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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Furthermore, at the time of the raid, Hooley’s license to sell raw milk had been suspended because his milk had tested positive for the bacteria Yersinia, which is required for testing in the state of Texas and penalties for testing positive usually result in the loss of two weeks’ worth of sales.

According to the Farm-to-Consumer Legal Defense Fund, the Fort Worth city code classifies vehicles as “food establishments” and “…the city claimed that the containers were from an unapproved source since Hooley’s license was under suspension at the time of the raid.”

As a result of his guilty verdict, Hooley has been ordered to pay $1,500 in fines and an additional $67 in court costs. Hooley has not yet decided whether to appeal.

Read more details about Hooley’s trial, verdict, and responses from the public via the Farm-to-Consumer Legal Defense Fund.

To learn more about raw milk and other nutrient dense foods, visit westonaprice.org

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State Rep. Dan Flynn has introduced this bill in each of the 3 past legislative sessions, getting it a little farther in the legislative process each time. Flynn calls HB 91 a “free enterprise bill,” as it will empower dairy farmers to increase revenues by meeting consumer demand.

This bill faces heavy opposition in the Senate from the Texas Association of City and County Health Officials, Texas Pediatrics Society, Texas Environmental Health Association and Select Milk Producers. However, it has the support of the Farm and Ranch Freedom Alliance, which has turned out members in support of the bill each time it has been introduced.

Realmilk.com is a consumer education project of the Weston A. Price Foundation, a nutrition education nonprofit based in Washington, D.C. Visit their website, westonaprice.org.

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The path to changing laws is frequently long and difficult. This year’s battle over a raw milk bill in Texas was particularly difficult and took some unexpected twists that have effectively killed the bill this session. Since at least some of these new twists are likely to become common in raw milk fights across the country, it is worth learning from the hard knocks Texans have suffered.

Industry Flip Flop

Big Dairy opposition to raw milk is not new. The industry giants have killed bills in California, Wisconsin and elsewhere. In Texas, though, there was a new twist because the industry initially supported the raw milk reforms. In November 2009, a group of raw milk farmers and consumers presented a proposal to the Advisory Council for the Texas Department of State Health Services (DSHS) to allow licensed farmers to sell raw milk at farmers markets and through delivery. (Current law allows licensed farmers to sell only on-farm.) The Executive Director for the Texas Association of Dairymen (TAD ) testified in favor of the proposal.

Over the course of the next year, TAD repeated its support for expanding legal sales of raw milk. But in December of 2010, TAD reversed its position. We have no proof as to what triggered the flip flop, but the association’s comments give strong clues. Back in 2009, TAD ’s comments focused on the needs of family farmers and the potential for raw milk to help them. The Executive Director spoke about the economic plight of the farmers selling milk into the conventional markets and acknowledged that direct-to-consumer sales of raw milk could save family farmers. After the flip flop, the TAD ’s comments switched to the typical fear mongering promoted by Dairy Farmers of America, which not coincidentally controls a majority of TAD ’s Board. In essence, the organization appears to have gone from listening to its farmers to listening to the corporate headquarters.

Budget Crunch

The next twist was the claim by DSHS that the bill would cost the state money. With Texas facing a record budget shortfall, this was enough to stall the bill. The agency began with a simple fact: the costs of all of the state’s inspections and tests are greater than the amount of fees generated. But from there, the agency spun a fantasy where dozens of raw milk dairies would be licensed, more outbreaks would occur, the agency would need more employees, and so forth. Not only did these assumptions lack any basis in fact, but the underlying viewpoint was startling: the agency was effectively claiming that it was in the state’s fiscal interest to have a few massive dairies rather than healthy small family farms. Ultimately, when faced with the lack of facts to support the claims, the agency concluded that there would be no “significant” fiscal impact to the state and removed that obstacle to the bill.

Alleged Outbreak

But just as the bill headed to the long-awaited hearing, yet another twist arose. After ten years with absolutely no illnesses attributed to raw milk in Texas, on the day of the hearing, there was a press release claiming that four illnesses, between December and March, were attributed to a raw milk dairy in the Texas area.

