2024 Annual IAFP Meeting in Long Beach, California

The International Association for Food Protection (IAFP) held its annual meeting from July 14-17. The IAFP meeting is the largest food safety conference in the world; this year, over 3,000 people from industry, government and academia attended. The meeting is the conference for the industrial food system; this year, as in the past, Merck Animal Health and Cargill were major sponsors. Labor shortages and broken down supply chains over the past few years have made the food safety regulators’ jobs more thankless than ever. The regulators might have to deal with a foodborne illness outbreak that contains ingredients sourced from multiple countries where the traceability is difficult. The FDA Food Safety Modernization Act (FSMA), which went into effect in 2011, was supposed to reduce the number of foodborne illnesses in the U.S. A high ranking FDA official provides a regulatory update at the meeting each year; until the 2023 conference, that official acknowledged that the number of foodborne illnesses has remained flat. The past two years, the official giving the regulatory update hasn’t covered the matter; with the noticeable deterioration in quality in the conventional food supply, the likelihood is that foodborne illness has not declined.

A solution to the food safety problem would be to decentralized food production and deregulate both food production and distribution at the state and local level—a move attendees at the conference do not consider; their job is to figure out and implement improvements to food safety under the existing industrial paradigm. Nevertheless, the IAFP meeting is an important event to follow; it can serve as an incubator for laws and policies that have an effect on the local food system.

The following is a review of some topics covered at this year’s meeting.

Bird Flu—Highly Pathogenic Avian Influenza (HPAI)

With reports on the bird flu “pandemic” being blared in the media daily, a panel consisting of federal government regulators (FDA, USDA, CDC) and individuals from academia and industry convened to discuss what to do about the outbreak of HPAI that had first spread to dairy cattle towards the end of March.¹ The panelists lamented how the public was not listening to their warnings not to consume raw milk; in May, one polling firm estimated that demand for raw milk had risen as high as 65% since the onset of the “pandemic”. The panel members spoke about how social media such as TikTok and Instagram are influencing the public to purchase raw milk. One panel member thought the public was buying raw milk out of fear. Another panelist was closer to the truth when he acknowledged that mistrust of government, academia and industry has led to an increase in the consumption of raw milk. Accurate science was what the panel thought could stop or slow down the increase in raw milk consumption.

Another reason brought up in the discussion about why the consumption of raw milk was going up was a fear of industrial food and not knowing where your food was coming from. One panelist thought the consumer would support locally produced pasteurized milk. A panel member resolved to gather more information on why consumers think raw milk is the right thing. The panel agreed that HPAI was going to be around for a while and that it would be important to harmonize messaging with partners whether they be in the federal government, state government, or in industry.

Reports are that labs are using the notoriously inaccurate PCR test to test for HPAI; numerous labs during COVID were running the test at 40 cycles or more where the chances of a false positive test result were high. Two employees for a lab exhibiting at the IAFP conference tradeshow guessed that their lab was running the PCR test at 45 cycles to test for HPAI. Interestingly, an official with the Massachusetts Department of Agriculture and Natural Resources stated, “PCR tests are only viable up to 30 cycles, so these labs would likely run no more than 30 cycles.”² Massachusetts has been the only state so far to require raw milk dairies to test for bird flu; so far, all milk samples tested have been negative for HPAI.

Cronobacter

Another talk impacting raw milk at IAFP was a panel discussion on cronobacter³, a pathogen found mainly in powdered infant formula. A speaker at a past IAFP conference disclosed that there is a 20% mortality rate for infants infected with the pathogen. A panelist at the 2024 conference stated that cronobacter can survive in the powdered formula up to five years. Another panelist said that cronobacter has characteristics of both salmonella and listeria. Takeaways from the panel discussion were that cronobacter is ubiquitous in the environment and that there’s still lots to be learned about the pathogen.

In 2022 an Abbott Laboratory plant in Michigan shut down after infant formula produced in it was linked to deaths and illnesses caused by cronobacter. Shortly after the shutdown, traffic to a page on raw milk infant formula on the Weston A. Price Foundation’s website went up 1,000% as demand for raw milk surged. Much of the panel discussion centered on how difficult and complex the cleaning process is in a plant producing powdered infant formula; profit margins are high so firms in the business have the incentive to stay in even though the risks are considerable compared to most foods. It would not be surprising if future problems with cronobacter occur in infant formula plants, directly leading to further jumps in the demand for raw milk.

Food Fraud

One of the more eye-opening sessions at IAFP was a panel discussion on food fraud⁴—something that affects 10% of the commercial food supply according to a speaker at the session. Food fraud is especially present with honey, oils, spices, fish, and juices. Food fraud is the intentional adulteration and mislabeling (misbranding) of products; one trick of the trade is altering expiration dates on the label, and another is putting a low quality product in the packaging and labeling used by a competitor and passing that product off as the competitor’s. Undeclared allergens on food labels are also a problem.

Protecting against food fraud is a complex and arduous process for a business. Different sectors within a firm work on it from product development to quality assurance to procurement. Tracking supply chains, vulnerability (to fraud) assessments, verifying authenticity (e.g., GMO-free, organic, country of origin), lab testing ingredients or finished food products, and being in compliance with legal requirements are all part of the process. The world of food fraud is great incentive for buying directly from a farmer you know and trust.

Cell Cultured Meat (CCM)

Investors have spent billions on cell cultured meat but so far there is very little product on the market. Pre-market approval from FDA is necessary to sell cell cultured meat; that agency has joint jurisdiction with USDA in regulating that product. In IAFP session on cell cultured meat (CCM)⁵, a speaker said that FDA had only granted approval for two cell cultured poultry products, and no approval for any beef or pork products yet. Another speaker remarked that price and perfection for cell cultured meat are not there. The legal framework to navigate to get approval is difficult. A typical CCM product will have anywhere from 60 to 100 inputs (ingredients); FDA evaluates each to determine whether it is a food additive recognized in the law or, in most cases, whether it is GRAS (generally recognized as safe). One speaker remarked that the infrastructure for the CCM industry is lacking; there is no large-scale commercialization of the product. Another said that pathogens such as Campylobacter, Salmonella, and E. coli in CCM are a problem. There was a comment that, with the expense of manufacturing CCM, there was little product available. One of the speakers disclosed that the U.S. is a test market for CCM and that much of the investment in the product was European. The upshot of the session was that CCM is not having success getting established in the market; the speakers at the session spent little or no time addressing the complete lack of demand for CCM.

Attending the IAFP conference is an affirmation of how important it is to build out a parallel food system; the pace which favorable laws and infrastructure for a prosperous local food system is rounding into place needs to increase.

Footnotes:
1. Anderson N, Detlefsen C, Nichols M, Martin N, Suarez D, & Sinatra J. (2024, July 16). LB – Late Breaking Session – Responding to an Outbreak of Highly Pathogenic Avian Influenza (HPAI). [Panel discussion]. IAFP 2024 Annual Meeting, Long Beach, CA. https://iafp.confex.com/iafp/2024/onlineprogram.cgi/Session/10155

2. Cahill M. (2024, August 28). Government email. MA Dept. of Agricultural Resources Div. of Animal Health.

3. Clifford D, Farber J, Gollinger M, Hanlin J, van der Sanden J, & Warren B. (2024, July 15). RT11 – Cronobacter spp. Control: Bridging Knowledge Gaps and Taking Action. [Panel discussion]. IAFP 2024 Annual Meeting, Long Beach, CA. https://iafp.confex.com/iafp/2024/onlineprogram.cgi/Session/9571

4. Burke J, de Leonardis D, Jorgens A, & Winkel, C. (2024, July 15). RT10 – Think Like a Criminal – The Dark World of Food Fraud. [Panel discussion]. IAFP 2024 Annual Meeting, Long Beach, CA. https://iafp.confex.com/iafp/2024/onlineprogram.cgi/Session/9766

5. Anandappa A, Overbuy K, Pantano A, Rainer N, & Yang L. (2024, July 17). S64 – Cultivating Meaty Cells – A Perspective Focus on Food Safety, Regulatory, and Experiences. [Conference symposium]. IAFP 2024 Annual Meeting, Long Beach, CA. https://iafp.confex.com/iafp/2024/onlineprogram.cgi/Session/9808

The post Industrial Food Safety: 2024 IAFP Meeting Recap appeared first on Real Milk.

