over the life of the product given the above true science.

It is similar to antibiotics – their use is effective against all bacteria and so kills any harmful infection, but leaves the recipient more vulnerable to future infection as it has destroyed the balance of flora. The big difference between these situations is that raw milk that is processed from healthy cows in hygienic conditions is highly unlikely to be infected and antibiotics are only administered where infection is demonstrated!

Current laws have hindered access to raw milk and made them expensive and time consuming to obtain. I compromise my budget to continue to do so because of the massive health benefits of consuming raw milk.

Why we blindly follow the dictates of our ill informed NATO allies is bewildering when the entire EU and many other regions of the world continue to consume their staple milk raw. When will we stop thinking we can help mother nature along?

You know even the Queen of England (our sovereign still) consumes raw milk …if its good enough for royals its good for everyone.

Please no more restrictions with regard to milk. In fact, please do the research and support a move to legalise the sale of raw milk with the other similar hygiene standards that are applied currently to commercial milk distribution and you will have a far superior and safer product for consumption in NZ.

Karyn Redfern

Rachel Rose

I have purchased raw milk since 2010 when I moved to Whanganui and became aware that I could buy organic, local milk. Only with time did I come to appreciate the opportunity I had to consume raw milk. The availability of this milk is very much valued by me and many of my friends and neighbours. WIth the milk I make my own yoghurt, keffir and cultured butter, all foods that are a valuable, nutritious part of my diet. With what I now know about the industrial scale of conventional dairying in this country and its effects on our environment and the animals, I would choose not to eat or drink dairy if I could not buy raw milk from small farms who produce only raw milk.

I believe it is important to distinguish between raw milks. One is produced by farms — often organic, small and more diverse — who produce only raw milk and whose whole operation is geared toward producing milk that will not be pasteurised. This starts with breed selection and soil management, all the way through to procedures for milking and bottling the milk. I feel very safe drinking raw milk from such a farm and widely encourage others to investigate this option.

This is not at all the same as milk produced by conventional dairy farms supplying bulk product to Fonterra and other processors, who may keep some back to sell raw as a response to rising consumer demand. I myself would be very unlikely to buy milk from such a producer. I think public education about raw milk needs to point out the difference between these two types of farmers.

I find the current restrictions onerous and inconvenient and am entirely opposed to any new regulation that would make it harder for consumers to purchase raw milk or make it more difficult for family farms producing solely raw milk. Specifically, I wish to see the maximum amount a consumer can buy per day to be increased or removed. The most obvious issue with the current restriction is that cheese making requires substantial quantities of milk, even for a single, small, household batch — 10-20 litres. I also find it ludicrous that the current regulations require me and five immediate neighbours to all singly travel out to the farm to collect our weekly milk, which may only be a litre or two per household. This is a waste of time and fuel and carbon emissions! This is even more of an issue in larger metropolitan areas where people may have to travel much longer distances over congested roads.

I am not at all convinced by the data published by MPI about the incidence of illness related to raw milk. I am alarmed by the latest round of documents from MPI which suggest a further hardening of its position about raw milk safety. I request that MPI make much more detailed data available about the outbreaks of illness alleged to stem from raw milk consumption. Has it been conclusively proven that the illness came from raw milk? Where was that raw milk produced and by what kind of farmer (with regard to the distinction I draw above)? What were the practices on that farm? Were they followed? How was the milk handled and stored once bought by the consumer? Raw milk is not different to conventional milk and other dairy products or meat; for it to be safe to eat, people must store and handle it correctly.

I am strongly opposed to the restriction of the sale of raw milk. MPI must be aware of the depth of feeling about this issue; it is abundantly clear from reading online forums! If made illegal, I predict that many educated consumers of raw milk will make well-considered and deliberate decisions to flout the law. I have lived overseas where raw milk was sold in health food stores with a label “not for human consumption” and sold as milk for pets or bathing. This is just one of the possible responses to making supply more difficult; cow-share schemes are another. If MPI takes action that makes safe raw milk from responsible producers difficult or impossible to legally purchase, it will not stop its sale. Rather it will force it underground and the consequences of that are obvious and undesirable.

