What Came First, the Egg or the Raw Milk? Your Blogger Prepares for Raw Milk Symposium; Help on Research

When I saw the headline Tuesday on a news site that the U.S. Food and Drug Administration implemented new rules about eggs, I prepared myself to be outraged. Would they now be requiring pasteurization of eggs? Irradiation?

Lo and behold, the new rules seem rational, or let me put it this way: they seem rational in the context of our upside-down world of fear and ever-more-regulation of the food system. The main requirements are that mid-size and large producers do regular pathogen testing and that eggs be continually refrigerated between the farm and grocer. Four facts stuck out to me in the summary of the new rules:

• Owners of flocks of fewer than 3,000 hens are exempt from the rules. That means the suppliers I (and growing numbers of other food-conscious individuals) deal with won’t be affected. I haven’t bought eggs in supermarkets, including Whole Foods, for some years now, relying instead on a few small suppliers (some with just a few dozen chickens) at the farmers market or a co-op. That way, the eggs I get are very fresh, and the yolks nearly orange with nutrients.
• What a big problem salmonella in eggs is. Depending on which FDA figures you believe, between 79,000 and 142,000 illnesses occur each year from salmonella in eggs, and 30 people die. Those chicken factories where most eggs are produced must be wonderfully biodiverse places to enable so much salmonella to contaminate chickens. (By way of comparison, raw milk is responsible for an average of between 50 and 100 illnesses each year, depending on which source or study you read.)
• That pasteurization of eggs isn’t a requirement for any egg producers, though it is held out as an option. As I said, the big emphasis is on refrigeration and pathogen testing.
•  The FDA held three public hearings and had two comment periods before finalizing the rules. Can you imagine a similar approach on raw milk?

All of which got me wondering: couldn’t the FDA and state agriculture agencies similarly try to involve citizens on how to ensure a safe supply of raw milk? Hold public hearings on sensible rules. Exempt dairies with fewer than, say, 100 cows, from being required to pasteurize their milk, and allow them to essentially self-regulate. This approach of exempting the smallest producers from excessive regulation has been promoted by Steve Bemis of the Farm-to-Consumer Legal Defense Fund for some time on this blog.

As sensible as the agency might have been, it’s sad when they give this advice: “The FDA reminds consumers to ... cook eggs and foods containing eggs thoroughly." Based on where I obtain my eggs, I'll continue to enjoy them runny.

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I want to thank the individuals who took the time to support the work of this blog, following my previous post. It’s much appreciated.

It turns out I’m going to need all the support I can get on Sunday, when I'mm due to attend a symposium on raw milk sponsored by the American Veterinary Medical Association at its annual meeting in Seattle. Through a combination of circumstances—my advance decision to attend as a media rep, a last-minute cancellation by one of the speakers, and a receptivity by the organizers to presenting alternative views about raw milk (raw milk advocate Amanda Rose will be presenting)—I’ve been invited to be part of the program. Presenters include scientists and public health officials from the U.S. Centers for Disease Control, universities, and state public health agencies, and food poisoning lawyer Bill Marler.

I’m going to give a 25-minute presentation, entitled, “Raw Milk Conundrum: Safety vs Rights”. I’ll focus on the realities of how many illnesses result from raw milk, and the disproportionate state and federal campaigns to discourage or eliminate supply—in arguing that the issue is a rights rather than a safety issue. Given the crowd, I don’t expect my viewpoint to be smilingly accepted, but hopefully, we’ll have a forthright exchange of views. More to come on the events.

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I'd like to encourage readers to provide input to Mark McAfee of Organic Pastures Dairy Co., based on his offer following my previous posting to initiate lab testing on how pathogens react in fresh and fermented raw dairy. Here's an opportunity to help develop the parameters for an important research project, based on Concerned Person's provocative questioning.

