The Front Page

Editors note: I was contacted this evening by a rather mysterious fellow, Gassalaca Jape, who seems to be having some trouble posting a comment on the DI. It concerns a letter to the editor calling for support to end the FDA ban on interstate raw milk sales. Apparently Mr. Jape tried to post a rather lengthy reply in response to some claims made by Phil Salvatore in opposition to the original letter. Anyway, this Jape fellow does not wish to be a participant here and turned down my offers for a posting account of his own but has agreed to respond by email should it become necessary. Mr Jape seems quite anxious to preserve his anonymity. Who or what he is on the run from I have no idea. In any case, what follows is his somewhat wordy response to the readers of the DI concerning a recent CDC study of disease outbreaks associated with raw milk consumption in the US.
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In response to a recent letter to the editor published by the Daily Independent of Ridgecrest, CA, several comments were posted, pro and con, regarding repeal of the current ban on the interstate sale of raw milk. One commenter claimed that consumption of raw milk products was wholly unsafe in every instance and was 150 times more likely to poison the consumer than a pasteurized product.


This claim is false on its face. Many varieties of imported hard, semi-hard, and aged soft cheeses, as well as several American examples, are sold and consumed in the USA, some for over two centuries.These cheeses are offered for sale in every state of the union in supermarkets and specialty stores, as well as served in restaurants throughout the country. A > 150 times risk of disease over that of pasteurized product illness would result in significant contagion and outbreaks across the US. The CDC database does not support this conclusion. Milk, overall, is one of, if not the safest food product sold, not only in the USA, but also in Europe.


So I was puzzled by the claim until I read the study upon which the claims seem to come, a CDC report published by Adam J. Langer, DVM, in the March issue of EID. It turns out that Langer based his estimates for that number on some unusual reasoning.


First of all, he used old CDC data dating from 1996-97 to get a "rough estimate" of the percent of population who consume unpasteurized dairy products. (1.5%) He then forgot about that number and used later surveys which only asked about fluid milk consumption, not cheese, to come up with a 1% figure which he then applied to estimate the percentage of the total milk production of the US sold for consumption in an unpasteurized condition. Langer multiplied total US Milk production for 2010 (193 billion pounds) by 14 to come up with a total weight of 2.7 trillion pounds, calculated production. (This number is not correct, by the way. I examined production tonnage for 1993 and several years following and found linear growth from 120 billion pounds total production leading up to the 2010 figure.)


Following Langer's argument, 1% of this would be 27 billion pounds total unpasteurized. He then used outbreak counts weighted by pasteurized vs. unpasteurized production numbers and came up with a 150X p of outbreak per unit measure of product.


This method, using outbreaks alone, does not take into account illnesses. Outbreaks are defined as instances of two or more cases of food borne illness. The math problem of using outbreaks alone is illustrated by the fact that a single outbreak can sicken two people, or 20,000.


Since I do not have the complete dataset used by Langer (the CDC database online only contains outbreak records from 1998 until 2009) I elected to analyze those available online data based upon reported illnesses, hospitalizations, and deaths. From 1998 through 2009, the latest year in the online database, there have been 62 confirmed outbreaks associated with drinking "raw" milk and 23 outbreaks associated with a raw milk dairy product, butter or fresh cheeses. The records do not go into detail about these cheeses, but I independently investigated some of the reported outbreaks and found that every one I encountered was associated either with unpasteurized cheese carried across the border from Mexico, ostensibly for private use but actually intended for sale in flea markets and the like, and homemade fresh cheese made from milk obtained from commercial or production dairies by workers and made into cheese privately. Cheese of this sort is often referred to as bathtub cheese. All sales of cheese made or obtained in this fashion are illegal. Furthermore, no instances of outbreak or illness were reported involving any aged unpasteurized cheese. *


The fluid milk illnesses totaled 1260 with 70 hospitalizations and 0 deaths.
Fresh cheeses accounted for 583 illnesses with 124 hospitalizations and 2 deaths.


Getting a handle on pasteurized dairy products implicated in food borne illness is a little more difficult. The vast majority of dairy products sold in the US are pasteurized and the CDC doe not appear to go to the same lengths to isolate and confirm the cause when pasteurized products are concerned. Unpasteurized dairy is implicated as the food vehicle in 96 outbreaks, and of those, 85 were confirmed, resulting in a confirmation rate of 89%. Pasteurized (or presumably pasteurized) dairy products are listed as the food vehicle in 302 outbreaks. Of these, only 117 were confirmed, resulting in a confirmation rate of 39%.


Plainly, where dairy is concerned the CDC goes to far greater lengths to isolate unpasteurized outbreaks.


But using the CDC confirmed records in the database, 117 outbreaks occurred over the 11 year period sickening 5497 and resulting in 219 hospitalizations and 4 deaths.