The sale of raw milk for human consumption is legal in Nevada; however, a Nevada dairy cannot produce raw milk to be sold unless there is a county milk commission to regulate production and distribution; even if there is a county commission, the sale of raw milk and raw milk products the farm produces is legal only in that county, nowhere else in the state.[1] Currently, only one of the 16 counties in the state, Nye County, has a milk commission. A bill allowing statewide sales of raw milk, certified by a county milk commission, was vetoed by Governor Brian Sandoval in 2013.

The Nye County Raw Dairy Commission (NCRDC) formed in 2012.[2] Under state law, the commission must “adopt written regulations, which must be approved by the Director [of the Nevada Department of Agriculture] governing the production, distribution and sale in the county of certified raw milk and products made from it,…”[3] It is the commission that certifies the raw milk and raw milk products so they can be sold. The Director, as far as is known, never approved the regulations the Raw Milk Commission drafted and adopted in November 2015 [4] (per agenda and minutes for 11/18/2016) [5,6]. If the director had approved, a Nye County dairy would have had to comply with not only the commission’s regulations but also dozens of regulatory requirements issued by the Nevada Department of Agriculture that are found in the state administrative code, including extensive physical facility requirements—all this to sell milk in a county of around 56,000 people [7]; Nevada’s population is 3.2 million [8].

Herdshare agreements aren’t an option for raw milk producers in Nevada. Anyone selling or dispensing raw milk must have a permit issued by the state and be in compliance with all county and state regulations. Nevada law defines “sold or dispense” to mean “any transaction involving the transfer or dispensing of raw milk by barter or contractual agreement or in exchange for any form of compensation, including, but not limited to, the sale of shares or interest in a cow, goat or other lactating mammal or herd.”[9]

Sales of raw milk for animal consumption are legal but only if there is an “approved denaturant”[10] added to the milk; all the approved denaturants are toxic. There isn’t much opportunity for dairy farmers in Nevada these days, especially small-scale operators. There are around 20 Grade A dairies left in the state, ranging in size from 500 cows to over 25,000 [11]. Nevada dairy farmers have lost millions of dollars in raw milk sales to neighboring California; 2025 should be the year when the booming demand for raw milk moves the legislature to pass a law that actually gives raw milk producers a chance to make a living.

——-
1. Nev. Rev. Stat. Ann. 584.207 (NRS 584.207), https://www.leg.state.nv.us/nrs/nrs-584.html#NRS584Sec207
2. Commission created in 2012 by “Nye Ordinances Chapter 8.40 Raw Milk Commission”. See archived Notice of Public Hearing on Nye County Bill 2012-15, originally posted July 17, 2012. https://www.nyecountynv.gov/CivicAlerts.aspx?AID=212&ARC=485
3. Nevada statute NRS 584.207, clause 3(b) https://www.leg.state.nv.us/division/legal/lawlibrary/NRS/NRS-584.html#NRS584Sec207
4. Regulations of the Nye County Raw Milk Commission. Adopted November 11, 2015 per agenda and minutes for Nov. 18, 2015. https://nv-nyecounty.civicplus.com/DocumentCenter/View/29055/Item8?bidId=
5. Raw Milk Commission Agenda November 18, 2016. (2016, Nov 14) https://www.nyecountynv.gov/AgendaCenter/ViewFile/Agenda/_11182016-2101
6. Draft Meeting Minutes for Nye County Raw Dairy Commission. (2016, Nov 18). https://www.nyecountynv.gov/AgendaCenter/ViewFile/Minutes/_11182016-2101
7. worldpopulationreview.com/states/nevada/counties
8. worldpopulationreview.com/states/nevada-population
9. Nev. Rev. Stat. Ann. 584.207 (NRS 584.209), https://www.leg.state.nv.us/nrs/nrs-584.html#NRS584Sec209]
10. Ibid.
11. nevadamilk.com/on-the-farm/nevada-farms

The post Nevada: How the De Facto Ban Works appeared first on Real Milk.

Reneau’s is limiting government power, not surprising for someone who endured a combined three-year investigation of the Tennessee Department of Agriculture (TDA) and USDA’s Food Safety Inspection Service (FSIS), all in connection with providing nutrient-dense food to her community through a food buyers club. Reneau was able to turn this adversity into a major legislative success.

In 2016 Reneau along with Nate and Ajnu Wilson started the Weekly Fig, a private membership association that distributed raw milk, meat and other nutrient-dense foods from local farmers to members of the food buyers club. A passage in Weekly Fig’s Articles of Association stated, “We proclaim the freedom to choose and decide for ourselves, the types of products, services and methods that we think best for healthy eating and preventing illness and disease of our minds and bodies, and for achieving and maintaining optimal wellness. We proclaim and reserve the right to healthy food options that include, but are not limited to, cutting-edge discoveries and farming practices used by any types of healers or therapists or practitioners the world over, whether traditional or non-traditional, conventional or non-conventional.” 

Weekly Fig rented out space to handle the storage and distribution of farm-produced food to its members; a short time after it had been in operation, a health department inspector barged in on the facility and conducted an unauthorized, warrantless inspection. The health department subsequently issued the Weekly Fig citations for not having the proper licenses for what they were doing. Soon after, TDA became involved sending its own inspector over to the facility. Reneau refused to let the inspector in, claiming TDA did not have jurisdiction over a private buyers club distributing food only to its members. TDA followed up by sending a warning letter to Weekly Fig stating, among other violations, that it was illegally operating a food establishment without a license and offering raw milk for sale. When TDA and the buyers club couldn’t come to a resolution on the matter, the department sent further correspondence to Weekly Fig putting Reneau and the Wilsons on notice that “future violations of the same or similar sort, i.e., unlicensed operation as a food establishment or sale of raw milk—will be considered grounds for the department to seek actions for injunction and or criminal charges.”

TDA did not take an enforcement action against Weekly Fig, but the threat of one remained over its head; so, when the 2017 Tennessee legislative session rolled around, Reneau contacted State Senator Frank Niceley to see if he could help the food buyers club with legislation.  Niceley introduced Senate Bill 651 (SB 651) which established that there was no regulation or licensing requirement for a “farm to consumer distribution point.“ Reneau testified at a Senate committee hearing for the bill; on May 11, 2017, SB651 was signed into law. A law distinguishing between the public and private distribution of food was now on the books—a major victory for food buyers clubs and farmers in Tennessee.

Unfortunately, Reneau’s problems did not end, even though there was no longer a conflict with TDA. Shortly before SB 651 became law, the Weekly Fig received a visit from two FSIS officials seeking to inspect the facility and the freezers in it. Reneau refused to let them in, telling them this was a private membership association and that, unless they had a warrant, they could not conduct an inspection of the facility.

FSIS Inspectors attempted a second inspection, and Reneau refused them again. When the inspectors provided her with copies of the laws they claimed gave them authority to inspect, she told them those laws apply to the general public, not a private membership association. In battling FSIS, Reneau showed the same courage and tenacity she did in her dispute with TDA—not accepting the government’s general assertions of authority and contesting the regulators point by point, asking for specific citations in the law to back up their claims. She grudgingly gave up ground to regulators, standing on her belief that there is a legal distinction between the public and private distribution of food.

Reneau said, “My whole life I have typically been a law-abider. I very much have a great respect for authority. It became very clear to me though, in my journey over the last 10 years with health and food and medical, that I need to be cautious about any authority exerted from those places because they had already proven themselves wrong in many cases.”

