The media have been taking their cues from press releases issued by public health departments that have been giving the advice to pasteurize all milk. However, the solution to avoid getting brucellosis is far different from what public health and the media are telling you. In the words of one healthcare professional, “For public health officials to issue public notices that the solution to this avoidable problem is to pasteurize all milk, is astonishing.”

First off, the three cases of brucellosis are the only known cases attributed to raw milk consumption over the past 20 years. Brucellosis is a systemic disease in cattle and humans that is caused by the bacteria Brucella abortus. At one time the disease in cows caused severe reductions in offspring and was a problem for the cattle industry. A national eradication campaign was launched in the 1950s and, according to USDA statistics, the number of cattle/bison herds affected by brucellosis in the U.S. has been less than 10 every year from 2003 onward.¹

The eradication program’s success has led to a huge decline in the number of brucellosis cases in humans; estimates are that there are about 100 cases of human brucellosis per year in this country.² In the U.S. this is mainly an occupational disease with most of the rare cases of brucellosis being in people who attended the birth of an infected cow and then became infected during handling of the birth tissues and fluids.^3,4

In an infected dairy cow, the Brucella abortus pathogen can proliferate in the mammary glands and then enter the milk. The pathogen can pass to humans when drinking the infected milk but, as mentioned, the cases of brucellosis (also known as undulant fever) attributed to drinking raw milk in the U.S. are extremely rare.

The “milk ring test” is the traditional and commonly used method to screen dairy herds to detect any cows with brucellosis; the test is performed on the herd’s milk to check for the rare presence of Brucella antibodies.

Two vaccines against brucellosis have been developed for calves: the S19 vaccine and the RB51 vaccine. The S19 vaccine is effective but it has the disadvantage of causing testing for antibodies to become positive. The vaccine can make it difficult to distinguish between a vaccinated cow and an infected cow. The RB51 vaccine does not cause the antibody testing of cows to become positive but another problem arises with its use.

The RB51 vaccine must be administered to calves before they become fertile; a side effect is that, if a cow is given the RB51 vaccine when pregnant, it may actually cause an infection with the vaccine strain of Brucella in the vaccinated cow. It is, therefore, possible that if the RB51 vaccine isn’t given strictly according to the protocol, the vaccinated cow may become infected and may shed the pathogen (i.e., the RB51 strain of Brucella) into the milk.

Public health officials have found in all three cases of illness from brucellosis attributed to raw milk consumption, the strain of Brucella abortus discovered in the three individuals was the RB51 vaccine strain. In fact, in November 2017, the Pennsylvania Department of Agriculture sent a letter to licensed raw milk producers in the state advising them to stop immunizing cows from brucellosis with the RB51 vaccine.⁵

So the solution to preventing brucellosis in raw milk is not for producers to pasteurize the milk but rather to either stop giving their herd the RB51 vaccine or to make sure their vets give the calves the vaccine before the calves become fertile. Worth noting, too, is that hundreds of people drank raw milk produced by the herds responsible for the three cases of brucellosis and, as far as is known, no one else became sick.

In the meantime, the media fear-mongering continues on. The latest case of brucellosis attributed to raw milk consumption dates back to November 2018, but to read the stories in the media, you would have thought it was just discovered. CDC press releases on this latest case dated January 23, 2019, and February 11, 2019, are providing the impetus for the flood of media reports.

Has an agenda ever gotten so much mileage over three illnesses?

A fear-inciting statement from the February 11 CDC press release that the media have parroted is, “the CDC and state health officials are investigating potential exposures, to Brucella strain RB51 in 19 states, connected to consuming raw (unpasteurized) milk from Miller’s Biodiversity Farm in Quarryville, Pennsylvania.”⁶ (The farm allegedly distributed raw milk to people in the 19 states listed later in the release.) Being exposed to a pathogen is far different than being sickened by it; we are exposed to various pathogenic bacteria such as listeria and e. coli in the environment every day.

One headline screamed, “Deadly Disease Caused by Raw Milk Has Already Put 19 U.S. States on High Alert.”⁷ There have been no deaths from brucellosis attributed to raw milk consumption since the eradication program succeeded in substantially eliminating the incidence of the disease and possibly even long before then.

The public health agencies and their allies in the press have been misleading the public long enough on raw milk and brucellosis. It’s time for fear and hysteria to give way to science and common sense.

