Analysis of a Campylobacter Outbreak: There’s More Than Meets the Eye to a Raw Milk Illness Investigation
Thursday, March 4, 2010 at 08:42AM 
Scott Freeman, owner of Kiniker Dairy in Colorado.One of the most emotional issues around the anti-raw-milk campaign by federal and many state authorities is that of illnesses. I guess the question boils down to this: Should we believe the authorities, who are committed to shutting off the supply of raw milk, to investigate and analyze illnesses that may or may not be the result of raw milk consumption?
We now face this question with the recent issuance of a report by the Colorado Department of Public Health and Environment about the campylobacter outbreak last spring at Scott Freeman’s dairy. It’s something I’ve reported on previously, and which Scott Freeman refers to in a comment following my previous post.
I’ve spent some time reviewing the state’s documents, and I should say, I started off wanting very much to be highly critical. I do have criticisms, but I came away impressed with the thoroughness of the investigation as presented in the report. When I say that, I’m trying to allow for the fact that we’re not going to get a Presidential commission type of investigation—remember, we’re dealing with a public health department that has lots of reports of illness from restaurants and other places to look into, and must prioritize its work.
In this case, public health officials personally interviewed 159 of Scott Freeman’s 208 shareholders. I know some raw milk advocates will read all kinds of biases into the report, and certainly a number are present (which I’ll discuss). But after allowing for those (nearly a given when it comes to the public health community’s attitudes toward raw milk), the report is enlightening from both positive and negative perspectives.
On the negative side:
--The number of people sickened was quite high, according to the report. It states: “There were a total of 81 cases identified in this Campylobacter outbreak… Thirty-one percent of all shareholder households reported at least one person with illness that met the case definition, which is a substantial attack rate.” When you consider that data from the U.S. Centers for Disease Control shows that in the period 1973-2005 there was an average of 54 illnesses per year, one outbreak of 81 cases is a lot. It’s important to note, as well, that only one of the illnesses was serious enough to require hospitalization.
--The department made a strong case that sanitation at the Kinikin Dairy wasn’t up to snuff. “The milking parlor was inadequately built/constructed shed which failed to meet the minimum standards prescribed in the Pasteurized Milk Ordinance or the Manufactured Milk Regulations, as well as the standards described on the dairy’s own raw milk website. The floor consisted of dirt and hay, and was soiled with manure. The interior was unfinished plywood, with openings directly to the outside around the door and other various points within the structure. Overall the structure was not clean nor in good repair. Animals other than cows (dog, chicken) entered the milking area during the visit. The milk room/house (storage area) was well constructed and had the minimum of equipment. There was evidence of manure being tracked into the milk house… There were no handwashing facilities in the milking parlor. Sanitizing solution was not used to sanitize the Mason jars used to bottle the milk, and on the day of inspection, there was no chlorine sanitizing solution present.”
--The investigation highlighted tensions between farmers and public health officials. Scott Freeman initially cooperated with officials. But when he continued to make milk available to shareholders after the Dept of Public Health and Environment requested he end sales, the department issued an order prohibiting distribution. He says he continued the distribution because shareholders requested he do so, and because they own the cows, he was obligated to do so. (Documents associated with the exchange between Scott Freeman and the department are contained in an appendix.)
--The department never found campylobacter in the dairy’s milk. Would that it were so straightforward.It found evidence of campylobacter via a PCR test (polymerase chain reaction, which identifies genetic material from campylobacter), but noted that such tests were not part of its usual protocol, and therefore not conclusive in and of themselves. Further complicating the situation, according to the report, the testing of milk samples was limited, apparently because of the department’s own screwups in handling milk testing samples. “Three additional milk samples were collected on April 22, May 1 and May 6 but were rejected by the laboratory because they were not delivered in the necessary time frame or did not have documentation that they were held at the correct temperature during transit, which is required for formal regulatory milk testing, although is often not required during outbreak investigations.” It would have been intriguing if those three additional tests had shown no evidence of campylobacter. It seems as if the public health people were sloppy in their handling of the samples, which isn’t comforting, given the public health hazard. Inference was the order of the day—based on the prevalence of raw milk drinkers among those with campylobacter, officials concluded raw milk was the culprit. (I think the public health officials make an important point that campylobacter isn't easy to pinpoint in any food.)