FSIS sent warning letters to Reneau and Weekly Fig after the attempted inspections and subsequently filed a court action to inspect the facility and look at the buyers club’s records. During the standoff, Reneau decided to shut down the Weekly Fig when it lost its lease and a suitable replacement within its budget could not be found; being pregnant with her fifth child made the decision easier to discontinue with the day-to-day operations. Nevertheless, FSIS pressed on with the case seeking records from the Weekly Fig.

In April 2019, Reneau had a court hearing, attending it while 37 weeks pregnant; the judge ordered that she appear for a deposition and bring buyers club records. The deposition took place in July 2019; Reneau brought her two-month-old baby with her—nursing the baby throughout the questioning from DOJ and USDA attorneys. She was worried about protecting the privacy of her club members and farmers; as it turned out, the deposition was more about getting the matter off FSIS’s desk—after two years, the federal investigation of Weekly Fig was over.

Through her experience with the Weekly Fig, Reneau has seen a side of government that most have not. She says, “I would just like to see less of the government making decisions on behalf of people as it affects their private lives. We should be able to make decisions for ourselves as long as it is not impacting other people … I just feel like the government has taken too much of a role in private life and that is where I would like to see things shift.”

Michele Reneau is active in defending faith, family and freedom, and constitutional rights—including the fundamental rights of parents to direct the upbringing, health and education of their children according to their values and beliefs. Acting on the courage of her convictions, she is someone who walks the talk.

The post How One Weston Price Chapter Leader Made an Impact appeared first on Real Milk.

Niceley, an honorary board member of the Weston A. Price Foundation (WAPF), is one of the more productive and liberty-minded legislators in the country and an effective advocate in Nashville (the state capital) not only for his own constituents but also for numerous other Tennessee residents, especially farmers. It’s common for farmers around the state to contact Niceley, a fifth-generation cattle farmer, for help instead of their own legislators if they are having an issue with a regulator or government agency, be it state or federal.

The successful legislation he has sponsored and policies he has helped implement as both a state representative and state senator have made a huge impact on small farmers and local artisan food producers and many others in Tennessee. In his latest term, Niceley sponsored successful bills legalizing the over-the-counter sale of ivermectin (Tennessee was the first state to do so), taking the sales tax off gold and silver coins, legalizing the unlicensed, unregulated sale of cottage foods not only direct from the producer to the consumer but also to third parties such as grocery stores, and establishing a state meat inspection program.

Niceley has done more to deregulate local food production and distribution than anyone in the past 15 years, enabling family farms and local artisans to have a better chance to make a living. His list of accomplishments include:

2009 [HB 720]
Sponsored bill legalizing the distribution of raw milk through herdshare agreements. In 2012 Niceley followed up on that bill by getting an Attorney General’s opinion that it was legal to distribute other raw dairy products through a herdshare agreement as well.

2012
Got an Attorney General’s opinion that farmers didn’t need a permit to sell eggs from their own farm.

2014 [SB 1707]
Sponsored a bill adopting the federal poultry exemption enabling farmers to process up to 20,000 birds a year. The Tennessee Department of Agriculture has since expanded the exemption by policy to include processing rabbit meat on the farm.

Before the bill passed, Tennessee had one of the worst regulatory climates for on-farm poultry processing in the country; during that time, the Farm-to-Consumer Legal Defense Fund (FTCLDF) received a call from a poultry farmer in Bristol, Tennessee, getting ready to move across the state line to Bristol, Virginia, because he was so fed up with the restrictive laws and policies on on-farm poultry processing.

2017 [SB 343]

Sponsored a bill adopting the federal exemption on custom slaughter and the exemption on non-amenable species. The latter exemption allows the sale of meat from animals such as bison and domestically raised deer that are slaughtered and processed at a custom facility.

2017 [SB 651]
When Weston A. Price Foundation (WAPF) chapter leader, Michele Reneau, was threatened with prosecution because the food buyers club she co-managed did not have a permit, Niceley passed a bill, exempting food buyers clubs from licensing and regulation.

2017
Received Attorney General’s opinion stating that there can be an unlimited number of owners for an animal slaughtered and processed at a custom facility and that entities such as a food buyers club can be an owner of such a custom animal.

2019 [SB 358]
Sponsored bill legalizing sales of raw butter by licensed dairies.

2020 [SB 2049]
Sponsored a bill requiring that any meat labeled as a product of Tennessee must be from an animal that was born and raised in the state.

2020 [SJR 841]
Sponsored a resolution commending the Weston Price Foundation for its 50-50 Campaign urging people to buy at least 50% of their food budget direct from the farm.

2022 [SB 693]
Sponsored the Tennessee Food Freedom Act legalizing the unlicensed unregulated sale from homemade food producers of food that does not require time and temperature control for safety, including fermented foods; these sales can be direct to consumers and also by some third parties such as food buyers clubs and grocery stores.

2023 [SB 123]
Sponsored the bill to establish a State Meat Inspection program in Tennessee; like many states, Tennessee has a shortage of federally, inspected slaughterhouses, especially in the eastern half of the state.

2024 [SB 1914]
Sponsored a bill providing for vending machines with whole milk in the schools, giving children a more nutritious option while still preserving federal funding for Tennessee’s school lunch program. The federal rule that withdraws funding from Washington if whole milk is served in a school lunch has worsened children’s health and the economic condition of the dairy industry.

Niceley‘s work impacts the local food movement around the rest of the U.S. as well. The first thing legislators typically ask when a constituent requests that they introduce a bill is: “Has this been done elsewhere?”

The senator has introduced and helped pass a number of bills that were law in few, if any, states outside Tennessee. In the 2024 session he helped pass a bill defining and regulating as a drug any food that contained “a vaccine or vaccine material.”

Legislation he introduced this past session includes: a constitutional resolution to protect the individuals right to grow and acquire the food of their choice [SJR 902]; a bill that would have barred any prohibition on the growing of produce and the raising of chicken or meat rabbits on a residential lot [SB 1761]; a bill that would have exempted farms from any vaccine mandate for their livestock or poultry, if the farms practice was not to vaccinate their livestock or poultry [SB 2543]; and legislation that would have prohibited cell-cultured meat from being defined as “meat” [SB 2603].

Niceley has been generous with his time in helping legislators, farmers and eaters in other states working on food and agriculture bills. As for Tennessee, there is no one who has done as much for the small farmer and local food producer in that state as Frank Niceley.

[Photo credit: Solari.com “Blast from the Past“]

The post The Farmers’ Legislator appeared first on Real Milk.

Few of us were born when the forces for milk pasteurization launched the first major attack on Nature’s perfect food.  In 1945, a magazine called Coronet published an article, “Raw Milk Can Kill You,” blaming raw milk for an outbreak of brucellosis in a town called Crossroads, U.S.A., killing one-third of the inhabitants.  The Reader’s Digest picked up the story and ran it a year later.

Just one problem with this piece of “reporting.”  There was no town called Crossroads and no outbreak of brucellosis.  The whole story was a fabrication—otherwise known as a lie.  And lies about raw milk have continued ever since. Unfortunately, the fictitious Crossroads story paved the way for laws against selling raw milk, starting with Michigan in 1948.

Here’s another example of lies against raw milk (which I referenced in an earlier post, but it is worth repeating). In 2007, John F. Sheehan, BSc (Dy), JD, US Food & Drug Administration, Center for Food Safety & Applied Nutrition (USFDA/CFSAN), Division of Dairy and Egg Safety, prepared a PowerPoint maligning raw milk; it was presented to the 2005 National Conference on Interstate Milk Shipments (NCIMS) by Cindy Leonard, MS.

As shown in the table below, all of the fifteen reports associating outbreaks of foodborne illness with raw milk that Sheehan cites are seriously flawed. For example, in two of the fifteen, the study authors presented no evidence that anyone consumed raw milk products and in one of them, the outbreak did not even exist. Not one of the studies showed that pasteurization would have prevented the outbreak.

Fast forward to the present and the ruckus about bird flu in dairy cows—more lies, very clever lies, but lies nevertheless.

