Online Raw Milk Risk Management Training - February 10, 2021

On February 10th, the Raw Milk Institute (RAWMI) will be presenting a 4.5-hour Raw Milk Risk Management training workshop. This presentation will be livestreamed online, so that means you could attend from your own location. The presentation will be part of the 2021 Ohio Ecological Food and Farm Association Conference (OEFFA).

About the Training

This RAWMI training day focuses on the benefits of raw milk, grass-to-glass identification of risks, development of a risk management plan, and lessons learned from other raw milk dairies.

We'll be providing lots of practical tips for the production of safe raw milk. This training has been shown to reduce outbreaks and illnesses, increase safety, and lower insurance costs.

There will be a couple long (1+ hour) breaks built into the schedule so that you can attend to other activities before re-joining the online class.

Registration Fees and Scholarships

The fee to attend this class is $75 for people who aren't members of the OEFFA.

We have $50 scholarships available if the cost is prohibitive for you. Email sarah@rawmilkinstitute.org if you want more info on how to apply for a scholarship.

How to Register

If you'd like to attend, the online registration form is here: https://conference.oeffa.org/registration/

Our class is listed under "Food and Farm School Classes." Hope to see you there!

Udder Preparation for Raw Milk

Raw milk that is carefully and intentionally produced for direct human consumption is a low-risk food.  Udder preparation is one of the most important steps for producing clean, safe raw milk. If you don’t properly clean the udders and teats, dirt and manure contamination can contribute pathogenic bacteria into the milk. With proper cleaning and preparation of the udders and teats, the risk of pathogenic bacteria in the milk is dramatically reduced.

Manage the Environment

Got dirty, muddy udders? If so, that’s a sign that your farm conditions have some room for improvement. If you manage the farm environment properly, that will go a long way towards ensuring that your animals’ udders are fairly clean before even stepping into the milking parlor. The following are some important environmental factors to manage.

Clean and Dry Resting Places

If your animals are given a relatively clean and dry place to rest, they will be less likely to get filthy on a regular basis. Your individual farm will have its own unique challenges depending on the weather and landscape. Some examples of optimal resting areas are well-managed rotational pastures, compost bed packs in the barn, or other areas that are high, dry, and shaded.

Calves and Kids

Be aware that your animals’ offspring (calves, kids, etc.) can be a source of pathogens. Just like human babies, these animal babies explore the world with their mouths and can then directly transfer harmful bacteria to the udders. Animal babies have immature immune systems and are also more likely to harbor pathogens themselves. For low-risk raw milk production, ideally the calves/kids will be bottlefed and not allowed access to their mother’s udders. 

Chickens, Pigs, and Other Livestock

Poultry and livestock on the farm can be sources of pathogens as well.  For instance, if a cow lies down in a pasture with fresh chicken manure, her udders can become contaminated with salmonella or campylobacter pathogens. Ideally, the milk animals should be kept separately from other animals to reduce the pathogen risk.

Poultry should not be allowed into the milking parlor. Some raw milk farms choose to purposely rotate their chickens through the pastures after the cows/goats have moved through the pasture to ensure they are not sharing the space simultaneously.  If your chickens do share pastures with your milk animals, extra care will need to be taken to ensure the udders are properly cleaned before milking.    

Hair Management

Depending on the animal, there may be excess hair around the udders and teats. This hair can make it more difficult to properly clean the area before milking.  Regularly trimming the hair is one method for ensuring that proper cleaning can be achieved.

Additionally, the long tails on cows can become a source of contamination during milking when the cow switches her tail. Trimming the hair at the end of the tail is a good method for reducing this risk.  

Manure Management

Manure in the milking parlor can become a source of pathogen contamination, especially for cows which have much messier manure than goats and sheep. The milking parlor should be cleaned of manure on a daily basis before, during, and after milking. Giving cows a brief standing period or walk before leading them into the milking parlor is another method for reducing the amount of manure in the milking parlor.

