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Weston A. Price Foundation - London Chapter Message Board › Raw milk needs you! WAPF Consultation response, 30 April deadline

Raw milk needs you! WAPF Consultation response, 30 April deadline

Philip R.
Phil_Ridley
Group Organizer
London, GB
Raw milk needs you!

The consultation on raw drinking milk is coming to an end. You must send in your responses by the 30th April!

Write to:

Freddie Lachman
Food Hygiene Policy
Food Standards Agency
1st Floor, Aviation House
125 Kingsway
London WC2B 6BH

Email: RDM@foodstandards.gsi.gov.uk­

See below for the Weston A. Price Foundation, London Chapter's response, which you can freely copy and forward to the FSA if you agree with our statements. Summary:

The FSA are proposing four options for raw milk sales law:

Option 1. Do nothing, leave the law as it is.

Option 2. Pasteurise all milk, raw milk sales become illegal

Option 3. Take all restrictions off raw milk sales and leave current raw milk testing and standards in place

Option 4. The FSA’s preferred option. Introduce measures to harmonise and clarify current controls. This is the current FSA preferred option following its information gathering phase prior to starting the consultation. Harmonisation that is proposed means that other species (sheep, goat and water buffalo) milk will come into the same raw milk law as for cows milk.

Of the options proposed, only option 3 meets the rising demand from consumers. All the other options maintain restrictions on raw milk, when all the evidence points to raw milk sales being less restricted. Only option 3 proposes this.
However, we do consider option 3 satisfactory because it also proposes the following draconian label, with no evidence presented to support it:

This product has not been heat-treated and may therefore contain organisms harmful to health.

The Food Standards Agency strongly advises that it should not be consumed by children, pregnant women, older people or those who are unwell or have chronic illness.

We feel that there should be no change to labeling, noting that 66% of pasteurized milk consumers surveyed by the FSA considered the present labeling sufficient. We also feel that there should be an option to review the testing and registration regime to see if food hygiene can be improved within the present system, to support our calls for the liberalization of retail options for farmers.

Under the FSA’s preferred option 4, these would be legal forms of selling raw milk:

  • Farm gate
  • Doorstep delivery
  • Farmers markets
  • Internet sales with couriered delivery
  • Vending machine located on the farm premises
  • To a distributor


Under the FSA’s preferred option 4, these would be illegal forms of selling raw milk:

  • Vending machines located off the farm premises, for example in a retail store
  • Retail sales of raw milk
  • Sheeps, goats and water buffalo milk sales that can currently be legally sold in retail outlets, will become illegal to be sold in retail outlets


The FSA consultation document should be based upon scientific evidence, and evidence of the market for raw milk.

We feel the scientific evidence is flawed because the evidence available demonstrates that the FSA have incorrectly assessed the health risk from RDM. It would also appear that the FSA have not considered all the evidence which might explain why they incorrectly assess RDM high risk when it is demonstrably low risk. There have been Zero illness or health issues arising from RDM since 2002 despite consistently rising RDM consumption. There have also been zero incidents from any other milk sales (goat, sheep etc) in the same period. Weston A. Price Foundation, London Chapter's response to the raw milk review:

Philip Ridley
philridley@hushmail.com­
07580141191
westonaprice.org

Summary:

  • Freedom of Information Requests issued by the Weston A. Price Foundation reveal that despite the consultation document rhetoric, that there is no evidence of there ever having been an outbreak associated with any registered herds, regulated by the FSA and authorized by law to sell raw drinking milk direct to consumers.
  • All stated outbreaks were associated with unregistered herds that produce raw drinking milk to a lower standard and which are required by law to pasteurize. We note that outbreaks continued in Scotland for a significant period after raw drinking milk sales were banned there. The Weston A. Price Foundation supports the mandatory pasteurization of raw drinking milk from unregistered herds.
  • Furthermore, none of the evidence presented by the Advisory Committee on the Microbiological Safety of Food (ACMSF) relate specifically to registered herds, despite them having access to the FSA’s statutory test data. The data presented relates to generic herds not authorized to sell raw drinking milk direct and no distinctions have been made. This demonstrates clear cherry picking and manipulation of evidence to support the Committee’s stated goal, to achieve a ban of the sale of raw drinking milk.
  • ACMSF are, as a result, acting contrary to The Government Office for Science “Code of Practice for Scientific Advisory Committees (2011)”[1]
  • Subsequently, despite negative connotations throughout the consultation document and insinuations that registered raw drinking milk is inherently dangerous, FSA have presented no evidence to justify further retail restrictions for registered raw drinking milk.
  • Despite the absence of evidence of risk, as confirmed by ACMSF in FSA board meetings, the FSA’s preferred options recommend banning the retail of registered non-bovine raw drinking milk, banning of raw milk vending machines used across Europe, and recommend draconian labeling requirements.
  • Dairy UK has been lobbying for a ban of raw drinking milk. We are concerned that the organisation’s conflict of interest has not been identified in consultation documents and FSA Board Meetings. Dairy UK are paid a subscription from dairy farmers on all pasteurised milk sales. They suffer direct financial loss when farmers sell direct to consumers and do not pay Dairy UK a subscription. The processors Dairy UK represent who purchase pasteurised milk in bulk also suffer greater competition for milk and may be forced to pay a fairer price for milk if more farmers have access to price discovery by selling direct to the general public without intermediaries. Since this is the main corporate lobbyist in the raw milk review, we consider that a proper identification of conflicts of interest be noted whenever they contribute to FSA meetings or consultations relating to registered herds selling raw milk direct to the general public.