In a press release dated March 25, 2024 , the U.S. Department of Agriculture (USDA), Food and Drug Administration (FDA) and Centers for Disease Control and Prevention (CDC), as well as state veterinary and public health officials, announced investigation of “an illness among primarily older dairy cows in Texas, Kansas, and New Mexico that is causing decreased lactation, low appetite, and other symptoms.”

The agencies claim that samples of unpasteurized milk from sick cattle in Kansas and Texas have tested positive for “highly pathogenic avian influenza (HPAI).” Officials blame the outbreak on contact with “wild migratory birds” and possibly from transmission between cattle. The press release specifically warns against consumption of raw milk, a warning repeated in numerous publications and Internet postings.

According to the press release, national laboratories have confirmed the presence of HPAI (Highly Pathogenic Avian Influenza) through testing, but it does not reveal the type of test used to detect this so-called viral illness.

The first lie:   Researchers have found HPAI virus in the milk of sick cows.

Officials have NOT found any viruses in the milk or any other secretions of the sick cows. The CDC has yet to reply to repeated requests for proof of finding the isolated HPAI virus in any fluid of any sick chicken or other animal. Nor have health and agriculture agencies in Canada, Japan, the UK and Europe provided any proof of an isolated avian influenza virus.

As for all the studies you can find in a PubMed search claiming “isolation” of a virus, not one of them shows the true isolation of a virus, any virus, from the fluids (phlegm, blood, urine, lung fluids, etc.) of any animal, bird or human.

The truth is that “viruses” serve as the whipping boy for environmental toxins, and in the confinement animal system, there are lots of them–hydrogen sulfide, carbon dioxide, methane and ammonia from excrement, for example. Then there are toxins in the feed, such as arsenic added to chicken feed, and mycotoxins, tropane and β-carboline alkaloids in soybean meal. By blaming nonexistent viruses, agriculture officials can avoid stepping on any big industry toes nor add to the increasing public disgust with the confinement animal system. Way back in 2006, researchers Crowe and Englebrecht published an article entitled, “Avian flu virus H5N1: No proof for existence, pathogenicity, or pandemic potential; non-‘H5N1’z causation omitted.” Nothing has changed since then.

Here’s your homework assignment:  Contact USDA at Aphispress@usda.gov and ask them to provide proof of the isolation of the HPAI virus or any virus in the milk of the sick cattle.

SECOND LIE: National laboratories have confirmed the presence of HPAI (Highly Pathogenic Avian Influenza) through testing.

They don’t say anything about the kind of test they used, but it almost certainly was the PCR (polymerase chain reaction) test. The PCR test detects genetic material from a pathogen or abnormal cell sample and allows researchers to make many copies of a small section of DNA or RNA. The test was not designed to determine or diagnose disease, it was designed to amplify or increase a certain piece of genetic material.

Each “amplification” is a doubling of the material.  If you amplify thirty times you will get a negative; amplify 36 times or more, and you will get a positive.  At 60 amplifications, everyone will “test positive” for whatever bit of genetic material you believe can cause disease. If you want to show that you have a pandemic brewing, just amplify, amplify, amplify. Folks, this is not a valid test, not good science by any stretch of the imagination—especially as there is no virus to begin with. How many times did our health officials amplify the samples they obtained from the milk of the sick cows?  Be sure to ask them when you email Aphispress@usda.gov for proof of the virus.

THIRD lie: The “virus” is highly pathogenic.

According to the Wall Street Journal, one—just one–person working in the dairies got sick and tested positive for avian influenza after exposure to dairy cattle presumed to be infected with the H5N1 bird flu.  The person reported eye redness, or conjunctivitis, as his only symptom—a symptom that can be explained by exposure to any of the many airborne toxins in confinement dairies, or even to toxic EMF such as 5G.  (How are they treating the illness? With vitamin A and herbal eyedrops?  No, the poor sod is getting treatment with a toxic antiviral drug.)

According to the CDC, the disease in humans ranges from mild infections, which include upper-respiratory and eye-related symptoms, to severe pneumonia.  If the “virus” is so highly pathogenic, we’d expect a lot of workers working around these sick cows to end up in the hospital. . . but we’ve heard of none so far.

FOURTH LIE: You can get avian flu from drinking raw milk, but pasteurized milk is safe

According to medical biologist Peg Coleman, “Recent risk communications from CDC, FDA, and USDA regarding transmission of highly pathogenic avian influenza virus or HPAI (subtype H5N1) to humans via raw milk include no supporting evidence of viral transmission from raw milk to humans in the peer-reviewed literature. . . An extensive body of scientific evidence from the peer-reviewed literature . . . does not support the assumption by these US government agencies that [non-existent] HPAI transmits to humans via milkborne or foodborne routes and causes disease. Nor does the scientific evidence support the recommendation that consumers should avoid raw milk and raw milk products [emphasis in the original].”

Coleman notes the suite of bioactive components in raw milk, including bovine milk, that destroy pathogens and strengthen the gut wall. “Many of these bioactive components of raw milk are . . . sensitive to heat and may be absent, inactive, or present in lower concentrations in pasteurized milks. . . Cross-disciplinary evidence demonstrates that raw milk from healthy cows is not inherently dangerous, consistent with the CDC evidence of trends for 2005-2020 and evidence of benefits and risks. There is no scientific evidence that HPAI in raw milk causes human disease.”

And while USDA, FDA and CDC assure the public that pasteurization will make milk safe, they note that “Milk from infected animals is being diverted or destroyed,” implying that pasteurization alone does not guarantee safety. In any event, sales of industrial pasteurized milk continue their relentless decline.

Fortunately, raw milk drinkers are already skeptical of government pronouncements and are skilled at seeing through lies.  Both large and small raw milk dairy farms report that sales are booming. The current bird flu fracas is just another Crossroads, U.S.A., a bunch of lies fostered by a dishonest dairy industry taking aim at the competition.

The post Raw Milk at the Crossroads…Again appeared first on Real Milk.

On March 9 House Bill 4911 (HB 4911) became law; the bill provides, in part, that “raw milk may be sold by a seller in West Virginia to a consumer in West Virginia.” The new law takes effect June 7th.

The bill legalizes the sales of raw milk in retail stores; there is a labeling requirement that includes the warning statement, “Consuming unpasteurized raw milk may increase your risk of foodborne illness, especially for children, elderly, immunocompromise individuals, and persons with certain medical conditions.”

Under HB 4911, the Commissioner of Agriculture may issue regulations “in compliance with raw milk dairy industry standards.” HB 4911 initially had a clause providing that producers weren’t liable for illness attributed to milk consumption unless they intentionally contaminated the milk, but a Senate amendment to the bill cut out that provision. Courts don’t favor liability waivers for foodborne illness.

A decade ago, West Virginia had the most strict raw milk laws in the country banning sales both for human consumption and for pet consumption as well as prohibiting herdshare agreements. In 2016 the state legislature passed a bill legalizing herdshares, but that new law never took hold with raw milk producers; the law had costly testing requirements and also required farmers to file copies of each herdshare contract they had with the Commissioner of Agriculture.

HP 4911 passed through the House and Senate by big margins and became law when Governor Jim Justice did not take action on the bill (state law requires the governor to veto the bill within 15 days from the time it reaches his desk).

Congratulations to the bill’s lead sponsor, Delegate Michael Hornby (R) and West Virginia raw milk producers and consumers. Soon the Real Milk Legal Map will reflect this change for West Virginia.

Last updated 7/30/24, removed “Retail” from graphic

The post West Virginia: Bill Legalizing Raw Milk Sales Now Law appeared first on Real Milk.

The most important legislation for the local food movement that has been before Congress the past eight years has been the Processing Revival and Intrastate Meat Exemption Act, known as the PRIME Act; in this current session, the bill has been introduced as House Resolution 2814 (HR 2814) [1] and Senate Bill 907 (S. 907) [2]. The PRIME Act would allow states to pass laws legalizing the sale of custom slaughtered and processed meat in intrastate commerce; the lack of slaughterhouse infrastructure throughout most of the U.S. is the biggest weakness of the local food system. Under current law, only the owners of an animal can receive the meat slaughtered and processed at a custom facility; only meat from an animal slaughtered and processed at a federal- or state-inspected facility can be sold.