--The department’s negative attitude toward raw milk pervades its conclusions: “Unpasteurized milk has been the source of numerous outbreaks in the past, in Colorado and other states. Another Campylobacter outbreak associated with unpasteurized milk from a cow share operation occurred in Larimer County in 2005. Outbreaks of Salmonella, E. coli O157 and Listeria associated with unpasteurized milk have been documented in other states and have resulted in deaths and cases of hemolytic uremic syndrome. Fortunately this outbreak involved only one hospitalization and no deaths. With the increasing number of cow share programs, outbreaks associated with unpasteurized milk are likely to continue in Colorado." "Numerous" outbreaks in Colorado, yet all it can come up with is one, four years previous? And “resulted in deaths”? Like any number of governmental authorities, it makes this assertion, even though there aren’t any known deaths from raw milk since at least the 1980s.
On the positive side:
--The department made recommendations to Scott Freeman to improve his sanitation. As I noted earlier, it concluded that sanitation was lacking at the milk parlor. So the department recommended installing hand-washing facilities and improving washing of equipment and bottles to improve sanitation, and he adopted the suggestions. Isn't education part of the public health department's role in life?
--One of the most interesting pieces of data from the public health investigation is a survey of the shareholders’ reasons for drinking raw milk. Perhaps not surprisingly, it is buried in the reports (table 7 of Appendix 2), rather than highlighted. It shows the two most popular reasons being that it’s more nutritious and better tasting (than pasteurized milk), with substantial numbers saying raw milk helps relieve their allergies, improves their immune systems, and enables them to overcome lactose intolerance. There aren't many such surveys around--it's useful information that helps document why so many people are willing to take whatever small risk might be involved to consume raw milk.
One of the messages that comes through loud and clear from the report is that investigations of food-borne illness are as much art as science. It’s a form of detective work. As a result, when I read a report like this, covering 81 illnesses, and then see the repeated invocation of the mantra that we have 76 million cases of food-borne illness each year, it’s hard not to be skeptical. The only way to characterize that 76 million number is as a wild estimate, and it underlies the current push for draconian limitations on food producers being proposed in the current food safety legislative push.
I’ll be curious to read Scott Freeman’s take. I know he disagrees with a number of conclusions, most importantly, the one that lays the blame for the campylobacter outbreaks on his dairy. He may have good arguments, but I sense in all this that the public health professionals made a good-faith professional effort to figure out what might have gone wrong at his dairy, despite their own biases. It’s a situation everyone can learn from, and hopefully that’s what will happen, as opposed to ongoing recriminations.
Reader Comments (65)
So much for knowing your farmer. In order to sell raw milk safely (if that is truly possible), farmers, like the Kinikin Corner Dairy, need to not only “be knowledgeable of sanitary standards and testing methods,” but also actually apply and observe them. As raw milk proponents continue to push for their rights to sell and drink raw milk, they need to also understand the need to make food safety a part of the equation. Not having “hand washing stations,” not using “bleach for sanitizing bottles,” not using “proper dishwashing water temperatures, and [not] monitoring of transport temperatures” simply is irresponsible.
http://www.marlerblog.com/2010/03/articles/case-news/kinikin-corner-dairy-campylobacter-outbreak-report-issued/
milk farmer - You must be kidding? I suppose that you also believe that Obama was born in Kenya, the Holocaust did not happen, the CIA blew up the Twin Towers, WMD's will soon be found in Iraq and Elvis lives down the street?
I don't know if the dairy in question is pristine and a victim of government or a total hellhole that the government report actually took it easy on...I've not seen it.
What I do know is that you want to force government regulation, as opposed to private groups setting standards on raw dairy.
How about we do the same for the legal profession? You folks do have your "dirty daries"...ambulance chasers running TV ads at 3am, the John Edwards of the profession, etc...yet you folks self-regulate with private, state-by-state organizations, like the worthless GA Bar Assn, and no national oversight. You folks self-regulate...but we can't?
Why? What makes you so special? Or is it nothing in particular, just your profession's elitism...you know what is best for us better than we do?
I think we oughtta make lawyers government regulated. In todays political climate, with the public's opinion of lawyers and politicians, you'd do good to make as much as someone who's job entailed repeating, "Do you want french fries with that?" over and over...that is, IF you were allowed to work.
Hell...the public (government) might declare your profession a danger to the public good and outlaw you...like you want raw milk.
BH
http://www.JuicyMaters.com
BTW...enjoying my blog? I see from my SEO your firms IPO is a regular visitor...
Looks like Weston Price was correct.
Another example of old dogma (low fat high carb) espoused by medicine, government, and big AG is incorrect.
http://www.washingtonpost.com/wp-dyn/content/article/2010/03/02/AR2010030202091.html?hpid=sec-health
I wonder if the good handler of the law and protector of the public would laugh at and ridicule 1000 + Architects and Engineers who question the destruction of 911
http://www.ae911truth.org/
IMO your comments where totally uncalled for and totally "unprofessional. It is no wonder most Americans view lawyers with disgust!