As a result:

  • FSA have failed to comply with HM Government’s Standards of Consultation[2] document they are signed up to by not properly defining the scope of the consultation document and evidence employed to registered herds, despite all recommendations relating solely to registered herds.
  • The consultation documents and recommendations do not accord with the FSA's adopted Strategy to 2015[3], which states: “We aim to be science and evidence based in everything we do" because none of the evidence relates to registered herds.
  • FSA appear to have produced a “dodgy dossier” to justify further restrictions and draconian labeling requirements that the evidence does not support and that same approach could be used to progressively impose further restrictions in future consultations.
  • The four options presented are inadequate and prejudice the consultation, impairing the ability of consultees to contribute to its outcome, again, contrary to standards of consultation. Whereas we find Option 3 the least onerous, we do not believe the evidence justifies stricter labeling requirements and do believe that a review of registered draw drinking milk should include proposals to analyse the testing regime.


Detailed comments:

HM Government's Standards on Consultation state that there should be clarity of scope and impact. That consultation documents should be clear about what is being proposed. However, the stated scope of the review is a general review of raw drinking milk controls with no distinction being made between registered and unregistered herds.

The evidence presented is generic, relating to principally, and in most cases entirely to unregistered herds not authorised to sell raw drinking milk directly to the general public, with no evidence relating specifically to registered herds, yet all of the recommendations relate solely to registered herds.

Registered herds are registered and regulated by the FSA, authorized by law to sell raw drinking milk direct to the general public. They submit to additional and more frequent testing and higher test standards than unregistered herds. As a result and due to the commercial incentive to protect the reputation of their raw milk sales they produce raw drinking milk of materially and consistently higher hygiene standards than unregistered herds. FSA can close down raw drinking milk sales at farms if statutory requirements are not satisfied, and they can recommend changes to the registration and testing regime if they deem that the present controls are insufficient, but additional retail restrictions and stricter labelling have been proposed in leu of any assessment of whether the FSA's present testing regime could be improved.

Registered herds also have their facilities inspected by Local Environmental Health Officer’s, who can also close down operations if food hygiene requirements are not satisfied. This is also the case with food and drink retail operations.

Unregistered herds not only submit to less testing and lower test standards, but also have the moral hazard of knowing that their milk will be heat treated, killing potential pathogens, thereby providing materially lower incentive to produce milk at higher hygiene standards. Indeed, lower milk prices in the wholesale markets make it commercially unviable to apply the standards employed by registered herds who can sell milk at between £1 and even £3 a liter, versus circa 25p per liter on wholesale markets. The Weston A. Price Foundation supports the mandatory pasteurisation of unregulated raw drinking milk.

Following freedom of information requests, we have discovered that the FSA has no evidence that any of the stated outbreaks from raw drinking milk were from those herds registered and regulated by the FSA that are authorised to sell raw drinking milk direct to the general public. Indeed, the FSA has never seen any of the outbreak reports and Public Health England, responsible for the statistics has stated that they rarely receive outbreak reports from Local Authorities. Through further inquiries, we have discovered that Public Health England do not know which Local Authorities reported each of the outbreaks and do not know whether outbreak reports exist or were ever produced. We therefore do not therefore have any evidence of whether the stated outbreaks are associations or proven links to unregulated raw drinking milk.