The PRIME Act would amend the Wholesome Meat Act of 1967 (WMA), the legislation that established these requirements. Unless you are an oligopolist, the WMA has been a disaster. At the time the act passed into law, there were around 9,600 slaughterhouses in the U.S. [3];  the country’s population at the time was around 200 million. Today there are between 2,800 and 2,900 slaughterhouses [4] in the country and the current U.S. population is around 335 million. Four companies now control over 80% of beef processing in the U.S., and four companies control over 60% of pork processing [5].

There has never been a better chance to pass this bill than now. Congress is currently in the process of writing up the 2023 Farm Bill. The PRIME Act has a legitimate chance to be included in the Farm Bill; it has much less chance to pass as a standalone. Giving the bill momentum was a congressional hearing in June that the House Judiciary Subcommittee on the Administrative State, Regulatory Reform and Antitrust held titled, “Where’s the Beef? Regulatory Barriers to Entry and Competition in Meat Processing” [6]; the PRIME Act was a focus of the hearing. Farmer/slaughterhouse owner Joel Salatin testified on how it could be a solution to the difficulties small farmers and ranchers have in meeting demand for local meat with the current laws in place that favor the big meatpackers.

Congressman Thomas Massie, a cattle farmer representing Kentucky’s 4th district, is the lead sponsor for HR 2814 as he has been since he first introduced the PRIME Act in 2015. Adding more urgency to the need to have the legislation included in the 2023 Farm Bill is a statement Massie made in a Washington Post interview earlier this year, indicating that he might serve only one more term [7], meaning he wouldn’t be around when the next Farm Bill would be deliberated in 2028. There is no one in Congress who would put in anywhere near the time and resources to pass the PRIME Act that Massie has; neither is there anyone who has the expertise on the matter that he does.

To say passage of the PRIME Act is badly needed is a huge understatement. Demand for locally produced meat is booming, but it is difficult for farmers and ranchers to meet that demand with the lack of access to slaughterhouses under inspection. Right now in parts of the country, farmers have to book a slaughterhouse slot as much as 1-1/2 to 2 years in advance. Moreover, farmers often have to transport their animals several hours to an inspected slaughterhouse, increasing their expenses and stressing out the animals which could affect the quality of the meat. The majority of livestock farmers live closer to a custom slaughterhouse than an inspected slaughterhouse.

Aside from better enabling farmers to meet the demand for local meat, passage of the PRIME Act could begin the long-overdue process of decentralizing meat production in the U.S.  According to USDA data from 2022 [8], 52 federally inspected slaughterhouses account for around 93% of the cattle slaughtered in the U.S.; 60 federally inspected facilities account for nearly 98% of the hogs slaughtered in the country. This centralization along with the supply chain breakdowns and labor shortages of the past few years has made the meat supply more vulnerable as well as leading to a decline in quality. It’s likely that passage of the PRIME Act would initially impact a fraction of 1% of meat production, but its revival of the community abattoir would improve food security through increased self-sufficiency at the local level.

Massie said several years ago that he knew of 1,000 shuttered slaughterhouses in the country whose owners would re-open if the PRIME Act became law; the owners did not want to run a business if an inspector was present each time they were slaughtering animals (government regulators typically inspect a custom house only once or twice a year). The owners did not believe they could generate enough revenue operating under laws prohibiting the sale of meat slaughtered and/or processed at a custom facility.

The only argument the opposition to HR 2814 has is food safety, but the data shows they don’t even have that. In response to a Freedom of Information Act (FOIA) request filed by the Texas nonprofit Farm and Ranch Freedom Alliance (FARFA), the USDA acknowledged that between 2012 and 2020 there were no cases of foodborne illness due to the consumption of custom slaughtered and processed meat [9]. By contrast, according to the Centers for Disease Control (CDC) between 2005 and 2020, over 6,000 cases of foodborne illness were attributed to beef and pork consumption [10]; the likelihood is that all or nearly all that meat was slaughtered in big USDA facilities that process 300-400 cattle per hour. The big plants process more animals in a day than a custom house would in a year. There is better quality control in a custom facility, inspector or no inspector.

A key part of food safety is traceability–another advantage meat from a custom house has over meat from one of the big USDA facilities. A hamburger in the industrial food system could come from hundreds of cattle raised in multiple states and countries; a hamburger from a custom facility is going to be from one cow.

Increasing the amount of locally produced meat available for consumption would not only benefit food security and food safety but also human health and the economy. With passage of the PRIME Act, there would be less money spent on, and less demand for, resources of the healthcare system—freeing up money to be spent in more productive areas of the economy. The records on foodborne illness outbreaks indicate that a higher percentage of people per serving who consume meat produced by the big plants of the conventional industry cost the healthcare system more money than the people who obtain locally produced meat from small farmers and ranchers. The likelihood is also that people who purchase locally produced meat place less demand for resources on the medical system in the treatment of chronic disease then do those who buy their meat from the industrial system.

Beyond the deterioration of quality the centralization of meat production has caused, there is another development in the conventional industry making passage of the PRIME Act imperative: the production and marketing of alternative proteins, such as cell-cultured meat and insects. Industry has spent billions in the development of alternative proteins even though there is little or no demand for them—with two of the major meatpackers, Tyson and Cargill, being investors. The question is: what will the ruling establishment do to help industry get a return on its investment? Will it involve enforcing policies that will make animal proteins less available? The best response to the ruling elites’ plans is to build out a parallel food system as independent of federal control as possible; a robust slaughterhouse infrastructure will be a centerpiece of that system. The PRIME Act will be a catalyst in making that happen–moving the system towards a day when the local abattoir will once again dot the countryside.‍

References‍

[1]  U.S. Congress. (2023). House Resolution 2814. [PDF]. Introduced April 25, 2023. PDF accessed at https://www.congress.gov/bill/118th-congress/house-bill/2814/text‍

[2]  U.S. Congress. (2023). Senate Bill 907. [PDF]. Introduced March 22, 2023. PDF accessed at https://www.congress.gov/bill/118th-congress/senate-bill/907/text

[3] USDA, Statistical Reporting Service Crop Reporting Board. (1969). Annual Livestock Slaughter, April 1969. [PDF] “Table 20 – Number of Livestock Slaughtering Establishments, March 1, 1967, 1968, 1969”, p. 35. PDF accessed at https://usda.library.cornell.edu/concern/publications/r207tp32d

[4] USDA, National Agriculture Statistics Service. (2023). Livestock Slaughter 2022 Summary (April 2023). [PDF]. [Table – “Livestock Slaughter Plants by Type of Inspection – States and United States: January 1, 2022 and 2023″ Inspected Percent of Total Commercial Slaughter by Species, Month, and Total – United States: 2022 and 2021 Total”, p. 62]. PDF accessed at https://usda.library.cornell.edu/concern/publications/r207tp32d

[5] James, H.S., Hendrickson, M.K., and Howard, P.H. (2012, February). Networks, Power and Dependency in the Agrifood Industry. Department of Agricultural & Applied Economics Working Paper. College of Agriculture, Food and Natural Resources: University of Missouri. Available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2004496 (Accessed: 7 September 2023). [See  “Table 1 – Concentration ratios and dominant firms for selected agrifood sector”, p. 32]

[6] Forbes Breaking News. (2023, June 13). ‘Where’s The Beef?’: Thomas Massie Leads House Judiciary Committee Hearing On Meat Industry. [Video]. YouTube.com. https://youtu.be/jky4-J-Tsc0?si=qfEkqL2BsH9rATQF‍

[7] Will, G.F. (2023, June 22). “Meet the implacable, off-the-grid libertarian working to energize Congress”. The Washington Post. https://www.washingtonpost.com/opinions/2023/06/21/kentucky-republican-thomas-massie-congressional-plan/‍

[8] USDA, National Agriculture Statistics Service. (2023). Livestock Slaughter 2022 Summary (April 2023). [PDF]. [calculated from tables on pp. 8 and 61]. PDF accessed at https://usda.library.cornell.edu/concern/publications/r207tp32d‍

[9] USDA. (2020, June 25). [Foodborne illness from custom meat]. FOIA response, 2020-FSIS-00397-F.