I also find it absurd that alcohol and tobacco are legally available for sale and can be readily purchased in supermarkets: as can adulterated food devoid of nutrients and laden with calories, rancid fats, chemical additives and sugar. The health impact of the ready supply of these “foods” are obvious, with diabetics and obesity becoming epidemic. It is accepted by government, agencies and academics that this is a health crisis and a great deal is said about the need for public education and better food choices. How, in this context, is it defensible to further restrict the sale of a traditional food that has kept generations of peoples healthy?

I ask that MPI make decisions that support and foster small, diverse family farms and that do not burden these responsible guardians of soil, water and animals with time-consuming, difficult and expensive administration or compliance responsibilities, whether overtly or in practice.

Rachel Rose

Raw Milk Producers Association of New Zealand

Thank you for listening to the submissions presented to the last round of consultations in 2011.
The RMPANZ was formed in the light of the anticipated law changes that we are now consultingon. Raw Milk producers are concerned that any law changes will affect this group more than any other group or individual. In our first year as an organization our membership exceeded 50, and as such considers our group to be the first point of contact for MPI in consultation and development of any or all options.

The discussion documents recognize the RMPANZ as an interested party of some substance, with a good number of members operating as Raw Milk producers for many years. As such we have many skills, experiences and alternative research, and would like to assist in the process of making new legislation. The RMPANZ represents interests in a large portion of all raw Milk sales and we welcome all opportunities to work for improved public health while not limiting freedom of choice.

We agree that the present laws for raw drinking milk are outdated and therefore need updating. Raw Milk is a food and as such no longer needs exemption from the current laws in this country. But it does not deserve to be singled out either, and we suggest it should get the same treatment as all other fresh perishable food.

We also ask that a clear distinction be recognized between Fresh Raw Milk drinking milk, and Raw Milk produced for further processing. And this distinction needs to flow right through from the regulatory process, all the way to the reporting processes, so that in the future any raw milk illness reported recognizes the difference.

Raw Milk Producers Association of New Zealand

The full submission is on this page

Stephen Blackheath

Stephen Blackheath raw milk submission 2014.pdf

The Ministry for Primary Industries is hugely over-stating the risks of drinking raw milk (by about 700 times). Peer-reviewed science tells us their claim that raw milk is a high-risk food is simply a lie. This should be a huge scandal and should put the whole process into disrepute. It is vital that you spread the word.

Summary: I argue that they are hugely misrepresenting the risks of raw milk and that they are doing it for political reasons to do with monopolization of the food industry. If you want more background about the international shenanigans involved, then please also see my Food Bill submission. I am sorry I can’t offer you more interesting reading Food Bill submission – final.pdf

I study politics in my spare time in the hope that I can learn the real reasons behind things and communicate them to others, because informed people are a lot harder to deceive.

Please write a submission, if you would, short or long, it doesn’t matter. When they get submissions from people they have failed to “guide” into their way of thinking, it gives them the fear. The government’s invulnerability is a carefully crafted illusion, nothing more. This is a technique called “learned helplessness” from the science of behaviourism. Now you know why there is so much apathy and defeatism. It’s scientifically engineered.

Note: They do not care what you want, but they care very much what they can get away with, so this is the angle you should come from. The illusion of legitimacy is their power. You can take it away. Remember: If the MPI are biasing this process to a pre-determined outcome, they are breaking the law.

Besides, do you have a choice? Stand up, or your ability to make your own decisions about your food and your health will be taken away. Deny it if you like, but this is the reality.

Stephen Blackheath

Stephen Blackheath raw milk submission 2014.pdf

Susan Galea

Overall the questions and answers posed in this document are loaded towards considering raw milk as inherently unsafe. Some of the questions are more like a survey question. The document suggests that there were many outbreaks and cases in New Zealand in 2013 but there is no evidence to support this. I have been unable to substantiate this information even on the ESR website. This information is used to background the questions which is rather misleading if there is no evidence.

Not only is the evidence not there, but in fact also if it was there it is only an association and not a proof as the reason for illness could well be “swimming in contaminated water” but being asked if they drink raw milk have replied “yes” and then that has falsely become a risk factor, even when the water is known to have issues.

The health department sheet for investigating camphylobactor is not available and so one must assume that the general questionnaire is used. That does not have any specified questions about risk factors, but leaves the practitioner able to ask and record whatever they like. They do not ask “have you been drinking pasteurised milk or eating spinach” for instance. This is an unsatisfactory way to base changes to the sale of raw milk on. However it explains why there may be no evidence. Raw milk has in fact been supplied in New Zealand for over 14 years and all farmers seem to be drinking it anyway , but there has been no real evidence of illness due to that milk.