——
¹ “Brucellosis Affected Cattle/Bison Herds by State, FY 1997-2018” graph [PDF]. USDA-APHIS National Brucellosis Eradication Program (September 10, 2018), https://www.aphis.usda.gov/aphis/ourfocus/animalhealth/animal-disease-information/cattle-disease-information/national-brucellosis-eradication/brucellosis-eradication-program

² “Facts About Brucellosis” [PDF]. USDA-APHIS National Brucellosis Eradication Program, Section “Resources” link (see question #21), https://www.aphis.usda.gov/animal_health/animal_diseases/brucellosis/downloads/bruc-facts.pdf

³ “How Brucellosis is Spread” section. USDA-APHIS National Brucellosis Eradication Program (September 10, 2018) [PDF], https://www.aphis.usda.gov/aphis/ourfocus/animalhealth/animal-disease-information/cattle-disease-information/national-brucellosis-eradication/brucellosis-eradication-program

⁴ “Fast Facts: Brucellosis, Undulant Fever” [PDF]. Iowa State University, The Center for Food Security & Public Health. April 2008, http://www.cfsph.iastate.edu/FastFacts/pdfs/brucellosis_F.pdf

⁵ Letter dated November 30, 2017 [PDF]. Pennsylvania Department of Agriculture, Bureau of Animal Health and Diagnostic Services, Dr. David Wolfgang (Director) and Dr. Lydia Johnson (Director, Bureau of Food Safety & Laboratory Services); accessed at https://www.yourfamilyfarmer.com/uploads/documents/RB51-Brucellosis-Letter-PDA-2017.pdf

⁶ Media Statement [PDF]. CDC (February 11, 2019),
https://www.cdc.gov/media/releases/2019/s0211-brucellosis-raw-milk.html

⁷ “Deadly Disease Caused by Raw Milk Has Already Put 19 U.S. States on High Alert” [PDF]. ScienceAlert.com, Carly Cassella (February 15, 2019), https://www.sciencealert.com/it-s-dangerous-to-drink-raw-milk-the-cdc-warns-for-the-umpteenth-time

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Update, Winter 2008

On November 18, 2008, Albany County Supreme Court Judge John C. Egan, Jr. dismissed the petition of Meadowsweet Dairy, LLC, for a declaratory judgment that the LLC’s distribution of raw dairy products to its members was not subject to state regulation [see updates below for background on this case]. In holding that the dairy was under the regulatory authority of New York State Department of Agriculture and Markets (NYS-DAM), the judge also denied Meadowsweet Dairy’s motion for a preliminary injunction to prohibit NYSDAM from “conducting any further inspections, issuing any further search warrants, and taking any further administrative, civil or criminal actions against the plaintiffs” during the course of the litigation between the two parties.

The case turned primarily on whether the LLC members were to be considered as “consumers” under the law. Under state regulation anyone who sells, offers for sale or “otherwise makes available raw milk for consumption by consumers” is required to get a permit. The definition of “consumer” that Judge Egan adopted was so broad that even someone keeping a family cow would be required to obtain a permit. In ruling that the LLC members were “consumers,” the judge found that Steve and Barbara Smith (the farmers and member-managers of the LLC) were required to obtain a raw milk permit. In addition, the judge found that the Smiths were required to obtain a milk plant permit if they wanted to sell dairy products other than milk. The milk plant permit would do the Smiths little good because it only allows the sale of pasteurized dairy products.

The judge’s ruling is ominous for those in New York who want to produce raw milk for a living. Inspectors for NYSDAM have been open about the department’s desire to get rid of raw milk. The good news is there is a move underway to introduce a bill that would legalize the unlicensed, unregulated sale of raw milk by farmers direct to consumers.

Update, Fall 2008

On May 16, hearing officer Susan Weber issued her long-awaited report on the January 17 hearing concerning a motion by the New York State Department of Agriculture and Markets (NYSDAM) asking Meadowsweet Dairy, LLC to show cause why the dairy should not be shut down for operating a milk plant (referring to the sale of raw dairy products other than milk) and selling raw milk without all the necessary permits (see Winter 2007 and Spring 2008 updates below for background on the case). As expected, Weber sided with the agency.