[10] Centers for Disease Control and Prevention (CDC). (2021, May 26). Access® database for outbreaks reported from 2005 to 2020 from all transmission sources (food, water, animal contact, environmental, and person-to-person) [Data set]. Provided by Hannah Lawinger, CDC NORS Data Request Manager.

The post THE TIME FOR PRIME IS NOW! appeared first on Real Milk.

Blog post first published July 19, 2023. Updated for journal publication and republished September 30, 2023.

Graphic: Real Milk Legal Map [1]

View the updated Raw Milk Legal Map, color index, and state-by-state status

Over the past decade or so, a growing number of states have passed laws to either legalize the sale of raw milk and raw milk products or increase access to raw dairy; no year has been as productive as 2023. Resistance from the dairy industry and public health agencies is not as great as it once was, and demand for raw dairy products is increasing rapidly. Through either statute, regulation or policy, 46 states now allow the sale of raw milk for human consumption, the sale of raw milk for pet consumption, or the distribution of raw milk through herdshare agreements.¹ The four outliers prohibiting any sale or distribution of raw milk are Hawaii, Louisiana, Nevada, and Rhode Island.

LEGISLATION

The states passing raw dairy legislation this year include:

• IDAHO – Senate Bill 1036 (SB 1036) removes the limit on dairy animals that herdshare operations can have; under prior law, herds were limited to seven cows, fifteen goats, or fifteen sheep.
• IOWA – Iowa became the 46th state to legalize raw milk sales or distribution when Senate File 315 (SF 315) passed into law. The bill allows the sale from producer direct to consumer on the farm or through delivery of any dairy product. There are testing, labeling and recordkeeping requirements.
• NORTH DAKOTA – House Bill 1515 (HB 1515) legalized the unregulated sale of raw milk and any other raw dairy products from producer direct to consumer. Under prior law only distribution of raw milk and raw milk products through herdshare agreements was legal. HB 1515 originally allowed only Grade A dairies (who produce milk for pasteurization) to sell raw milk to the consumer, but those supporting raw milk sales by all dairies hijacked the bill, turning it into the version that passed. The North Dakota Department of Agriculture (NDDA) has issued a press release² claiming that sales are limited to raw milk only (and not other raw dairy products) under HB 1515 even though the bill states that farms selling raw milk direct to consumers aren’t subject to any provision of the chapter in the North Dakota statutory code, titled “Dairy Product Regulation.”³
• UTAH – House Bill 320 (HB 320) legalizes retail sales of raw milk and any product produced from raw milk if a licensed producer has a majority ownership in the retail store. Licensees may also sell these products on-farm as well deliver and/or sell via refrigerated mobile unit. Prior law limited the raw dairy products licensees could sell to milk, butter, and cream. sell via refrigerated mobile unit. HB 320 marks the fourth raw milk bill since 2015 that the mother-daughter team of Symbria and Sara Patterson, founders of the nonprofit Red Acre Center, have been responsible for passing.
• WYOMING – Senate Bill 102 (SB 102) allows the sale of any raw dairy products produced by unregulated producers in retail stores. Prior law limited transactions to direct-to-consumer. When it comes to food freedom of choice, Wyoming remains way ahead of the curve; allowing any raw dairy products produced by an unregulated farmer to be sold in a retail store would be unfathomable in any other state. How much raw dairy is sold in Wyoming retail stores will likely be determined by what stores’ requirements for a producer to obtain product liability insurance are; it is difficult enough for regulated raw milk producers to get a product liability policy.

The biggest development in 2023 was in Iowa, a state that had once jailed someone for selling raw milk. Senator Jason Schultz (R) and farmer Tom German had been trying for 17 years to legalize raw milk sales in the state. A difference maker this time around was dairy farmer Esther Arkfeld, a mother with young children, who was the face of the effort to legalize raw milk sales in Iowa. Lobbyist Tyler Raygor of Americans for Prosperity (AFP) also helped; Raygor and another member of AFP were the only ones who registered with the state to lobby for the bill; 24 people—representing government agencies, the dairy industry, and Farm Bureau among other organizations—registered to lobby against SF 315.

The national opposition to further legalization of raw milk sales in any state made Iowa a litmus test. Mary McGonigle-Martin, a board member of the national food safety group Stop Foodborne Illness said, “Public health has lost the war on raw milk”⁴. McGonigle-Martin had testified four different times in opposition to Iowa raw milk bills. Passage of SF 315 into law struck a nerve with the mainstream media, which published more stories about raw milk after the Iowa law went into effect than it had in years. USA Today, the New York Times and Forbes, among other major media, ran stories warning about the “health risks” of drinking raw milk in an attempt to dissuade their readers from joining the millions of people who are already consuming the product.

A trend in recent years that accelerated in 2023 was the legalization of the sale of raw dairy products other than milk. In addition to Iowa, North Dakota, Utah, and Wyoming, laws have also gone into effect since 2021 in Alaska, Montana, New Hampshire, and Texas, allowing the sale of numerous products made from raw milk. Value-added is where the money is at; the trend bodes well for the ability of small-scale dairy farmers to make a living. It appears that the dairy processing lobby is no longer fighting the legalization of value-added raw dairy sales like they once did.

The food safety argument–the only argument the opposition has staked its stance on–is increasingly in favor of raw milk proponents. The latest foodborne illness outbreak figures from the Centers for Disease Control (CDC) are that in 2020 there were five foodborne illness outbreaks resulting in 28 illnesses that were attributed to raw milk consumption.⁵ The number of raw milk consumers continues to increase considerably; hundreds of thousands of consumers go to realmilk.com each year for the first time to find a source of raw milk in their state. The number of illnesses attributed to raw milk consumption is significantly less than it was a decade ago.

Increased demand, fewer illnesses, and deteriorating quality in the conventional food supply are a formula for raw milk legalization. The next state to lift the prohibition on any raw milk sales or distribution could be Hawaii. That state has had bills for legalizing raw milk sales by micro dairies passed out of the House the last two years only to die in Senate committee.  There is only one dairy producing raw milk for pasteurization in Hawaii. For reasons of food security alone, a raw milk bill there should pass into law.

Whichever of the four remaining states is next to get rid of the ban, the goal of Weston A. Price Foundation President Sally Fallon Morell to have legal raw milk distribution in every state is getting closer to realization.

REGULATION CHANGE

MISSISSIPPI: Until recently, Mississippi allowed the sale of only raw goat milk, and then only if the farm had nine goats or fewer. Thanks to state Agriculture Commissioner Andy Gipson, that has now changed per the policy of the Mississippi Department of Agriculture. Under the policy, distribution of raw milk (including cow’s milk) through herdshare agreements is legal; there has been some pushback from the state department of health, but the policy remains in place. Farm-to-Consumer Legal Defense Fund (FTCLDF) has written herdshare contracts for its Mississippi members. Gipson has been one of the more progressive agriculture commissioners in the country. In 2020 he adopted a policy on distribution of meat from custom slaughtered and processed animals—better enabling small farmers and ranchers to make a living—by removing the limit on the number of owners there could be for a custom animal. Prior to becoming commissioner, Gibson served in the Mississippi legislature where he supported several food freedom bills, including legislation to legalize the sale of raw cow’s milk.

