{"id":3434,"date":"2016-02-26T18:39:51","date_gmt":"2016-02-26T05:39:51","guid":{"rendered":"http:\/\/www.frot.co.nz\/design\/?page_id=3434"},"modified":"2020-05-03T15:23:54","modified_gmt":"2020-05-03T03:23:54","slug":"milk-rmpa","status":"publish","type":"post","link":"https:\/\/www.frot.co.nz\/design\/wapf\/milk-rmpa\/","title":{"rendered":"MILK RMPA"},"content":{"rendered":"\n\n\n
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\"real.milk.1\"<\/a><\/h2>\n

Raw Milk Producers Association of New Zealand submission on discussion document<\/strong><\/span><\/h2>\n

This was a submission on sale of raw milk to consumers<\/strong> <\/em>\u2013\u00a0MPI Public Discussion Paper No: 2014\/22<\/em> <\/strong><\/span><\/p>\n

\"\"<\/p>\n

Thank you for listening to the submissions presented to the last round of consultations in 2011.
\nThe RMPANZ <\/em>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.<\/p>\n

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.<\/p>\n

The discussion documents recognize the RMPANZ <\/em>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<\/em> 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.<\/p>\n

We agree that the present laws for raw drinking milk are outdated and therefore need updating.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.<\/p>\n

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.<\/p>\n

\"Real.Milk.White.Cow.200b\"<\/a><\/p>\n<\/div>\n

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The Problem<\/strong><\/span><\/h3>\n

Firstly, defining raw milk<\/strong> is key to defining the problem.
\nThe Raw Milk Association NZ would like to point out that the description of raw milk page 3 from the discussion paper No 2014\/22 and from the definition of raw milk 2.1 from the technical paper No 2014\/12 defines a substance that is un-contaminated. In pursuit of accuracy and clear focused discussion the association would expect the Ministry to re-define raw milk (as referenced in all the recent surveys of raw milk MPI study, Fonterra study 5.2 MPI Technical paper 2014\/12 ) from NZ farms as contaminated raw milk<\/strong>.<\/p>\n

With reference to this the association would further expect the Ministry to then consider the other raw milk that exists (de-contaminated raw milk<\/strong> as described in the discussion paper No 2014\/22 section 8.1.1 third paragraph and with reference to the milk tests attached) as a separate but parallel area for discussion.<\/strong><\/p>\n

Question 1<\/h5>\n

The Association agrees with the problem described but only under a more accurate definition, thus allowing discussion on firstly food borne illness that results from drinking contaminated raw milk (Factory Milk)<\/strong> and secondly discussing minimal food borne illness risk from drinking de-contaminated raw milk<\/strong>(Drinking Milk).<\/strong>
\nThe Association contends that this illness risk debate must be streamed to the two distinctly different products requiring two distinctly different control regimes.
\nThe Ministry\u2019s contention that an increased incidence of raw milk based human illness is indisputable but the re-definition of raw milk would then question \u201dwhich milk is causing the increased incidence of illness\u201d.\u00a0 The quantity of contaminated raw milk <\/strong>(intended for processing in factories) would in the Association\u2019s opinion contribute the vast majority of the increase in raw milk based illness.<\/p>\n

People in NZ do not yet understand that fit for intended purpose factory supply raw milk is highly contaminated with bacteria and pathogens and will choose this milk as it is often cheaper and more readily available.<\/p>\n

The Association does not contend that the de-contaminated raw<\/strong>milk<\/strong> produced by most of the members is totally free from contaminants but does contend that the level of contamination is hugely reduced. (see milk test results attached)
\nNow that we have clarified the need for two definitions of Raw Milk, we wish to comment on the evidence directly associated with illnesses from raw milk, which is very lite as presented in Appendix 1, Paper No 2014\/12. The majority of the illnesses listed could have come from anything else the patients ate, drank or touched.<\/p>\n

If the number of illnesses presented were infact from raw milk farms, then we would expect our members to know something about these cases. We therefore contend that the statistical risk analysis in Appendix 1 is based on false data and is not the same milk we wish our members to sell to their customers.<\/p>\n

We would also like to add some balance to the \u201cProblem\u201d<\/strong>.<\/p>\n