The major issue at stake between the two parties was whether the LLC was selling milk under state law which, if so, would require the dairy to obtain a permit. Under the state dairy code, “every person who sells, offers for sale, or otherwise makes available raw milk for consumption by consumers shall hold a permit to sell raw milk issued by the commissioner . . . .”

Weber found that the LLC members were “consumers” under the law and that in distributing raw milk to the LLC members the dairy was “making available” raw milk. The hearing officer also found that in processing raw milk into other raw dairy products the LLC was operating a dairy plant and needed a dairy plant permit in addition to being required to obtain a milk dealer’s license to distribute any products manufactured at the dairy plant. Under state law the only raw product a dairy plant can legally manufacture and sell is cheese aged more than sixty days.

Weber’s recommendations at the end of her report were that the New York Commissioner of Agriculture, Patrick Hooker, give the LLC thirty days to apply for the raw milk, dairy plant, and milk dealer’s permits with the Commissioner to issue a cease and desist order to the dairy if this was not done. In addition, the hearing officer recommended that the Commissioner fine the LLC $1000 for “manufacturing, producing, possessing, selling and offering or exposing for sale raw milk and raw milk products under insanitary conditions.” Weber found that the conditions at Meadowsweet “were not sanitary” and that the products produced there may have been “injurious to health.”

The report failed to account for the fact that none of the LLC’s members had ever become sick from consuming the dairy’s products and did not mention that all the members had a chance to the see the farm’s production area themselves and evidently weren’t bothered by any of the conditions they observed there.

On July 23 Commissioner Hooker issued to the LLC an order adopting Weber’s recommendations except that instead of allowing a thirty-day grace period for the dairy to file licensing applications, the order to cease and desist the production and distribution of raw milk and raw milk products went into effect immediately. The commissioner forbade the dairy from selling milk until it obtained a raw milk permit and prohibited Meadowsweet Dairy LLC from ever selling dairy products again, holding that even with a dairy plant license they can only produce pasteurized dairy products other than raw cheese aged at least sixty days.

Meadowsweet’s attorney, Gary Cox, has appealed the Commissioner’s order to the Albany County Supreme Court—the same court scheduled to hear the LLC’s declaratory judgment suit against NYSDAM. That suit asks the court to rule that the LLC and its operations are beyond the jurisdiction of the agency; NYSDAM has filed a motion to dismiss the complaint and the court is likely to rule on that motion sometime this fall.

Update, Summer 2008

The hearing on Meadowsweet Dairy LLC’s petition for a permanent injunction against the New York Department of Agriculture and Markets (NYDAM) should be taking place sometime this summer in the Albany County Supreme Court [see Winter 2007 and Spring 2008 updates below for background on this case]. The LLC’s shareholders are asking the court to rule that NYDAM has no jurisdiction over the distribution of raw dairy products to the shareholders and that the agency should be prohibited from interfering with the LLC’s operations. On March 10, Judge Egan of the Albany County Supreme Court stayed a motion by NYDAM to show cause why the Smiths should not be held in contempt of court for refusing to unlock the doors of the production facility on their farm when the inspectors from the department were executing a warrant to search the Smiths’ premises. Judge Egan, who will be hearing the LLC’s suit for the injunction, ruled that he will only consider the show cause motion if he determines at that hearing that NYDAM does have jurisdiction over the LLC’s distribution of raw dairy products.

In response to the Meadowsweet case, legislation has been introduced into both the New York Senate (S06827) and Assembly (A10870) that would legalize the sale of raw milk off the farm premises (texts of the bills can be found at www.assembly.state.ny.us/leg/). The reason the Smiths had dropped their retail raw milk license was that under it they could sell raw milk only on the farm, depriving them of customers who would not travel to their location to pick it up. The bills, if passed into the law, would put Meadowsweet Dairy under NYDAM’s jurisdiction regardless of how Judge Egan rules. Both bills state that “every person engaged in the production of raw, untreated milk for human consumption shall hold a permit issued by the commissioner.”

Update, Spring 2008

The dispute between Meadowsweet Dairy LLC and the New York Department of Agriculture and Markets (NYDAM) has escalated into a war that is now being fought on three fronts.  (See Winter 2007 update below for background on the case.)

In November the Commissioner of NYDAM issued an order for the destruction of dairy products that the agency had placed under seizure a month earlier.

On December 11, the LLC and its 121 owners filed suit against NYDAM in Seneca County Supreme Court asking that the court issue a permanent injunction prohibiting the agency from interfering with the LLC’s operations.