David Gumpert has an excellent blog posting with some of the unanswered questions about these allegations: http://www.thecompletepatient.com/journal/2011/4/21/health-officials-say-they-have-the-goods-on-texas-raw-dairy.html

Medical Lobbying

Despite the last-minute ambush, the proponents of the raw milk bill turned out in strength at the April 20th hearing on the bill. Over one hundred thirty people registered in support of the bill, and a dozen health practitioners, farmers, mothers and students spoke eloquently about the wide range of benefits of raw milk, from health to economic. Unfortunately, while we clearly “won” the hearing on both turnout and substance, the Committee delayed voting on the bill and there is not enough time left to pass it this year in Texas.

One of the key reasons that the bill was delayed yet again, despite the strong facts on our side, was the opposition of the Texas Medical Association. Medical associations have been predictably opposed to raw milk. Generally, that opposition has taken the form of general policies and statements opposing raw milk consumption, which have been quoted by the industry opponents. In Texas, however, the medical associations took a much more active role. The Texas Medical Association and the Texas Pediatrics Society developed so-called fact sheets that they distributed to the legislators. They also distributed “Food Safety Hazards Associated with Consumption of Raw Milk,” a deeply flawed study that misrepresents the actual risks involved with raw milk from small-scale dairies producing products that they intend to be consumed raw.

Most importantly, the associations spent time lobbying against the bill and testified at the Committee hearing. These associations carry a great deal of influence at the Legislature, and they have successfully blocked many bills far less controversial than the raw milk bill.

Lessons Learned

While dealing with the painful loss of a promising bill for this year, the effort was far from wasted. We laid important groundwork in Texas for coming back in the next legislative session and getting the bill passed then. And the lessons learned in Texas can serve to help raw milk proponents all over the country in their fights.

We must now anticipate that the medical associations will not sit on the sidelines, but will actively lobby against any expansion of access to raw milk. That means warning bill sponsors to be prepared, and preemptively addressing the mainstream medical establishment’s claims. Not only do we need the data about the rarity of illnesses caused by raw milk (which we had in Texas), we also need to develop materials explaining the flaws with the medical establishment’s paradigm of sterilizing its way to safety.

In addition, the industry opposition to raw milk has been shown to be fractured. By reaching out at the farmer-to-farmer level, we can try to build alliances with the conventional farmers facing a crisis in their businesses. As is common in conventional agriculture, the industry associations are representing the interests of the large, consolidated companies, not the family farmer. We can create bridges that bypass the industry associations and highlight the shared interests of raw milk farmers and other family dairy producers.

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In August of 2000 the farm was raided by inspectors from three divisions of the Texas Department of Health (TDH). The inspectors alleged that the farm was in violation of more than forty different health and safety violations, and further that it had deceived the public with the language on its website. Biologist/owner Lee Dexter defended the practice of selling raw milk by overwhelming the Attorney General’s Office with more than 2,500 pages of scientific literature relating to the safety and efficacy of raw goat milk and raw milk cheeses. In the aftermath, the TDH engaged in a flurry of dirty tricks. Inspectors detained the farm’s products in multiple locations and “paid visits” to its customers and processors. The TDH strategy culminated in the issuing of an Emergency Order prohibiting the sale of the farm’s cheeses in late 2001. Simultaneously, the TDH published an extremely damaging press release, which was widely distributed.

The farm did get its day in court. After hearing two days of testimony in December 2001, Administrative Law Judge, Cathleen Parsley, issued a Proposal for Decision lifting the Emergency Order. The judge stated that the Emergency Order had “pummeled Ms. Dexter’s business, and, as it turns out, with little legal justification to do so.” She also stated that the Department had held the farm liable for violations against regulations that were not yet in effect, did not prohibit the activity cited, were not applicable, or did not say what the TDH interpreted them to say. She concluded that the TDH failed to show how the alleged misconduct posed a threat to human health. In more recent court settings, WEF has defended its right to sell its products directly to the consumer. The outcome of these cases may have far-reaching implications for the rights of both consumers and producers of raw milk products in other states.

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