Throughout the discussion document and its supporting documents, assertions are made that pasteurisation of milk turns it into a perfectly safe product to drink. In the following paragraphs we wish to point out that just like with all foods, pasteurised milk can cause illness and even deaths occasionally.<\/p>\n

In presenting this data, we note that we cannot find data for pasteurized dairy illness in NZ. Is this data not recorded?<\/p>\n

SUMMARY<\/span> <\/em><\/strong><\/p>\n

31 total outbreaks <\/em>
\n\u00a09 fluid milk <\/em>
\n\u00a021 cheese: 17 non-Mexican style; 4 Mexican style queso fresco<\/em>
\n1 powdered milk <\/em>
\n\u00a02,840 total illnesses, 10 deaths <\/em>
\n\u00a02,200 fluid milk-related illnesses (3 deaths) <\/em>
\n604 cheese-related illnesses: 573 non-Mexican style (5 deaths), 31 Mexican style queso fresco (1 death) <\/em>
\n36 powdered milk-related illnesses <\/em><\/p>\n

It should be noted that there have been no deaths associated with Raw Drinking milk since CDC records began in 1972.<\/p>\n

Now looking at a recent study shows us certain Pasteurisation techniques can have negative impacts by increasing listeria growth post pasteurisation even under refrigeration. It predicts an increase from the existing average of 18 deaths per year, up to 670 deaths per year from Listeria in processed milk.<\/p>\n

Responding to Bioterror Concerns by Increasing Milk<\/em><\/strong>Pasteurization Temperature Would Increase Estimated Annual<\/em><\/strong>Deaths from Listeriosis<\/em><\/strong><\/span>
\nJournal of Food Protection, Vol. 77, No. 5, 2014, Pages 696\u2013705<\/p>\n

The results of this study indicate that increasing the<\/em>pasteurization temperature of fluid milk could increase the<\/em>subsequent outgrowth L. monocytogenes in milk contaminated<\/em>with this pathogen post<\/em>pasteurization. These changes<\/em>to the potential for outgrowth have been calculated to<\/em>increase the risk of death from listeriosis due to consumption<\/em>of pasteurized fluid milk by approximately 40-fold.<\/em><\/p>\n

Such an increase would have an appreciable public health<\/em>impact if all milk in the United States were processed<\/em>according to the increased pasteurization temperature based<\/em>on the fact that fluid milk is estimated to be responsible for<\/em>approximately 18 listeriosis deaths per year in the United<\/em>States. In reality, the observed increase in mortality would<\/em>probably be less, because standard pasteurization likely<\/em>occurs at temperatures above 72uC (about 75 to 76uC) and<\/em>because the increased pasteurization temperature may be<\/em>implemented in only part of the milk supply.<\/em>
\nThese findings indicate that increasing the severity of heat<\/em>treatments alters the growth kinetics of L. monocytogenes<\/em>and spoilage bacteria resulting in faster overall growth<\/em>during refrigerated storage. Future work is needed to<\/em>determine the exact biochemical changes in the milk (e.g.,<\/em>protein denaturation,<\/em>i<\/em>ncluding<\/em>enzyme inactivation (20))<\/em>responsible for the increased growth of bacteria in milk<\/em>pasteurized at higher temperatures.<\/em><\/p>\n

This is of concern when you read the following research from Australia showing variations in pasteurisation temperatures.
\nSCIENTIFIC EVALUATION OF<\/em><\/strong>PASTEURISATION FOR PATHOGEN<\/em><\/strong>REDUCTION IN MILK AND MILK<\/em><\/strong>PRODUCTS<\/em><\/strong><\/span>
\nDr Harley Juffs and<\/em>Associate Professor Hilton Deeth<\/em> \u2013 FSANZ 2007<\/em><\/p>\n