So, really, Don, you believe that 911 was something other than planes flown by religious extremists?
Do, you folks really think that the CO report is a great governmental conspiracy against a poor small raw milk farmer? David does not appear to believe it.
Report: Former Sen. John Edwards Facing 'Imminent' Indictment
Former Democratic Sen. John Edwards is facing “imminent” indictment relating to his use of campaign funds to cover up an extramarital affair during his 2008 presidential run, according to The National Enquirer.
A grand jury has been investigating the North Carolinian's use of the funds since April, and the Enquirer quotes a friend of Edwards saying that, although the former candidate does not believe he did anything wrong, he is “terrified” that he will be made an example of in this case.
Bob, the legal system is not perfect, but it works much of the time.
As for the "imminent" indictment of your campaign contribution recipient John Edwards, I'll concede it is a small pebble in the wall of justified retribution against elitist lawyers ONLY if the follow through results in the same punishment an itty-bitty peon, like me for instance, would get for the same transgression in a local county race...equal justice, you know.
I won't hold my breath.
BH
http://www.JuicyMaters.com (see politics>>raw milk wars)
PS...You really oughtta take a look at those FEC filings I commented about a few weeks ago. You'll find that they indicate you committed a felony...perhaps they are incorrect. If so, I'd be getting them corrected glass houses, you know.
As for claiming I committed a felony by donating money ($50,000) to the Inauguration, you are simply wrong (for once in your life I am sure). It was for tickets so my wife and three daughters could be close to history being made (and go to the Jonas Brother's concert).
Also, you comingle giveaways with return on "investment". Medicaid and food stamps are giveaways, and while I qualify for both I refuse them. Its not your, or anyone else's job to care for me.
Medicare and SS, on the other hand, are not giveaways. They are, in effect, insurance policies that people pay "premiums" on their entire working life.
Big difference.
Nope...not the 10K. Other issues. You are a smart lawyer, or so you say ("I never lose")...you ought to be able to figure it out...especially since someone too stupid to make their own nutritional choices, like me, found it in less than 5 minutes.
BH
http://www.seattlepi.com/business/394085_obamadonors30.html
I donated 25K and then other two daughters wanted to go too, so I donated 12.5K and 12.5K.
Bob -- You are getting way too caught up on this John Edwards thing. There are alot worse things that politicians do than lie/cover-up maritial affairs. You know, like screw over working Americans time and again. Or spend way more on the military in various forms than they do on social programs.
Funny how everyone remembers Clinton for his little affair, instead of for the fact that he outlawed gay marriage at the federal level. You tell me which is worse? You can't sit here and rail about class oppression when you subscribe to half of its ideology with these Ron-Paul-esque rants.
http://www.nocafos.org/news.htm
http://www.campaignmoney.com/political/contributions/william-marler.asp?cycle=08
Note items #8,9,10,and 11. Three checks for $2300.00 and one for $4600.00. I believe that though the law allows husband/wife to contribute $4600.00, the checks must be written separately and signed by each contributor. The left column shows either Bill or William Marler as the doner...no mention of another family member as required by law.
The one that really jumps out though is item #17. It isn't illegal, but sure indicates the kinds of folks you hang with.
BH
So, back to the raw milk debate. Again, as long as there are deniers, you are never going to move forward and find common ground with regulators. Raw milk works in Washington. People can buy it and farmers can sell it. Yes, there are outbreaks and recalls, but they are hopefully limited by regulation and inspection.
I agree with you that there is a need to create standards for raw milk, but the fact of the matter is that the dairy regulations in this country (especially in WI) are designed to protect big industry from competition. How are we to create standards that are designed for the needs of small raw milk producers? In my mind, a private non-profit certifications agency is the only way. I do not trust the state to do this job, as they are incompetant and can't even enforce their own standards for pastuerized milk.
Interesting idea on the private non-profit certifications - are you aware of the CA Leafy Green Marketing Agreement? Since the 2006 Spinach E. coli outbreak - there have been E. coli and Salmonella problems, but somewhat limited. Part of the problem with the LGMA, is that it did exclude small producers from sales into the broader system. It would be interesting to see if the small producers were able to find a market outside LGMA - I do not know.
Again, I see the WA raw milk model as workable. I still worry about retail grocery sales.
I'm not here to point blame on any person. I'm simply pointing out that our entire political system, including the regulatory regime, is utterly controlled by corporate money. Even the American Cheese Society, which was founded by small farmstead back-to-the-land cheesemakers, is now largely controlled by big specialty cheese producers. The Raw Milk cheesemakers association has been neutered. They don't want to push the issue of abolishing the arbitrary 60-day rule in favor of a science-based approach to raw milk cheese, for fear of upsetting the powers that be.