A more recent food survey conducted by the CDC estimated that 3% of the population consume unpasteurized dairy products. Furthermore, this number is certainly underestimated due to widespread consumer ignorance as to the pasteurization status of the foods they eat. As mentioned above, there are many unpasteurized cheeses sold in the US and used in restaurants nationwide. Parmigiano Reggiano, all Swiss Gruyere, Emmenthaler (the actual Swiss version of "Swiss" cheese,) Roquefort, Grana Padano, and some variants of Peccorino, many English Cheddars, as well as several domestically-produced aged cheeses including the famous Maytag Blue produced in Newton, IA, are never pasteurized. The US imports 305 million pounds of cheese each year, most of it from Italy and France, and much of it unpasteurized. Many of these cheeses are available in every major supermarket in the country. Were the respondents to the CDC survey aware that the italian Parmesan they buy at Costco or consume in restaurants is never pasteurized? But assuming the CDC survey only accounts for consumption of "fresh" unpasteurized dairy products, 3% of the population would be ~ 9,348,000 people. If this figure is accurate, the likelihood of infection through raw milk and unpasteurized fresh cheese would be .000197 in 11 years, or 1 in 5072. Using the mean yearly incidence of illness for unpasteurized milk and fresh cheeses, (1843/11=168) the odds of getting sick in a year of consuming unpasteurized dairy would be ..0000197 or 1 in 56,000. The odds of hospitalization? 1 in 530,000. The odds of death? 1 in 51,000,000. And it should be emphasized here that these numbers apply if a person consumes raw milk or fresh cheeses. Persons consuming properly made and stored aged raw milk cheeses have zero probability of contracting an illness from contaminated raw milk. There are no reported instances of contaminated unpasteurized aged cheeses. Again, see note below.


It must be emphasized that the odds of contracting a food borne illness from fresh unpasteurized dairy products and milk are still significantly higher than for their pasteurized equivalents. You are 11 times more likely to get food poisoning from unpasteurized products, 30 times more likely to be hospitalized, and 17 times more likely to die as a result. However, all of these probabilities are incredibly low when contrasted with illnesses caused by other dietary choices; quite a testimony for the safety of dairy foods as a whole.


But it is also important to consider the sources of much of the unpasteurized milk consumed by the people who became ill over the course of the 11 reported years. Studying news reports, I was able to find only a few instances where the milk consumed came from a legitimate dairy operating solely for the production of "raw" milk. My search was by no means comprehensive, but it appears that a large majority of the milk involved in outbreaks came from commercial operations normally devoted to pasteurized production. This distinction is important. In the US, major "production" dairy operations are designed to ship only milk intended for pasteurization. Since the milk will be pasteurized, there is less concern about pathogen introduction into the stream. Somatic cell counts (white blood cells or "pus," most commonly from mastitis) and bacteria counts are acceptable up to 1,000,000 cells per milliliter and the milk will still be marked "Grade A" by the USDA which tests every batch prior to pasteurization and processing. 31% of this raw milk delivered for pasteurization in this country has been contaminated with pathogenic organisms. Milk produced in this fashion with that amount of contamination is simply not intended to be consumed untreated. Since pasteurization kills most pathogens completely, or lowers their numbers to the point that they cannot cause illness, the milk becomes relatively safe for consumption. After pasteurization, plate counts of bacteria must be below 15,000/ml. .


Milk produced by at least one raw milk producer in California (Organic Pastures Dairy in Fresno) uniformly produces and sells raw milk that beats this standard without pasteurization. The milk is cleaner unpasteurized than what you may end up buying in the store. Of course, this is not a thorough indicator of perfect safety as there are possible pathogens that could escape detection, but what is important is that there is a radically different set of standards that a dairyman must ethically adhere to when his herd's milk is destined for use unpasteurized. At least in California. Which brings me to another point: Pasteurization itself.


It is a common claim in the US that there is no discernible difference between pasteurized milk and non. This claim is ridiculous. Studies have been conducted in France on the taste and texture differences between raw milk cheeses and cheeses prepared in the same fashion but using pasteurized milk. These studies confirmed that there is a definite, noticeable degradation in the quality of the cheese produced when pasteurized milk is substituted. And it should come as no surprise , either. The pasteurization process heats milk to 161º for a short amount of time. To see what 161F will do to a protein containing liquid, heat an egg to that temperature and watch it carefully with a thermometer. The egg will be thoroughly cooked. Try it with a steak. It will be well-done and cooked throughout when the center reaches 161º. That is the temperature that Pork is considered cooked. You cannot expect a protein and enzyme-packed liquid to emerge from such a temperature without marked changes. The milk, when it is pasteurized, has been thoroughly cooked. The cheeses it produces are inferior in every instance, and the product itself does not taste anything like the uncooked variant. Claiming otherwise is pure nonsense. But it makes the man happy. And speaking of the man, I would be remiss if I didn't mention another aspect of the controversy:


The CDC itself. The study I mentioned was conducted by a veterinarian. I have no reason to doubt his or his research team's sincerity when it comes to his alarming conclusions. But there is a powerful inertia, mostly financial in nature, that underlies the whole schema of this study. And that is the status quo of corporate agriculture in America. Everyone involved in the food business in the USA competes in a realm where cost-containment is paramount; lower prices are the rule, and there is big money to be made if you can pull it off. That is why all along Highway 99 in the San Joaquin Valley you see feedlot dairy operations with cows trying to graze on their own feces. They stand in it, they live in it, and then they are milked. They are filthy. They stink. The entire big ag apparatus in this country stinks. My great uncle owned a dairy farm in Utah. The cattle grazed in the summer and were fed silage and baled hay in the winter. This was 50 years ago. I used to help out on his farm, and on other neighboring farms as a boy in Utah and New Mexico. It NEVER stank on his or any farm I worked on. EVER. My cousin's father was a dairyman in Illinois. She grew up drinking "raw" milk every day of her childhood out on the farm. Those farms were never anything like the monstrosities we have allowed corporate ag to erect. Anyway, there is a huge financial stake in the status quo of 2012-USA where food is concerned. When organic milk production first became popular, it was not viewed as anything to be concerned with by the big boys. But as consumption of the more expensive (yet still pasteurized) product grew, corporate interests moved in. Nowadays, you are not even assured that the cows producing "organic" milk ever graze on real pasture. Yes, you do not have to drink bovine growth hormone in your glass of organic milk, but how long will it be before the big boys change the laws about what is allowed and still be sold as organic?


Small operations selling raw milk under conscientious production circumstances are probably not too big a threat to big dairy right now. But the inertial character of the machine seems to want to get everyone in line and make them conform to what will maximize return for the lowest cost. Low production dairies offering year-round pasturing of animals and extremely careful milk handling procedures could pose a risk to the established industry practice of squalor and torment. If people ever discovered that they could safely consume milk produced humanely and cleanly from small operations and no post-processing it could pose a real threat to the milk processors and middlemen in America. At this point, most of veterinary science and the research it conducts is tied to or beholden to the big agricultural machine. The ethos seems to have become "whatever they say!" Can you imagine the political uproar that would result if a CDC study declared organically, hygienically-produced raw milk safe? The Milk Processors board would be calling for the scalp of any government scientist involved in such a thing. Billions of dollars a year go to milk processors and wholesalers. They will never abide any threat to their dominance in the industry and they personally own lots and lots of congressmen who are available to them night and day. Is it any wonder the CDC did not draw any contrast between the sources of the raw milk outbreaks?




I am forced to admit that my prior fears about "raw" milk have mostly been due to the fact that I am acclimatized to drinking and eating pasteurized products. I grew up hearing about the infections that were rampant in big cities before pasteurization became common. I also know that these were the days before the importance of sanitation was completely understood. Before the ability to test herds for Bovine TB and other diseases the wisdom of universal pasteurization was unassailable. But even knowing that, I still drank a lot of raw milk as a kid, as did my cousin. But we knew where it came from and it didn't worry us a bit. But now, I would NEVER drink a glass of raw milk produced in this country in accordance with USDA Grade A standards. Is the CDC study serving to further the continuance of this kind of thing? Just pasteurize it all so you don't have to address the underlying problem, feedlot dairies and quick and dirty production?


I cannot answer that question. I also cannot answer, at this time, how the various state laws correlate to outbreaks of disease. The reason for this is I want to learn more about the true state of raw milk consumption in this country. Is it coming from legitimate dairies running clean operations, or is it "leaking" out of factory operations or unregulated and uninspected herds whose owners are simply trying to avoid middlemen? I have no comment as to the when or even if I will complete that part of the analysis. My inquiry into this study and the database have taken a great deal of time. So no guarantees on that. However, I will leave the reader with one interesting point. The CDC database contains 14,091 records of outbreaks accounting for 286,836 illnesses, 9694 hospitalizations, and 207 deaths. Compare that to the numbers I reported for ALL dairy products. Then, the next time you find yourself fretting about organic certified raw milk, consider the fact that nearly half of the outbreaks, illnesses, hospitalizations and deaths occurred in restaurants and cafeterias where raw milk cannot be sold by law. Your probability of illness is far greater going to a restaurant than it is eating any dairy product, pasteurized or not.




*In more than 50 years of scientific literature, there are virtually no reports of illness outbreaks from aged raw-milk cheese that can be blamed on the raw milk.-Janet Fletcher. http://www.specialtyfood.com/news-tr...w-milk-cheese/