Beyond that, however, temperatures ranged<\/em>from 72-86o C and times from 15-50 seconds, with many different combinations within those<\/em>ranges. As with batch pasteurisation, type of product was again a major influence on the<\/em>heating regime used, with the time and temperatures reported generally being within the<\/em>expected range for the type of product.<\/em>
\nOf particular note is that HTST treatment of milk for liquid milk products, at least by most of<\/em>the large processors and some of the smaller ones, was mostly in the range 74-78o C for 15-30<\/em>seconds. This reflects a recommendation by the peak Australian dairy industry organisation<\/em>in 2000 that the times and temperatures for HTST pasteurisation of milk for the liquid milk<\/em>trade be increased as a precaution against the presence in the raw milk of any M.<\/em>paratuberculosis organisms that might be resistant to minimum pasteurisation treatment of<\/em>72o C for 15 seconds.<\/em><\/p>\n

And finally in New Zealand there are 6 recalls of Pasteurised Dairy products listed on the Government Food Smart website thus far in 2014, showing that problems can and do occur, \u00a0exposing the public to some risk until all the foods in question are retrieved.
\nKlondyke Fresh brand Blue, Light ,Trim Milk and fresh Cream products<\/em><\/a>\u00a013 March 2014<\/em>
\nWhitestone Cheese Ltd brand \u2018Windsor Blue\u2019 retail ready and wholesale cheese products<\/em><\/a>\u00a06 March 2014<\/em>
\nKiwi and Mel-O-Rich brand Ice-cream & Frozen Desserts<\/em><\/a>\u00a019 February 2014<\/em>
\nKiwi, Mel-O-Rich and Much Moore brand Ice-cream & Frozen Desserts<\/em><\/a>\u00a010 February 2014<\/em>
\nAnchor and Pams Fresh Cream 300ml and 500ml<\/em><\/a>\u00a014 January 2014<\/em>
\nDeep South Ice cream<\/em><\/a>\u00a010 January 2014<\/em><\/p>\n

Our point here is, that while pasteurisation is a useful tool, it is not as fool proof as is often stated. We firmly believe that Raw Milk produced following sound guidelines can and is being produced at least as safely as pasteurised milk currently is.<\/strong><\/p>\n

\"Real.Milk.White.Cow.200b\"<\/a><\/p>\n

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\u00a0The Objectives<\/strong><\/span><\/h3>\n
Question 2<\/h5>\n

The Association contends that the re-defined raw milk will require two separate approaches to these objectives one for contaminated raw milk (Factory milk)<\/strong> and one for de- contaminated raw milk (Drinking milk)<\/strong>.
\nThe first point \u201creduced illness\u2026\u2026\u2026..\u201d. Will require separate effort for both types of raw milk.
\nThe second point \u201cmaintain existing access\u2026\u2026\u2026\u2026.\u201d. Would require significant restrictions for off farm consumer access to this contaminated raw milk<\/strong> (Factory milk<\/strong>) as it is the most dangerous for urban people who have had minimal exposure to these extreme levels of bacteria and pathogens.<\/p>\n

Whereas de-contaminated raw milk<\/strong>(Drinking milk) <\/strong>hygienically produced and backed up with sufficient testing should, with a consistent high milk quality standard, be suitable for urban consumers.
\nThe third point \u201c ensure consumers receive accurate\u2026\u2026\u2026\u201d. The warning and information given to consumers would have to be streamed differently for each milk type. It would be important to use words or rules carefully when describing the risks of contaminated raw milk (Factory milk<\/strong>) as the risk of affecting export product reputations is real.
\nThe fourth, fifth, sixth and seventh\u00a0 points are\u00a0 again requiring two separate streams of development to deal separately with contaminated raw milk (Factory milk<\/strong>) and de-contaminated raw milk (Drinking milk)<\/strong>.
\nThe eighth objective is to encourage the de-contaminated raw milk (Drinking milk)<\/strong> to aim for the highest possible milk quality and to encourage full use of milk test results to raise the milk standard of all participants. Some farmers may not be able to participate in raw milk sales if their milk test results are not good enough. There should also be a robust policing function included in the rules pertaining to raw milk produced for sale for human consumption.
\nThe Association is supportive of MPI to allow for the production of a high quality Raw<\/strong>Drinking Milk<\/strong> product that is safe, tested and supervised.<\/p>\n

\u00a0\"Real.Milk.White.Cow.200b\"<\/a><\/p>\n

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Background<\/strong><\/span><\/h3>\n