Same goes for Rick Fessenden, and his comments following my previous post on his desire to develop a new model for herdshares. I didn't mean to suggest unhappiness or problems in the existing herdshare approach--it's become the basic model for hundreds of farms--but rather to think about building on the existing model to develop new approaches for involving consumers in food production.

Comments

[Mark McAfee]

David,

Congrats....

My strongest piece of advice is to beg the convention to understand and accept the fact that:

THERE ARE TWO RAW MILKS IN AMERICA!!

One for people...following state by state standards.

One for Pastuerization....following the FDA PMO standards

This is a must. Currently, the FDA dead fastly refuses to acknowledge the presence of states rights or standards for any raw milk in America. This is "FDA first base" for the Raw Milk Movement.

I have sent to you my list of Two Raw Milks In America Comparison lists that I presented to everyone at the NCIMS conference.

Good luck and strong work. This again just shows how showing up is critical. Interesting to note that Sheehan will not be showing up.


I am looking for input on the proposed raw milk pathogen test recovery study....please contribute or forever hold your water.

All the best,

Mark

[Don Neeper]

We frequently eat the pastured eggs and deep orange egg yolks from our farmer not just runny but raw. My six year old son is a picky eater, and my wife frequently gives him a "milkshake" for breakfast made of raw milk, a raw egg, honey and some pumpkin spice run through a blender. (The FDA would probably have us hauled away for child abuse if they knew!) Our ice cream recipes are similarly made with raw milk and raw egg yolks. Amazingly enough, neither of our children has ever had an ear infection in his life, are rarely sick, don't need glasses, have no allergies and are tall and well-developed for their age. Now how could that be? :-)

[Steve Bemis]

The new federal rule on eggs is truly sensible and was in fact one of the reasons I put forth the idea that small farms should simply be exempt. In the face of the deadly-complex "food safety" bill presently in Congress, there should be a loud chorus, ever louder and ever more insistent, that small farms are simply exempted. There is a direct-sale exemption, of sorts, in the bill now but there are other aspects of the bill which are far from clear since the language is so broad as to be applicable to small farms when the FDA implements the law through regulation (the regional quarantine, for example, or the draconian search and seizure provisions without benefit of judicial review). Like the egg law, there should be a parallel size exemption similar to the 3000-hen exemption (as David and I have suggested, for example, 100 lactating cows as the raw milk exemption). The hearing transcripts on the egg rule are also interesting, since they show how insistent and regular appearances by small producers are effective. It was clear in the hearings that the large producers tried everything they could to get the small producers covered, and it was actually encouraging to see the FDA and CDC representatives in those hearings defending the position that the under-3000 hen exemption should be in the rule, for among other reasons, the impossibility of enforcing a wall to wall rule. "Eternal vigilance is the price of liberty."

[Sylvia Gibson]

Don,

Your milkshake reminded of when we were kids, we made orange julius' with the whole raw egg. It was so good! We ate raw cookie dough, licked the beaters, bowels, etc. Didn't get sick.

David,

I've no doubt that many have faith that your words will sink in at the symposium and open some minds.

[Kimberly Hartke]

Great, David, so glad you have been asked to be a presenter. That is an awesome opportunity. We want to hear all about it. Will you get someone to record your talk and put it on YouTube?? I'd love to embed it in my blog.

Just a side note--I went to my dairy farm today to visit the cow I board there. NPR was there working on a story about cow boarding! It may air in the next few weeks. I am planning to link to it from my blog, http://hartkeisonline.com.

I was sad to find out that milk from this same farm where i get my raw milk (through a cow boarding program) is also bought by a big milk processor and subject to UHT (ultra high temperature) pasteurization. What a waste of probiotics!!

[Concerned Person]

For anyone that is interested, here is what Bill Marler is presenting at the AVMA conference http://www.marlerblog.com/2009/07/articles/lawyer-oped/avma-conference-raw-milk-consumption-legal-implications-of-raw-milk-and-case-studies/

I actually can’t open it (must be an office 2007 version), so I don’t know what is there.

cp