The document tries to suggest that such outbreaks would affect NZ’s exports, but there was a very close call in Timaru this year which did not get proved to be in the raw milk on the farm and even that did not affect our exports. However there were scares in pasteurised milk last year from Fonterra that did affect our exports and our reputation. The other case in Timaru area which related to e-coli was due to a school visit to a non raw milk supply farm and so they probably do not take the care of their milk as do the raw milk suppliers.

There is a study on safe raw milk at http://www.realmilk.com/press/new-studies-confirm-raw-milk-low-risk-food/ which may be biased towards raw milk but is nonetheless just as believable as the opposite. I have also found references to Pasteurised milk outbreaks in the USA that were very dangerous. These do occur here in pasteurised products too and Bio Farm (NZ) had to recall product with e-coli a few years ago, there are probably many other recalls that we are not aware of because no one is trying to show that pasteurised milk also carries risks. I have heard of listeria in processing plants over the years.

I can accept that there is some risk and even if it is low and therefore care does need to be taken as with any food. I am however sure that testing will not reduce the risk unless the following is in place and suitable to the purpose.

Animal Health

A specific group of cows known to the farmer as designated raw milk cows should be used to enable health to be checked. A vet check for determining pregnancy can be a suitable time to check the health of the cows.

Anitibiotics should not be used because resistance is building to such remedies in general. It would be preferable to not allow grazing of round-up pasture or other pesticide sprayed pasture as these things reduce immunity by affecting the gut.

Cows should not be fed Palm Kernel as that also severely affects the ability of the gut to process which would also affect the immune quality of the milk. That can be seen in the paddock with the quality of the effluent.

What goes in to the cow also comes in to the milk, thus application of nitrogen to the pasture has been shown to be excreted in the urine and in the milk. Fonterra are monitoring the nitrate content of the milk as excess affects some of the products they are trying to make (MUN readings). Excess nitrogen in the milk is not good for people. Hormones should not be given to cows used for raw milk consumption.

In the same way dry cow therapy has been shown to present as antibiotics in the milk.

Cows should be checked (stripping it is called) at each milking to make sure that their milk is suitable before the milk is collected for human consumption. That is that there is no blood or flecks in the milk and that the colour and consistency is good. For a starter in the milk harvesting it may be necessary to demonstrate these things. It is also necessary to make sure that the teat is clean to prevent contamination of the milk, but actually it is the milk in the teat canal that is more important and initial stripping to check the milk is more important for milk safety than cleaning the outside of the teat.

Any C10 herds, unless in an endemic area should not be required to have annual TB tests.

Animal Feed

As above, animals must be fed correctly and not on anything that would adversely affect the health of humans consuming the milk. That includes GE feed as that has not been proven to be safe for human consumption. We should follow the precautionary principle until it is proven.

Also animals must be fed sufficient for their needs. They also need supplements to maintain their health in many areas of New Zealand as NZ soils are lacking in several minerals.

The risks of the incorrect feeding may not be revealed for many years later but there is an effect and may be as bad as causing deadly diseases such as been shown for A1 casein and homogenisation. Homogenisation was the subject of a study which showed that it was more likely to cause damage to the circulatory system in humans that the unadulterated cream.

Cows should not be just adequately fed for raw milk production but should be carefully fed on a range of plants that aid their health eg clover, plantain, chicory, herb ley.

Shed Suitability/cleanliness

NZCP1 has great guidelines for shed set up and usage and can be followed in principle by all raw milk farmers. As long as it can be demonstrated that any deviations gives the same results that should be sufficient. The effect of this is to minimise risks and enable thereto be no pathogens introduced in to the milk from a dirty environment and that the temperature of the milk is demonstrably reduced as quickly as possible and kept below 6 degrees until in the consumers possession.

A yearly shed inspection and a yearly plant inspection carried out by suitably experienced people who are aware of all the current requirements should be in place to validate the environment and the practices.

A written list of procedures should be available at the shed so that any helpers are aware of the requirements.

Packaging

New bottles should be used for all raw milk for human consumption. The use of containers supplied by the consumer should be discouraged as the cleaning may not be adequate and any failures in the consumer cleaning or their water supply may be reflected on the raw milk itself which is giving false results. It may be that in this year’s Timaru outbreak the bottles used were cleaned in the town water which is known to contain camphylobactor from time to time. The move to dispensers for raw milk will make this an issue as consumers can supply their own containers.