For clarity of the background, the Association would like to Refer MPI back to top of this submission in clause 3. In clause 6 they are for the most part referring to about Raw Factory Milk, not Raw Drinking Milk<\/p>\n

\"Real.Milk.White.Cow.200b\"<\/a><\/strong><\/p>\n

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Current situation<\/strong><\/span><\/h3>\n

The Association does not currently keep any information about sales by it\u2019s members. As mentioned in the document we are aware of many more producers who are not current members of the Association, so it is very hard to calculate consumption, but we feel 5 % is a reasonable estimate. While it is a small concern, the Association members take the attitude that we need to start somewhere if we are to educate everyone about the production of safe Raw Drinking Milk.<\/p>\n

Outbreaks of illness in New Zealand<\/h3>\n

As the Report states, the association of raw milk in these \u201creported\u201d incidents is very low. If you then take the Raw Factory Milk out of the equation, the \u201creported\u201d incidents are extremely low. As stated elswhere in this submission, if any of the very small number of incidents came from a Raw Drinking Milk farm, then our members believe we would know about them, but we don\u2019t.
\nWe would also like to comment on the state of \u201cOfficial\u201d reporting of Raw milk illnesses. MPI and Health authorities are often quoting illnesses, but very few of them are in any official reports. We question the motives and even the legality of this as it simply amplifies the \u201clegend\u201d about the severity of raw milk illness without justification.
\nWe want to see an improvement in the reporting processes, and the inclusion of raw Factory Milk and raw Drinking Milk along with Pasteurized dairy products.<\/p>\n

\"Real.Milk.White.Cow.200b\"<\/a><\/strong><\/p>\n

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Assessment of evidence<\/strong><\/span><\/h3>\n

Risk assessment<\/h3>\n

Risks<\/h4>\n

As we stated in clause 3, the risk assessment is overstated because the calculations are based on data from milk intended for processing, not consumption. We also wish to point out that there is no practice that \u201cguarantees\u201d any food to be free of pathogens, therefore the claim made in 8.1.1 paragraph 3 is invalid. We present further below evidence that milk intended for fresh consumption can be produced in as safe a manor as any other fresh food.<\/p>\n

Effects of pasteurization on raw milk<\/h4>\n

Conclusions that small quantities of missing components and small percentage changes in milk by pasteurisation have very little effect on it, are not consistent with knowledge that small quantities of microbes, good or bad, can have a major effect on milk. The conclusions also fail to acknowledge the combined or cumulative effect of all these components damaged by pasteurisation. Science now recognizes the \u201ccocktail\u201d effect of chemicals, why should the components of Raw Milk be any different.
\nIf we step aside from studies directly comparing Raw milk with Cooked milk, we find numerous studies looking at the effects of heat treatments on whey for processing. These studies describe in detail the various effects on the proteins and how they in-turn effect manufacturing. Manufacturers use this knowledge to design their products. These effects may help explain why and how a lot of people have trouble digesting pasteurised milk. Here are a few examples
\nMILK PROCESSING AND QUALITY MANAGEMENT. Edited by A.Y Tamime<\/em><\/strong>
\nHeat induced denaturation of whey proteins in milk affects many processing characteristics of milk, as described in more detail in Section 2.6<\/em>
\nHEAT-INDUCED WHEY PROTEIN REACTIONS IN MILK. <\/em><\/strong>
\nKinetics of Denaturation and Aggregation as related to Milk Powder manufacture. <\/em>
\nThesis by David James Oldfield, Massey University 1996.<\/em>
\n8.4 Possible Industry Applications<\/em>
\nHeat-induced reactions of milk proteins during processing determine, to a large extent, the functional attributes in many milk products. Although extensive research has been carried out on milk protein reactions in a number of heated systems (e.g. milk, whey), relatively little is known about the effect these changes have on functional properties.<\/em>
\nNow we take a look at pasteurisation of Human Breast Milk
\nEFFECTS OF PASTEURISATION AND HIGH-PRESSURE PROCESSING ON VITAMIN C, TOCOPHEROLS AND FATTY ACIDS IN MATURE HUMAN MILK<\/em><\/strong>
\nCarolina Molt\u00f3-Puigmart\u00ed<\/a>a<\/a>,\u00a0b<\/a>,\u00a0Marc Permanyer<\/a>c<\/a>,\u00a0Ana Isabel Castellote<\/a>a<\/a>,\u00a0b<\/a>,\u00a0M. Carmen L\u00f3pez-Sabater<\/a>a<\/a>,\u00a0b<\/a><\/p>\n