COURT CASE: TEST CASE FOR MAINE FOOD SOVEREIGNTY ACT

An important case from Maine Food Sovereignty Act (FSA) and possibly the state’s Right to Food Constitutional Amendment (RTFA) is ongoing in Kennebec Superior Court. Nathan and Rhiannon Deschaine, owners of Kenduskeag Kitchen, their customer Frank Roma, and the Farm-to-Consumer Legal Defense Fund (FTCLDF) have sued Jeanne Landrew, Commissioner of the state Department of Health and Human Services (DHHS), for violations of the FSA and the RTFA. The Deschaines prepare and sell home-cooked meals in Kenduskeag, a town which per the FSA, has passed an ordinance allowing the unregulated sale of most foods direct from the producer to consumer. The FSA gives towns and cities in Maine, the power to adopt ordinances legalizing unregulated local producer-to-consumer commerce within their boundaries.

DHHS sent an enforcement letter to the Deschaines in October 2022, claiming that the couple needed a license to operate their business because, among other reasons, “Kenduskeag Kitchen does not meet [the] definition of direct producer to consumer transactions because it is preparing and selling meals that contain food products and/or ingredients that are purchased from other sites.” The FSA contains no restriction that producers engaging in unregulated commerce under a town ordinance are limited to preparing food with only ingredients that they grow.

Roma is suing DHHS for a violation of the RTFA, which gives individuals the right “… to consume the food of their own choosing …as long as an individual does not commit trespassing, theft, poaching, or other abuses of private property rights, public lands, or natural resources in the harvesting, production or acquisition of food.” Plaintiffs are seeking to have DHHS enjoined from regulating the operation of Kenduskeag Kitchen and requiring it to be licensed; the department has filed a motion to dismiss the lawsuit. A favorable resolution to the case for
the Deschaines, Roma and FTCLDF should lead to a more expansive interpretation of the FSA and RTFA statewide, improving food security and food quality in Maine.

This article was originally a blog post on realmilk.com, and then updated and published in the Fall  2023 issue of Wise Traditions in Food, Farming, and the Healing Arts, the quarterly journal of the Weston A. Price Foundation.

References

1. WAPF, Raw Milk Legal Map and State-by-State Notes, latest update July 11, 2023. https://www.realmilk.com/realmilk-legal-map/
2. NDDA, “Raw milk sales now legal, limited to fluid milk,” [Press release], August 4, 2023. https://www.ndda.nd.gov/news/raw-milk-sales-now-legal-limited-fluid-milk
3. North Dakota Century Code, Chapter 4.1-25, “Dairy Product Regulation,” p. 10 (point 3 of clause 4.1-25-40.1). https://ndlegis.gov/cencode/t04-1c25.pdf#nameddest=4p1-25-40p1
4. Tony Leys “Public Health Has Lost the War – States legalize raw milk, despite public health warnings,” USA Today, July 3, 2023. https://www.usatoday.com/story/news/nation/2023/07/03/raw-milk-legalized-states-unpasteruizeddisease-risks-public-health/70369454007/
5. Centers for Disease Control and Prevention (CDC). Access® database for outbreaks reported from 2005 to 2020 from all transmission sources (food, water, animal contact, environmental, and person-to-person) provided by Hannah Lawinger, CDC NORS Data Request Manager on May 26, 2021.

The post Big Year for Raw Milk in State Houses appeared first on Real Milk.

Most states have adopted as law the model publication of the Association of the American Feed Control Officials (AAFCO), a document that governs the production and distribution of commercial feed, including pet food. There is a section in the model publication on feed terms which provides a definition for “milk”; the definition does not state that the milk must be pasteurized. Any state that adopts the feed terms section has legalized the sale of raw pet milk unless its statutes or regulations state otherwise.

Farmers wanting to sell raw pet milk in most states will either apply for a commercial feed permit or file an application for registration with the state department of agriculture; part of the process also includes submitting labels for the raw dairy products the farmer wants to sell. States typically require that the labels contain the statement “for animal consumption only“ or “for dogs and cats.” It is not the producer’s legal responsibility to follow their customers home to find out who is actually consuming the raw pet milk but if customers make it clear that they will be using the milk for human consumption then the farmers are running the risk of a misbranding charge if they go through with the sale. In this context, misbranding means knowingly selling a product for a purpose other than the purpose indicated on the label. There are some states such as Nevada that require a toxic dye or denaturant be added to the milk; in trying to prevent humans from consuming raw pet milk, these states are destroying the market for the product—people aren’t interested in poisoning their pets.

States shouldn’t be able to deny a license or registration application to sell raw pet milk when their laws allow it. Hopefully, more states will be approving farmers to sell raw pet dairy going forward.

Photo credit: More States Allowing Farmers to Sell Raw Pet Milk appeared first on Real Milk.

The largest food safety conference in the world took place from July 31 to August 3 when the International Association for Food Protection (IAFP) held its annual meeting in Pittsburgh. IAFP’s mission is “to provide food safety professionals worldwide with a forum to exchange information on protecting the food supply.”1 More than three thousand professionals from government, industry, academia and nonprofits attended this year’s meeting. The IAFP meeting is a window into what’s coming down the pike with food, food safety and food regulation. Food safety professionals have a thankless job, investigating foodborne illness outbreaks involving foods that often have ingredients obtained from multiple countries, due to the globalization of the food supply.

Globalization and a continued decline in food quality and transparency have made it difficult for government and industry to bring down the number of foodborne illnesses. Frank Yiannis, Deputy Commissioner for Food Policy and Response of the U.S. Food and Drug Administration (FDA), noted in a regulatory update he gave at IAFP that the number of foodborne illnesses in the U.S. has been flat for two decades.

SALMONELLA IN POULTRY

A major topic at this year’s meeting was the persistent problem of illness caused by salmonella in poultry. In a regulatory update she gave for the United States Department of Agriculture (USDA), Sandra Eskin, USDA Deputy Under Secretary for Food Safety, conceded that the department has consistently failed to meet public health goals with regard to salmonella in poultry. To deal with the salmonella issue, USDA implemented performance standards for poultry in 2015—testing requirements that disproportionately impacted small-scale USDA slaughter and processing establishments and were a factor in Texas terminating its state poultry inspection program. The performance standards led to fewer positive tests for salmonella in the facilities USDA regulates, but the number of illnesses attributed to salmonella in poultry—the bottom line in evaluating the effectiveness of that or any other food safety initiative—remained the same. USDA responded to its failure to make any progress by announcing on July 31 that it was establishing a zero tolerance standard for breaded poultry products, a first step in extending zero-tolerance to other poultry.

USDA-inspected poultry establishments commonly slaughter between two hundred thousand and three hundred thousand birds per day, a production level that makes quality control difficult to attain. Instead of imposing performance standards and zero tolerance, decentralization of poultry production would likely be more effective in reducing illness. Over fifty years ago, USDA’s Food Safety Inspection Service (FSIS) issued a regulation allowing on-farm poultry processing of up to twenty thousand birds per year without an inspector present for slaughter and processing; the number of foodborne illness outbreaks attributed to producers operating under the exemption are few, if any.

FSMA RULES

The most alarming news at the IAFP meeting was the announcement by Yiannis that FDA will be issuing a final rule on food traceability in November for what the agency designates as “high risk foods.” The proposed rule on food traceability, authorized by the Food Safety Modernization Act (FSMA), imposes extensive recordkeeping requirements; it even covers those who produce cottage foods in home kitchens and farmers who sell any of their private production to anyone other than the final consumer—the regulation could easily drive small-scale producers out of business. Unless the final rule is a substantial improvement on the proposed rule, the traceability regulation which should start going into effect next year represents the biggest threat FSMA has posed to the viability of small farmers and local artisans.

Another FSMA rule that was a focus of the meeting was the regulation on agricultural water (‘ag water’) used by produce growers; to say the ag water rules and the implementation of them are confusing would be an understatement. Rules on harvest and post-harvest agricultural water quality are going into effect in January 2023 for “very small business” January 2024 for “small business,” and January 2023 for all other business. In July 2022, FDA issued a proposed rule for preharvest agwater; that rule will go into effect for very small business in two years and nine months, for small business in one year and nine months and for other business in nine months after the final rule for preharvest ag water goes into effect. The proposed rule will require producer farms to do a preharvest agricultural water assessment covering matters such as water source and location, animal impacts, biological soil amendments of animal origin, adjacent land activity, untreated human waste and environmental conditions.