On December 13, NYDAM struck back by filing an administrative complaint asking farmers Steve and Barbara Smith (the majority owners of the LLC) to show cause why Meadowsweet Dairy should not be shut down for, among other things, selling raw milk without a permit. Shortly after filing the suit, the agency sent inspectors to the Smiths’ farm with a warrant to destroy those dairy products under seizure.  During their visit, the inspectors noticed other dairy products and asked to inspect them.

The Smiths responded by calling their local sheriff who, upon arrival at the farm, told the inspectors that they did not have a warrant to inspect other products and should leave.  Inspectors showed up again on December 19, this time with a warrant to inspect the Smiths’ entire premises.  When the inspectors got to the farm’s processing facility, they found that locks had been installed on its doors.  The inspectors asked the Smiths to unlock the doors.  The Smiths called their attorney, Gary Cox, and read the warrant to him.  The warrant did not contain any provision authorizing the use of whatever force to gain access to a facility; so, Gary therefore advised the Smiths not to unlock the doors.  After consulting with their boss at NYDAM’s Division of Milk Control and Dairy Services, the milk inspectors eventually left without getting into the processing facility.  They returned nine days later with the same warrant but were denied access a third time and again went home empty handed.

NYDAM retaliated for the Smiths’ refusal to let it inspect the farm’s processing facility.  On February 1, pursuant the request of the agency, Judge Egan of the Albany County Supreme Court issued an order requiring the Smiths to show cause why they should not be held in contempt for refusing to let the agency into their dairy processing facility when the inspectors had a warrant.  (Egan was the judge who signed the warrant.)  On February 28, a hearing was held on the judge’s show cause order.  At the end of the hearing the judge did not issue a ruling but instead told the parties that he would be taking the matter under advisement. The agency’s December 13 motion to show cause had been heard earlier by an administrative officer on January 17 and 18.

As of this writing, the officer had not issued a ruling but was expected to do so shortly. The Smiths’ lawsuit for an injunction against NYDAM was heard before the Seneca County Supreme Court on January 22.  The judge in that case did not issue a ruling but instead, under a state procedural law, transferred the case to Albany County Supreme Court where it will probably be heard by Judge Egan sometime this summer.

The Meadowsweet Dairy case shows the lengths to which NYDAM will go to maintain jurisdiction over cow share or farm share programs like the one the Smiths operate.  The battle between the two parties is shaping into a typical war of attrition where the bureaucracy tries to prevail by depleting the resources of its opponent. For updates on the Smiths’ situation as well for other news about the raw milk movement, please go to David Gumpert’s blog, www.thecompletepatient.com.

Update, Winter 2007

A potentially significant case is underway in New York. Until March of this year, Steve and Barbara Smith had held a permit to sell raw milk. Under state law, those holding a permit can sell raw milk only on the farm. The Smiths do not live near a population center and this restriction limited the growth of their customer base. On March 10, the Smiths gave up their permit and started a new business model. They deeded their cows to a limited liability company, Meadowsweet Dairy LLC, and sold membership interests in the LLC to those who wanted to obtain raw dairy products. The Smiths began deliveries to LLC members and their business grew rapidly—by October there were 115 members and thirty more on the waiting list.

When the Smiths returned their permit to the New York Department of Agriculture and Markets (NYDAM), they informed the agency of their plans to start Meadowsweet Dairy LLC. NYDAM contended the LLC was still subject to the permit requirement and continued to inspect the dairy. Tensions between the Smiths and NYDAM escalated over the next seven months until October 11, when the agency executed a seizure order on 260 pounds of raw dairy products at the Smiths’ farm.

The Smiths intend to respond to the seizure by filing suit to obtain a court ruling confirming the fact that Meadowsweet Dairy LLC is not under the jurisdiction of the state. The Smiths are members of the Farm-to-Consumer Legal Defense Fund and the Fund has hired Gary Cox to represent them. A favorable ruling would considerably improve the prospects of raw milk farmers in New York; there are fewer than twenty licensed farmers and the restriction to on-farm sales limits opportunities for licensees. A ruling that Meadowsweet Dairy LLC is not under the state‘s jurisdiction could enable New York raw milk producers to recover much of the business that is lost to the neighboring states of Connecticut and Pennsylvania.