Abstract<\/em><\/h3>\n

Holder pasteurisation has traditionally been used in human milk banks to inactivate the pathogenic microorganisms and part of the commensal flora that are potentially present in milk from donors. However, this process results in variable loss of nutrients. In the search for an alternative to pasteurisation, we assessed the ability of high-pressure processing (HPP) to maintain the fatty acid, vitamin C and vitamin E contents of human milk and compared this process with Holder pasteurisation. Fatty acid proportions in milk, as well as levels of delta-, gamma-, and alpha-tocopherols did not vary with any of the treatments. Total vitamin C and ascorbic acid levels were maintained after HPP. However, after pasteurisation, total vitamin C and ascorbic acid were about 20% and 16% lower, respectively, than in untreated samples. These results suggest that HPP merits further investigation as a potential alternative to Holder pasteurisation for treating donor human milk.<\/em><\/p>\n

RETENTION OF THE IMMUNOLOGICAL PROTEINS OF PASTEURIZED HUMAN MILK IN RELATION TO PASTEURIZER DESIGN AND PRACTICE<\/em><\/h3>\n

Charles\u00a0Czank<\/em>1<\/em><\/a>, Danielle K\u00a0Prime<\/em>1<\/em><\/a>, Ben\u00a0Hartmann<\/em>2<\/em><\/a>, Karen\u00a0Simmer<\/em>3<\/em><\/a>and Peter E\u00a0Hartmann<\/em>1<\/em><\/a>
\nInevitably, the mechanism of thermal inactivation of bacteria during pasteurization also results in considerable loss of beneficial proteins present in human milk. This can be attributed to the \u201cbroad action\u201d of heat that disrupts cell membranes and proteins through thermally induced denaturation (<\/em>7<\/em><\/a>). Typically, Holder Pasteurization can reduce the function of the immunoprotective proteins, such as secretory immunoglobulin A (sIgA), lactoferrin, and lysozyme, as much as 80%<\/em>
\nPASTEURIZATION OF MOTHERS OWN MILK REDUCES FAT ABSORPTION AND GROWTH IN PRETERM INFANTS.<\/em><\/strong>
\nY Andersson, K Savman, L Blackberg, O Hemell. \u2013 Sweden 2007<\/em><\/p>\n

Results; We found, on average, 17% higher fat absorption with raw milk as compared to pasteurized milk. Infants gained more weight and linear growth as assessed as knee-heel length was greater during the week they were fed raw milk as compared to the week they were fed pasteurized milk.<\/em><\/p>\n

We have presented just a few examples of different studies showing that there may be some truth to the claims by many people that pasteurised milk has a negative effect on their lives. These examples look at milk from different perspectives, showing that science has many varied opinions about effects of pasteurization on milk. Some of these examples may help explain why for some people Raw Milk benefits their lives while pasteurized milk destroys their lives.<\/p>\n

Besides the pure scientific approach to the question of Raw Milk benefits, we encourage regulators to take more notice of the personal accounts recounting life changing effects. When the number of accounts relayed reach as high as they are, they should not be dismissed as fantasy. Numerous people\u2019s lives have changed dramatically after consuming Raw Milk and that information needs to be taken into account throughout the decision making process.<\/p>\n

The information presented in Appendix 1 is largely based on milk produced for further processing. The practices used to produce this milk are hugely different from those that either are already, or should be employed to produce Raw Drinking Milk. We agree that most of the milk sampled in this risk assessment is not suitable for consumption without further processing.<\/p>\n

Here we will present some further information demonstrating that Raw Milk can be produced to a level of acceptable risk that is comparable to most other foods.<\/p>\n

MANAGING FOR MILK QUALITY<\/strong><\/h3>\n

http:\/\/milkquality.wisc.edu\/wp-content\/uploads\/2011\/09\/managing-for-milk-quality_english.pdf<\/a><\/p>\n