One speaker at the meeting commented that the implementation of the ag water rules will be complex and that there will need to be training and retraining of the trainers teaching farmers how to get into compliance with the new regulations. A state regulator remarked that there is no way farmers and regulators will be ready to implement and enforce the harvest and post-harvest ag water requirements when they start going into effect. Another speaker noted that there are still numerous knowledge and data gaps in understanding exactly what FDA wants on the ag water requirements. The extensive monitoring and recordkeeping requirements of the ag water rules make it a potential threat to the viability of small and midsize growers. Both the food traceability and the ag water rules look to be ways to consolidate market share into fewer and fewer hands.

TECHNOLOGY

The traceability rule in particular is an opportunity for FDA to further roll out what it calls “The New Era of Smarter Food Safety,” a campaign that “represents a new approach to food safety, leveraging technology and other tools to create a safer and more digital, traceable food system.”2 In his talk at the meeting, Yiannis told the audience to envision a future where all information on food (how it was produced, where it’s available, etc.) is such that food can be traced in seconds. He encouraged the attendees to imagine buying foods “you can trust” at a store because you know everything about it. Yiannis stated that we are moving toward an age where everything will have a digital footprint and voice so that inspectors can monitor a food processing plant whenever they want, not just inspect once every five years. He warned, “Things
are going to change dramatically in the years ahead.”3

One technology that Yiannis favors is blockchain, a digital ledger that can be used to trace food from farm to fork. One presenter at the IAFP meeting spoke about a Chinese blockchain product called GoGo Chicken. According to its manufacturer Zhong An Technology, “All info related to the chicken can be verified in the blockchain.”4 This includes “the chicken’s age and location, how far it walks each day, air pollution, the quality of water it drinks, when it’s quarantined, when it’s slaughtered…” and more.4 According to Yiannis, hundreds of Chinese poultry farmers raising free-range organic birds are using the technology to combat fraud from factory farms that are also claiming their birds are free-range. The organic birds are tagged with an anklet “that tracks and reports every aspect of their lives.”4

Another blockchain product, the IBM Food Trust, is a network used by over eighty brands. Consumers can use a QR code to determine the processor and the farmer of the food they are eating—a globalized virtual version of “know your farmer, know your food.” Blockchain is being used for beef to determine whether the cattle are, in fact, grass-fed; it can detect other kinds of food fraud as well. A speaker at the conference indicated that blockchain could be a fit for the FDA traceability rule. There are a number of potential downsides to blockchain. It is expensive and incredibly energy-consuming; one speaker conceded that there must be mass participation for blockchain to make sense. It is unclear how well blockchain protects the confidentiality of proprietary information.

Cybersecurity could be another issue; one speaker said that there had been two hundred cyber attacks on food and agriculture and that the government was monitoring over forty groups for ransomware activities. Scalability could also be a problem with blockchain as the required data storage capacity of the technology is huge. Further, blockchain is immutable once data are entered into it and timestamped; incorrect data can’t be rectified.

ARTIFICIAL INTELLIGENCE

Another technology in favor with government and industry is artificial intelligence (AI) defined at the meeting as “the ability of a digital computer or computer-controlled robots to perform tasks commonly associated with intelligent beings.”5 One presenter at IAFP spoke of Industry 5.0. Another commented that AI has a big role in FDA’s “New Era of Food Safety.”

AI can be used to make decisions on the farm regarding seed selection, water content, soil selection and crop monitoring. In a food processing plant, AI can be used to remove defective products through optical sorting and through sensory smell and taste through an electronic nose (known as an enose) that would replace human noses in a production setting. The industry can also use AI for selection and analysis of components in food, to identify flavor and provide quality assurance for packaging. AI can be used for warehousing and storage, analysis of delivery routes, for maintenance and timely repairs of equipment. For sanitation, the future is robots doing the cleaning instead of humans; robots can be made sterile so the thought is that pathogens would be less likely to crop up in the plant. Moreover, AI has been used to evaluate workers’ personal hygiene.

Aside from blockchain and AI, speakers at IAFP mentioned a number of other technological tools for food safety. There is facial recognition technology, which can be used for purposes ranging from determining when an individual came to and left a food processing plant on a particular day to how many people with a red shirt and black pants were in an area of the plant on a specific date. There is wearable vision technology with a remote or off-site assessor to direct an on-site inspector to potentially problematic areas of the plant. For the on-site inspector, there are body cameras used for a similar purpose. There are drones used to inspect silos or areas of a roof; there are temperature sensors to stay with the food product throughout its whole journey from the processing plant to the customer’s home. It all adds up to expensive, broad-spectrum, 24/7 surveillance.

FOOD SAFETY PROBLEMS MULTIPLY

Despite whatever technologies government and industry use to improve food safety, the fact is that regulators have a myriad of problems to contend with. The breakdown in supply chains has led to conditions more conducive to food fraud, something that is common with foods like honey and olive oil. One speaker commented that with the breakdown in supply lines, it’s all manufacturers can do to find the ingredients they need, much less verify them for authenticity. Another challenge is foreign materials, such as metals, found in food products. According to one conference presenter, foreign materials are the number one reason for food recalls in the industry, surpassing allergens. Some plants have installed x-rays or metal detectors to deal with the issue. Another problem is the continually increasing antibiotic resistance in livestock and poultry. One speaker commented that surveillance for antimicrobial resistance is becoming increasingly common, with resources and costs being a challenge.

Nanoparticles in food are another threat to the safety of the food supply; recent articles in the media have covered the considerable number of food products that contain nanoparticles. A study displayed at the meeting found that currently used methods for washing produce did not get rid of silver nanoparticles in romaine lettuce. According to one of the authors of the study, the silver nanoparticles accumulate in both the liver and kidneys.

As if regulators didn’t have enough to contend with, the introduction of insects into the food supply is another food safety risk they will be taking on; categorization of insects as a food allergen is under consideration. In the meantime, the number of products on the market containing insects appears to be rapidly increasing; the authors of one study on edible insects, publicized at the meeting, used—among other products for their work—a trail mix containing black scorpions as an ingredient.

CONCLUSION

The best response to all the problems the industrial food system is suffering is to support the production and consumption of locally produced food. The digitization and massive overregulation in the industrial system is unlikely to reverse the deterioration in quality of conventional food nor to reverse the increasing lack of transparency of what is actually in the food. The answer isn’t increasing regulation to the point it further consolidates the food industry; instead, it̕’s deregulating locally produced food to increase its market share. There is no need to spend billions on transparency and traceability—those are already built into local food. More of being able to look the producer of your food in the eye—fewer QR codes to see who grew your favorite food five thousand miles away—is the path to improve nutrition, health and community.

Part of this article first appeared at Solari.com in “Surveillance and Centralization on the Menu.”

REFERENCES

1. About IAFP. International Association for Food Protection. https://www.foodprotection.org/about/

2. FDA (2020, July). New Era of Smarter Food Safety: FDA̕’s Blueprint of the Future. [PDF], p.1. https://www.fda.gov/media/139868/download

3. Yiannis, F. (2022, Aug 1). U.S. Regulatory Update on Food Safety. [Conference session]. IAFP 2022 Annual Meeting, Pittsburgh, PA.

4. Peters, A. (2018, January 12). In China, You Can Track Your Chicken On–You Guessed It–The Blockchain. Fast Company. https://www.fastcompany.com/40515999/in-china-you-cantrack-your-chicken-on-you-guessed-it-the-blockchain

5. Virtual Food Safety Monitoring, Auditing, and Artificial Intelligence Applications. (2022, Aug. 2). [Conference session]. IAFP 2022 Annual Meeting, Pittsburgh, PA.

The post 2022 IAFP Meeting: What’s Happening with Big Food appeared first on Real Milk.