The new bottle can be manually filled, capped and the outside rinsed in a clean environment without risk of contamination in exactly the same way that the dispensers do so as it comes out of a pipe from the milk vat. In addition the raw milk bottlers can be wearing new rubber gloves, have face masks on and wear hair nets. These people engaged in the bottling task must not be sick, they must not allow the gloves to be in contact with anything else while doing the job and if the gloves are removed they must use a new pair. The inside of the cap must not be in contact with anything before being placed on the bottle.

If the milk it to be pre-ordered, that is acceptable to me, then the record of the consumer is already held, the consumer can at ordering be re-informed of the risks of drinking raw milk and must confirm they accept the milk as such. There does need to be this information and acceptance of the risk at a dispenser outlet.

There will be no random collection or delivery of milk to people who do not know and do not accept risk. The consumer will knowingly accept the milk or the delivery of the milk. In this case the labelling of the bottle is entirely a marketing tool. A date stamp can be placed on the lid.

After bottling the bottles must be immediately refrigerated to ensure that the temperature does not rise above the required temperature.

Testing

The frequency of testing does not affect the possibility of risk. All it would do is focus the harvester on the necessity for good results. If they get bad results it will cost them more to get the test results correct. It can be good to do extra testing when a new raw milk producer starts supply but those who have consistent results over a period of years can be surer about the effective practices and procedures. A test with a positive pathogen result is too late to stop the milk being drunk as MPI are suggesting the milk has to be drunk within 4 days and the results are not available until four days or longer for some pathogens. If a pathogen is found in a test follow up tests must be made until the milk is clear of the pathogen.

The presence of Listeria innocua is irrelevant as it does not affect human health, however its presence indicates that raw milk in itself has the ability to knock out the listeria mono as that is what the innocua does it acts as an antigen to listeria mono.

Delivery

It is preferable to deliver to centralised locations where the milk can be assured of keeping below 6 degrees C. Only consumers who have pre-ordered will collect the milk as they are the only ones who will know where to go. If MPI think it advisable there must be a way to electronically capture detail about those collecting, which would aid monitoring.

I would like to question what monitoring will occur at a private residence? Suppose there are visitors there instead of the documented consumer? What if someone else comes along and drinks their milk? How will that be monitored by MPI? Will MPI have to incur expense by visiting each of these residences?

It would not be acceptable to provide MPI with records unless the milk is suspected of causing a danger as Govt departments are known to have sent such details out to the public via emails and this data is commercially sensitive and private. Maybe consumers would object to having their details kept for so long. Anyway a lot of addresses will be out of date after 6 months in an urban environment.

The maximum time to enable tracking for an outbreak would surely be around 2 months so 4 years of records seems extremely excessive. Also why is amount taken important to record as amount does not indicate more risk or more follow up?

Colostrum

Why does MPI forbid the sale of colostrum in this document? Colostrum has the best immune enhancing capacity, that is why it is provided for the calf by the cow to set them up for life with good immunity. This can also benefit humans as they are battling the same environmental challenges.

It may be because of dry cow therapy hold over in the colostrum. However the first milk up to 10 days has been found to have the same antibiotics from the dry cow therapy in it though it does decrease with time.

It would be better to ban dry cow therapy from raw milk herds. That then ensures no antibiotics in the milk. It would be inconsistent then to allow any raw milk herds to be treated with any antibiotics unless the cow is removed from the raw milk herd subsequently.

I urge MPI to allow the sale of such good health benefiting substance as colostrums to be sold under these conditions above. There is a demand for colostrum from consumers.

Quality

Quality is not just about absence of risk. The quality of raw milk is also determined by the amount of good things in the milk itself. What breed of cow, what were they fed, good amounts of cream and milk solids. Absence of A1 casein, GE, nitrate, extra calcium, sufficient selenium. Milk is a whole food.

Raw milk producers should be encouraged to make all their practices geared up to providing the very best milk.

Raw versus pasteurised milk

The MPI document states that pasteurised milk is just as good as raw milk. However the calcium in pasteurised milk cannot be absorbed into the body. Some of the raw milk available has been tested and shown to have more available calcium than calci trim and it is all available to the drinker. That is just one example of a difference.