Essential Aspects of the Milking Routine <\/em>
\nEffective implementation of a milking routine that includes forestripping, predipping, adequate <\/em>
\ndrying and effective post-milking teat disinfection should be the goal of all dairy farms. <\/em><\/p>\n

Effective Predipping. Methods of premilking teat preparation have been extensively studied <\/em>
\n(Galton et al., 1982, Galton, et al., 1984, Galton et al., 1986, Pankey, 1989, Ruegg and Dohoo, <\/em>
\n1997). There is no question that the most effective method to disinfect teats is to predip using an <\/em>
\napproved disinfectant. The use of pre-dipping using iodine has been demonstrated to reduce <\/em>
\nstandard plate counts and coliform counts in raw milk by 5 and 6 fold,<\/u><\/em> respectively as compared <\/em>
\nto other methods of premilking udder preparation (Figure 2; Galton, et al., 1986).<\/em><\/p>\n

Here we have 12 years of results from Organic Pastures Dairy Raw Milk Sales from their 300 cow herd using good herd management and hygienic milking procedures.
\nhttp:\/\/www.organicpastures.com\/pdfs\/Bacteria%20Counts_6_1_14.pdf<\/a>
\nInternal Testing Source: Sierra Dairy Laboratories<\/p>\n

 <\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
SPC<\/strong><\/td>\nColiforms<\/strong><\/td>\n<\/tr>\n
Sample Count<\/td>\n681<\/td>\n122<\/td>\n<\/tr>\n
Std. Deviation<\/td>\n3,524<\/td>\n4<\/td>\n<\/tr>\n
Cumulative Average<\/td>\n2,420<\/td>\n3<\/td>\n<\/tr>\n
YTD 2014 Avg<\/td>\n488<\/td>\n2<\/td>\n<\/tr>\n
2013 Avg<\/td>\n1,127<\/td>\n4<\/td>\n<\/tr>\n
2012 Avg<\/td>\n1,015<\/td>\n5<\/td>\n<\/tr>\n
2011 Avg<\/td>\n3,706<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2010 Avg<\/td>\n4,171<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2009 Avg<\/td>\n3,425<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2008 Avg<\/td>\n4,003<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2007 Avg<\/td>\n3,426<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2006 Avg<\/td>\n4,161<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2005 Avg<\/td>\n5,068<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2004 Avg<\/td>\n1,926<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2003 Avg<\/td>\n1,089<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n
2002 Avg<\/td>\n1,344<\/td>\nnot consistantly tested<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

For more American examples, take a look at the results on the websites of other Listed Farmers here http:\/\/rawmilkinstitute.net\/listed-farmers\/<\/a><\/p>\n

NZ Raw MILK results to come<\/p>\n

And a portion of Expert witness testimony by Dr Ron Hull (Australia) to a California court. He is a world consultant on Dairy Microbiology.
\nhttp:\/\/www.realmilk.com\/wp-content\/uploads\/2000\/01\/expert-testimony-0508.pdf<\/a>
\nQ. You disagree why?<\/strong><\/p>\n

A.<\/strong> Because we know where pathogens come from in the dairy industry. In the case of shedding cows, we know why they shed pathogens, and we have procedures to eliminate those pathogens from the gastrointestinal tract of those animals, and that\u2019s been commercial practice now since \u2013 in the poultry industry at least since 1970.<\/p>\n

We\u2019re talking 38 years that\u2019s been knowledge, and it\u2019s now practiced in other agricultural industries. So we can be assured that our animals are not shedding pathogens. So we can be very specific in our control measures for controlling pathogens in the dairy herd and \u00a0 in the milking environment.<\/p>\n

\"Real.Milk.White.Cow.200b\"<\/a><\/p>\n

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\u00a0<\/span><\/strong><\/p>\n

Potential options considered but not proceeded with:<\/span><\/strong><\/h3>\n

Prohibition<\/h3>\n

We agree that prohibition will not work. Canada is a perfect example that it doesn\u2019t work. Despite the risk of huge fines, thousands of desperate consumers convince farmers to supply them with milk.<\/p>\n