There is also no indication that the Advisory Committee on the Microbiological Safety of Food (ACMSF) made any distinction between registered and non-registered herds when presenting evidence about the microbiology of raw drinking milk to the review. Indeed, in the Chair of the Committee stated at the public stakeholder meeting that they did not make a distinction between the two and this is on record, yet the evidence provided is being solely used for the purpose of formulating policy for registered herds.

The following statement made by the ACMSF Chair on para.50 of the 20th FSA March Board Minutes[4] reveals that despite ACMSF’s rhetoric about the potential of death from raw milk, that there was no evidence to support those concerns, repeated in publications by Dairy UK.

”The absence of evidence of diseases associated with raw milk and cream was not equivalent to the evidence of absence.” ACMSF Chair

Certainly, there is possibility and indeed probability of risk to be anticipated and managed and that process should be pursued, but there is no evidence to justify any further retail restrictions or stricter labeling requirements. Indeed, the evidence suggests that retail should be liberalised.

Further evidence base requested:

Further to our requests relating to using a relevant evidence base, we request that the FSA review peer reviewed literature pointing to microbiologically protective factors in raw milk, reduction in nutrient content from heat treatment and also associations with protection against medical issues including asthma. Simply stating that the evidence is not conclusive in the consultation document is inappropriate. We seek a proper independent review of the literature given that it is relevant to microbiological safety and also, is a relevant factor relating to consumer choice, since we believe that consumers should have the freedom to act on peer reviewed literature regardless of the type of study if those findings support consumer choice.

This article covers in particular the microbiological protective factors in raw milk: http://www.realmilk.com/wp-content/uploads/2000/01/PathogensinRawMilk.pdf­

The following PowerPoint Presentation from the Weston A. Price Foundation provides a significant list of journal articles to review: http://www.realmilk.com/safety/real-milk-powerpoint/­

A further list of articles, not exhaustive, is listed at the end of this commentary. The Weston A. Price Foundation would be happy to advise on a full range of relevant literature.

It is noted that the FSA’s preferred options involve the banning of raw milk vending machines. However, the manufacturers do not appear to have been contacted for the specifications or evidence base relating to the machines, nor it appears have other European regulation authorities been asked for the safety records of the machines despite thousands being used across Europe. It is imperative that the banning of a new technology that increases producer access to markets should be based on a sound evidence base and the present justifications are therefore flawed.

This is particularly true for farmers, many of whom do not have staff to man shops and markets, and yet a vending machine in the nearest town could be filled and maintained by them daily. It is noted that the machines self-sterlise and have safety features that cease vending if minimum temperatures are exceeded and if the sterlising capabilities stop working.

Finally, the FSA carries out routine testing of registered herds. It is paramount that it be included and be analysed as the principle exhibit. These test results should be shown alongside unregistered herds to identify the differences between the two types of milk. To not use that information in such a review is displays negligence in relation to the required standards of consultation.

Implications of pursuing the present course:

  • The Weston A. Price Foundation, London Chapter will submit a formal complaint to the FSA, which it is willing to escalate to Ombudsman level, if the FSA does not cease and desist from pursuing further restrictions and draconian labeling requirements based upon the findings of a consultation document that failed to provide clarity on the scope of the consultation and as a result presenting irrelevant evidence relating to unregistered raw drinking milk that does not fall under the scope of the recommendations.
  • The Foundation also seek formal recognition that evidence relating to future recommendations for the regulation of registered herds use relevant evidence known to relate specifically to registered herds. If that evidence does not exist, the Foundation would support a review of evidence collection procedures.
  • We request that the FSA formally recognize that raw drinking milk from registered herds is materially different in hygiene standards to that of unregistered herds and that there is no evidence that raw drinking milk from registered herds is inherently dangerous.
  • The Weston A. Price Foundation acknowledge that raw drinking milk from unregistered herds can be inherently dangerous and we do not support the retail of raw drinking milk without proper food hygiene requirements.


Initial list of journal articles, in addition to those noted in links above:

Akinbi 2010. J Pediatr Gastr Nutr, 51, 3:347-352
Andersson 2007. Acta Paed, 96:1445-1449
Benn et al 2002. J All Clin Imm 110, 1:72-77
Björkstén 2001. J All Clin Imm 108, 4:516-520.
Braun-Fahrländer 2010. Clin & Exp All, 41:29–35
Coenen 1999. Diss freie Universität, Berlin
Czank 2009. Ped Res, 66, 4:374-379
Elwood et al., 2010. Lipids (2010) 45:925–939
Elwood et al 2008. J Am Coll of Nutr, 27, 6:723–734
Ewaschuck 2011. J Perinatol, 31, 9:593-598.
ISAAC, 2008. http://isaac.auckland...­
Itan et al. 2010. BMC Evolutionary Biology, 10:36-47
Jahreis 2011, Oral presentation 1st raw milk workshop, Prague
Jaudzus 2010. Ann Nutr Metab, 57:103–111
Kummeling 2008. Br J Nut, 99:598–605
Kusche 2012 (in review).
Loss 2011. J All Clin Imm, 128, 4:766-773
Narayanan 1984. Lancet, 17, 2(8214):1111-1113
Parodi 2009. In: Tamime (ed). Dairy fats and related products, 28-51
Perkin 2006. J All Clin Imm, 117, 6:1374-1381
Price 1939. (2006) 17th Printing. ISBN 0-916764-08-7
Ran-Ressler 2011. Lipids, 46:569–576
Rist 2007. Br J Nutr, 97:735–743
Schapowal, 2010. http://www.smgp.ch/ar...­
Silvestre 2008. Acta Paed, 97, 8:1070–1074
Wijga 2003. Pediatr All Imm, 14:156-162
Zoeren 1987. Arch Dis Childhood, 62,161-165

The following article, by Nadine Ijaz researched the cases of raw milk causing food poising, and studied the biology of raw milk. Her work was peer reviewed and presented to the British Columbia Centre for Disease Control. It is independent unfunded research that reviewed evidence about the claims of the safety of raw milk. Her conclusions were that raw milk should not be classed as a high risk to human health food, but should be classed as a low risk to human health food.
http://www.bccdc.ca/NR/rdonlyres/00E8757C-99E4-4414-8C54-2C92BB776567/0/RevisedPresentationJuly8RawmilkmythsandevidenceNadineIjaz_PROTECTED.pd­

[1] The Government Office for Science (2011) “Code of Practice for Scientific Advisory Committees” https://www.gov.uk/government/publications/scientific-advisory-committees-code-of-practice­ [2] HM Government (2008) Code of Practice on Consultations http://www.berr.gov.uk/files/file47158.pdf­
[3] Food Standards Agency (2013) “Food Standards Agency’s Strategy to 2015” http://www.food.gov.uk/about-us/publications/busreps/strategicplan/#.U0LbxtzxW2w­
[4] Food Standards Agency Open Board Minutes 22 May 2012 http://www.food.gov.u...­
Natalie C.
user 46219112
London, GB
Post #: 53
Hi Phil
I just wanted to let you know that I have taken action despite going quiet on the discussion forums - life with a toddler and baby is not for the faint hearted OR tired OR unhealthy - get raw milk legalised quick! I really hope so, it would be a devastating blow if it isn't or worse, banned completely.

Hope you are well.

Anyone can use some or all of this if it is easier to write to the FSA;


Date: Monday, 28 April 2014
Subject: Raw Milk Consultation
To: "rdm@foodstandards.gsi.gov.uk"­ <rdm@foodstandards.gsi.gov.uk>


Dear Mr Lachman

I can only see one option of the consultation that is satisfactory and that is option 3, to make raw milk legal for retail to the British public.

I give it to both my baby and toddler and I drank this milk during both pregnancies due to it's nutrition content. It is my number one choice in milk and butter but currently with money being so tight, it is off the menu as we cannot afford it due to its very limited supply causing it to be so expensive, and also trips to the farmers market every Sunday are just not viable or fit in with modern life.

I urge you to please listen to what the consumers want, people like me, lay men and women who understand the benefits of unpasteurised milk which is a living food by which the process of pasteurisation kills all the essential bacteria, vitamins and nutrients that make it a nutrient dense, healthy food. Pasteurised milk is essentially dead milk and those who prefer it will not be affected by the legalisation of raw milk and can make the choice to buy pasteurised.

The evidence is all there to see that raw milk is safe and not harmful to health, if there was even the slightest chance that raw milk was unsafe, I would never have risked taking it during pregnancy or giving it to my children.

I want to have the choice and the right to make that choice without being penalised for it not only by the inconvenience and expense but by the governments failure to recognise raw milk for what it is - an amazing superfood. I strongly believe that Nature's way is the best way as we are rediscovering and food of all things should be eaten in its natural state without interfering with it in order to get the full benefits. So please, let those of us (and I believe there are a significant many) who choose raw milk over pasteurised be given a choice and the right to choose.

I look forward to hearing from you.

Yours sincerely

Natalie Costa


--
Life in all its splendour is Mother Nature obeyed. - Weston A Price, DDS

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