Another is that there does not seem to be an explanation as to why most lactose intolerant people can drink raw milk with no ill effect while pasteurised milk gives them problems. Never mind what is in the milk or not and all the trouble to refute this, there must be something about raw milk that is different from pasteurised that means that it is tolerated.

Risks and costs

Many people say that due to the risks of raw milk drinking costs to the public health system will go up. However no one seems to take into account the fact that public health costs have gone down due to the following improvements by raw milk drinkers already:-

Lactose intolerant people do not need supplements to help them digest lactose in milk.
Asthma and Eczema are not present in raw milk drinkers so the costs due to Asthma and Eczema must have reduced. These 2 can be life threatening as people do die of Asthma at least.
Eczema in babies that are switched to powdered formula or pasteurised milk before 2 years old is a real problem for them and may result in them not being able to drink milk at all which is bad for babies as milk enables then to get all the nutrition they need (as milk is a whole food). If they drink raw milk they are better off and healthier for it.
Health benefits of raw milk in improving immunity for those who drink it.

The risks have been overstated. The risks are accepted by raw milk drinkers as they have benefits from drinking the milk. Most city raw milk drinkers are paying a premium for raw milk and understand the risks.

Pesticide usage in New Zealand results in many foods containing pesticides. It has been shown that pesticides have a negative effect on the immune system. Here is a study showing the links to autism http://blink.htcsense.com/web/articleweb.aspx?regionid=4&articleid=24917846

Raw milk should not contain pesticides so basically should be certified Organic to remove all risks.

Susan Galea

Wellington Chapter of the Weston A Price Foundation

This discussion paper appears to be based on the assumption that raw milk is inherently dangerous, which is a biased premise, based on the assumption that because milk has been pasteurized for approximately 100 years, that must mean it needs to be.

Raw milk is inherently safe if it comes from healthy cows, kept in suitable conditions (outside, in the sunshine, feeding mainly on grass) and given appropriate care when needed.

Raw milk is much higher in nutrients, including those that combat toxins.

Raw milk is safe if it is harvested in a hygienic way, with the intent that it will be consumed raw.

It becomes dangerous when it comes from cows that do not have a suitable lifestyle. eg factory farming, not being outside in the sun, or not being mainly grass fed, or the milk is harvested with the intent that is will be pasteurized, so the same stringent care isn’t taken.

The main problems currently are that:

The regulations are over restrictive, and restrict people’s freedom of choice

There is a failure to differentiate between high quality raw milk (usually safe) and poor quality raw milk (potentially, though still not necessarily, dangerous)

There is a tendency to blame raw milk for any illness, without testing either the milk or other possible sources. This is leading to increased numbers of reported illness where raw milk may be a risk factor, without any proof. This possible correlation (which is rising as more people drink raw milk) is then used to substantiate your claim that illness from raw milk is increasing.

Your job is to protect people from the poor quality milk while allowing freedom of choice.

The solutions are:

Allow the RMPANZ to set the guidelines for safe practices, which will ensure high quality raw milk. Membership of the association would be subject to following their guidelines, which might include:

How the animals should be raised, housed and fed

Required testing and veterinary care

Hygiene practices for harvesting the milk

How milk is stored and transported

Educational material made available to customers

Remove all restrictions on quantity (purchased or sold), and remove restrictions on where the farmer can sell to the customer. The only regulation I would suggest is that the customer buys directly from the farmer, rather than through shops. That way they have a relationship with the farmer. If the farmer is a member of the RMPANZ, they know they are following suitable guidelines. If they are not members, then it is the buyer’s responsibility to check the farmers practices themselves.

Allow people their freedom of choice in what they buy – in the same way that people can choose to buy alcohol, cigarettes, sugar, and many other substances that are much more harmful than raw milk.

Over regulation in this area will only drive the whole market further underground.

Wellington Chapter of the Weston A Price Foundation

www.frot.co.nz

MILK SUBS 2014

Submissions to MPI – July 2014

2014 Submissions on Proposed options for the sale of raw milk to consumers

Cedric Backhouse

Cory Gully

Deb Gully

Ian Gregson

James Bellamy

John Martin

John Martin

Karyn Redfern

Rachel Rose

Raw Milk Producers Association of New Zealand

Stephen Blackheath

Susan Galea

Wellington Chapter of the Weston A Price Foundation

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