Status quo<\/h3>\n

This is not an option either<\/p>\n

Non regulatory control measures<\/h3>\n

This is also not a good option<\/p>\n

Sale at retail outlets<\/h3>\n

We don\u2019t want to see a retail option. Direct from the farm to consumers is the best option.<\/p>\n

Sales at farmers markets<\/h3>\n

Some farmers markets may work, but overall they are not a viable option at this stage. They may be an option in the future once systems are in place and have settled down. This option does work in parts of America, and it is still only for pre-ordered collection, NOT sales.<\/p>\n

\"Real.Milk.White.Cow.200b\"<\/a><\/p>\n

\n

 <\/p>\n

Options under consideration<\/span><\/strong><\/h3>\n

Option 1:<\/h3>\n

The Association acknowledges the need to draw a line in the sand between regulated control of food products and small scale operations. And it doesn\u2019t matter where that line is drawn, people immediately either side will be disadvantaged.<\/p>\n

Therefore we are pointing out that we have members who will be affected by just missing out on option 1, and so ask for some understanding and tolerance as we assist these producers to adjust to any new requirements.<\/p>\n

Option 2:<\/h3>\n

The Association wishes to point out that the development from Option 1 over to Option 2 , 3 or 4 may be a big capital step for some as customer demand grows, and therefore some understanding and communication may be needed in this area as well.<\/p>\n

Option 3:<\/h3>\n

Advantages<\/strong><\/p>\n

The Association disagrees with the assertion that \u201cthe current demand by some consumers to buy raw milk in places other than the farm would be met\u201d. Our farmers that currently deliver are clear that they would not be able to support home delivery as it would not be economically viable. Therefore the demand by consumer to buy raw milk from places other than the farm would not be met. The regulations would fail to meet the objective of maintaining existing access to raw milk.<\/p>\n

The Association disagrees with the assertion that \u201cthe additional requirements imposed on home deliveries would help manage risks to consumers\u2026\u201d. It would be very difficult if not impossible to monitor compliance with the refrigeration requirement. This may mean that milk may not remain at under 6 degrees Celsius and therefore increase the risk to the consumer.
\nWe agree with the other advantages stated under this section.<\/p>\n

Disadvantages<\/strong><\/p>\n

The Association disagrees with the assertion that \u201cdespite the proposed hygiene and safety controls for home deliveries \u2026 safe food\u201d for the following reasons.<\/p>\n

The science that the Ministry is relying on are small sample sizes. The Ministry is also demonstrating correlations which may not be statistically significant, and correlations are not demonstrations of causation in terms of a higher risk of adverse health consequences if a larger amount of raw milk is available.<\/p>\n

If the milk presented for sale is not the milk produced for further processing (Factory Milk), then increased sales should not a risk factor.<\/p>\n

The Association agrees with the assertion that option 3 is not consistent with the way the Ministry regulates the sale of other raw foods that potentially contain pathogens.<\/p>\n

Other comments on Option 3<\/p>\n

If option 3 was implemented and used the Association is concerned that milk delivered may not be secure, allowing it either to be tampered with or stolen.<\/p>\n

Question 23<\/h5>\n

The Association supports the addition of Option 4 as detailed below.<\/p>\n

Option 4: sales from farm as for option 2, plus delivery to a common pick up point<\/h3>\n

Option 4 extends option 2 by allowing dairy farmers selling 40 litres or more of raw milk per day to deliver raw milk directly to a common pick up point, provided the consumer has: <\/strong><\/p>\n

CDC data is often referred to as a source of information for Raw Milk illness, but what is always overlooked is their data on Pasteurised Dairy illnesses.
\nhttp:\/\/www.realrawmilkfacts.com\/PDFs\/pasteurized-dairy-outbreak-table.pdf<\/a>
\nThese tables were compiled by the Real Raw Milk Facts working group through searches of the Centers for Disease Control and Prevention\u2019s (CDC) online foodborne disease outbreak database (1998-2010). Because the CDC database has about a two-year lag period, preliminary data was gathered from government and dairy industry press releases, reports, and newsletters to document recent outbreaks (2011-present). Information on farm type and size was taken from the implicated dairy\u2019s website, state reports, and articles when available. <\/em><\/p>\n