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ACTION ALERT

August 12, 2007–A consistent pattern of harassment against raw milk farmers is emerging in Pennsylvania and New York. We are sending this Action Alert to all members because these tactics could be used in other states as well. It is vital for raw milk farmers to know how to protect themselves from unfair treatment by inspection agents, and for consumers to protest to the proper officials that their access to raw milk is being unfairly threatened.

We are watching this situation very closely and will be submitting Freedom-of-Information requests in both states to obtain test records and any statements by officials on this situation.

A concerted letter writing campaign by WAPF members can really help this situation and help ensure a supply of raw milk in these two very important states. . . so we are asking that everyone pitch in with their most persuasive writing skills!

Background

Since April, a total of nine farmers have been told that their milk tested positive for listeria monocytogenes. The positive tests appear to coincide with the FDA’s issuance in March of a powerpoint presentation on the “dangers of raw milk.” There are NO reports of anyone getting sick from drinking the milk of any of these nine farms.

Please note that the generic bacteria listeria is ubiquitous and not harmful, although its presence in milk is considered a red flag. Only one strain, listeria monocytogenes (l-mono), is considered pathogenic. The standard protocol is to test milk for listeria and, if the test is positive, to then test for the specific bacteria listeria monocytogenes, a process that takes five days or more.

According to a lab technician employed by Mosely Laboratories in Indianapolis, which uses the standard protocol for detecting l-mono, results are 100 percent accurate. The technician stated that of the fifty tests on raw milk that he has run for l-mono over the past two years, not a single one has been positive.

Pennsylvania

The Pennsylvania Department of Agriculture is using a new testing system, Called Vidas 30, which they claim can determine the presence of l-mono in 48 hours “with 98 percent accuracy.” (The Vidas 30 system is also said to detect the presence of salmonella, e.coli and campylobacter.)

The first case involved a raw milk dairy in Butler County, Pennsylvania. According to the Pennsylvania Department of Agriculture (PDA), the milk tested positive for l-mono on April 13 and sales of the milk were banned. The PDA issued a press release, warning about the milk from the dairy, but nothing in the press release indicated that there was a positive test for l-mono. After three subsequent negative tests, sales were reinstated at the farm. PDA did not issue a press release after reinstatement of sales.

The second case involved a farm in Berks County, Pennsylvania. The statewide PDA press release stated that milk tested positive for l-mono on May 10. According to the farmer, PDA claimed the 48-hour test results showed the milk was positive for l-mono. Subsequently, the agency reversed its position and concluded that the milk was negative for l-mono. PDA took a second sample of milk from the farm on May 17, which also tested negative, and sales were reinstated on May 24. At the request of the farmers, PDA issued a press release stating that the milk from the farm had tested negative for l-mono, but sent it only to a local television station.

A third case involved a farm in Lebanon, Pennsylvania. The PDA press release stated that milk from Green Acthe farm tested positive for listeria on June 1. PDA told the farmer that the preliminary test showed the milk was positive for l-mono. Final test results indicated that it was positive as well. The farmer sent a milk sample from a different batch to an independent laboratory, Mosely Lab of Indianapolis, and the test results were negative for l-mono. Subsequently, PDA took a second sample of milk and that sample was negative for l-mono. The farmer took a sample from the same batch, sent it to Mosely Lab, and that sample also tested negative for l-mono. Even though PDA usually requires three negative tests from its own laboratories to let a farm resume sales, it evidently accepted the results from Mosely and required no further tests for l-mono. The second sample PDA took showed that the milk had a high coliform count, and when a follow-up sample showed that the coliform count was at an acceptable level, the state permitted sales to resume on June 13.

A fourth case involves a farm in Clarion County, Pennsylvania. The PDA press release stated that the milk from the farm tested positive for listeria on June 14. PDA contacted the farmer on June 15 to tell him that his milk had tested positive for l-mono. On June 20 the farmer sent a sample of milk to Biotech Labs in New Castle; and, even though the milk tested positive for listeria, final tests resultsshowed that it was negative for the l-mono strain. On June 26, the farmer sent two samples of milk to Mosely Lab and a week later the test results came back negative for l-mono. PDA is supposed to be running another test for l-mono; but as of this date, it has yet to take a sample so raw milk sales at the farm have not resumed.

