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 – 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 email@example.com
Unlike in many other countries raw milk is NOT currently allowed to be sold in NZ shops.
A summary of the submissions was posted on the MPI website here
“The Ministry for Primary Industries invites all interested parties to make written submissions on the issues raised and options presented in this consultation
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 firstname.lastname@example.org
Raw Milk Producers Association of New Zealand
Wellington Chapter of the Weston A Price Foundation
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.
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:
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.
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:
It becomes dangerous when:
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:
Your job is to protect people from the poor quality milk while allowing freedom of choice. The solutions are:
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:
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.
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.
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:
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.
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).
Q32. It should not be necessary if a recognised laboratory is used for the milk testing.
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.
Q45. Any Raw milk advocacy group, such as NZARM
Deb Gully – Certified Natural Health Practitioner
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.
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
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.
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
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.
I only know that there are a lot of vendors and their volume varies depending on the number of cows they have.
I am a current vendor.
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.
…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.’
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:
* 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?
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.
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.