New York Cases

In New York, five different farms have tested positive for l-mono, according to the New York State Department of Agriculture and Markets.

The first involved an Allegany County farmer whose milk tested positive for listeria, and which prompted a December 26 warning from the New York State Agriculture Commissioner Patrick H. Brennan against drinking unpasteurized milk.

One case involved Dawn and Jeffrey Sharts of Beech Hill Farms. The farm has sold milk into the conventional market for over thirty years. Last year the farm obtained a permit to sell raw milk, at which time, says Dawn Sharts, “the inspectors suddenly began treating me like I was selling toxic waste.” When the milk from the Sharts’ farm tested positive for l-mono last spring, the department put a press release on its website announcing the positive test. Several weeks later, when subsequent tests showed the milk to be negative, the department refused to take the press release off the website.

Unlike Pennsylvania, the Sharts’ believe the problem with testing in New York is that the department uses antiquated manual measurement methods to test instead of electronic measurement. A sample taken by the state and tested for somatic cell count had ten times the level than did a sample taken that same day tested by a lab for Sharts’ pasteurization plant. They also accuse inspectors of using careless testing methods, for which they have videos of the inspectors’ actions at the farm to back up this claim.

Action to Take

1. We are asking all members to alert their farmers about what is going on. Any time the state takes a test sample, the farmer should send his own sample to an independent laboratory. It is probably not a bad idea to videotape any sample taking and inspections. If the farmer is accused of having l-mono in his milk, he should immediately contact the Farm-to-Consumer Legal Defense Fund at (703-208-FARM)

2. Please contact the following officials by email. If you live in Pennsylvania or New York, it would be very good to send a snail mail letter to the officials in your state. The tone of the letter should be polite but concerned. Points to include:

• Describe how you and your family depend on raw milk for your health.
• Protest the unfair treatment to farmers doing their best to comply with the law (this is especially true in Pennsylvania, where the PDA has campaigned to get farmers to obtain licenses.)
• Demand that the state issue a press release when the farm has been given permission to resume sales, to be posted on the department’s website and sent to the same media list that received the initial press release.
• Point out that the present testing for listeria is an overreaction to a problem that does not exist. According to a certified report from the Centers for Disease Control on foodborne illness caused by raw milk 1972-2005, there is not a single outbreak due to listeria in raw milk or raw milk products other than three cases involving Mexican-style raw milk cheeses smuggled over the border (known as “suitcase cheese”).
• In Pennsylvania: Ask that only the preferred methodology as outlined by the FDA be used in testing for l-mono, which has a greater accuracy than the new testing system used by the Pennsylvania Department of Agriculture. In New York: Ask that inspectors use careful and standardized testing procedures.

People to Contact

Honorable Edward G. Rendell
Governor, State of Pennsylvania
225 Main Capitol Bldg.
Harrisburg, PA 17120
governor (at) state.pa.us
717-787-2500
717-772-8284 (fax)

Honorable Dennis C. Wolff
Secretary of Agriculture
2301 North Cameron Street
Harrisburg, PA 17110
dwolff (at) state.pa.us
717-772-2853
717-783-9709 (fax)

Mr. Bill Chirdon
Director, Bureau of Food Safety and Laboratory Services
2301 N. Cameron Street
Harrisburg, PA 17110
wchirdon (at) state.pa.us
717-787-4315
717-787-1873 (fax)

Honorable Eliot Spitzer
Governor of New York
State Capitol
Albany, NY 12224
Email through website – http://161.11.121.121/govemail
518-474-8390
518-474-1513 (fax)

Patrick Hooker
Commissioner,
New York Department Agriculture and Markets
10 B Airline Drive
Albany, NY 12235
Patrick.hooker (at) agmkt.state.ny.us
518-457-8876
518-457-3087 (fax)

Will Francis
Dairy Division Director
New York Department of Agriculture and Markets
10 B Airline Drive
Albany, NY 12235
will.francis (at) agmkt.state.ny.us
518-457-1772
518-485-8730 (fax)

We would like to file a Freedom of Information Action (FOIA) for each of the farmers, which will request information on testing procedures and test results.  This should ideally be  done by a customer of the farmer, and at least by someone living in the respective state. We have drafted language and can help with the filing. So we need nine volunteers to file the requests. If you would like to volunteer for this task, please contact Cathy Raymond at cathy (at) farmtoconsumer.org

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