Pre-Milking Udder Preparation

The end goal of udder preparation is for the udder to be clean and dry at the time of milking. A basic procedure to achieve this is as follows.

1.       Clean the udder and teats

2.       Pre-dip each teat in an iodine- or hydrogen peroxide-based teat dip

3.       Wipe off the teat dip

4.       Strip each teat and inspect the milk

5.       Apply the milking machine

6.       After milking, apply iodine-based post-dip to each teat

Each farm has its own unique challenges. There is no one procedure that will work perfectly for all farmers at all times. Here are some specific pointers that may help you in developing your own best udder preparation procedures.

Clean the Udder and Teats

If the udder and teats are very dirty, such as caked with mud or manure, you may need to do a wet soapy wash of the area first. There is no need to wet down the whole animal, as that will make it more likely for contamination to drip down onto the udders. Remember that wetness will allow bacteria to migrate from one area to another, and any bacteria is likely to end up at the low point which is the teats. If you must wash the udder and teats, make sure to dry them well before proceeding with the damp cloth wiping steps below. 

If the environment has been managed well, the udder and teats will probably be relatively clean when the animal enters the milking parlor. Use a clean, damp cloth to wipe off the teats and udder. Make sure to wipe from the teats outward, so that the teats are the cleanest parts. Using white cloths will allow you to easily see whether there is still any dirt or filth coming off the teats/udder.

Make sure to use a new cloth for each animal, and you may even need to use multiple cloths per animal to make sure the teats are well-cleaned. Have a separate bucket to place the soiled cloths into, so they don’t contaminate the clean cloths.

Pre-dip Teats in Iodine- or Hydrogen Peroxide-Based Teat Dip

After cleaning the udder and teats, pre-dip the teats. Both iodine and hydrogen peroxide-based teat dips are approved for organic milk production.

Iodine-based teat dips have been used successfully since the 1960’s and have a longer shelf life than hydrogen peroxide-based dips. Because iodine-based teat dips have a thicker consistency, care needs to be taken to ensure that the pre-dip is properly wiped off before milking. Iodine-based teat dips are currently quite expensive.

Hydrogen peroxide-based teat dips are much less expensive than iodine-based dips, but they also have somewhat less effectiveness in preventing mastitis. Hydrogen peroxide-based teat dips have a thinner consistency and thus can work well in spray applications. Care needs to be taken to ensure that the spray is applied to all sides of the teats.

Make sure to leave the pre-dip on for at least 30 seconds so that it has appropriate time to sanitize the teats. Beware not to dip dirty udders into your teat dip, else you may end up contaminating the whole cup! 

Once the teat dip has been on for at least 30 seconds, wipe off the teat dip with a clean, dry cloth.

Dip Then Strip, or Strip Then Dip?

It does not appear to matter whether you strip the teats and then pre-dip, or dip first and then strip the teats. Data from the National Mastitis Council has shown that there is “no significant difference in the monthly rate of clinical mastitis, new subclinical cases or milk per cow per day" whether the teats are stripped-then-dipped or dipped-then-stripped. Either way, the important thing is to build consistency and stick with your procedures. 

Strip Each Teat and Inspect the Milk

Using clean or gloved hands, manually strip a few squirts of milk out of each teat. Inspect the milk for any signs of coagulation, stringiness, blood, etc. If there is anything abnormal, the milk is best discarded or used for some other purpose rather than direct human consumption.

Apply the Milking Machine

Once the teats have been cleaned, dipped, stripped, and dried, you are ready to apply the milking machine. Manage the milk claws such that they never touch the ground, and are quickly applied to the teats once the vacuum is turned on.

After Milking, Apply Iodine-Based Post-Dip

Once the milking is done, apply an iodine-based post-dip to the teats. This will help to seal the teat orifice against bacteria. Try to ensure that the animals remain standing for at least 30 minutes after applying the post-dip; this will allow the dip to fully dry before there is any potential contamination from lying down.

Example Udder Prep Video

Here is a video example of udder preparation, so you can see some of the principles of proper udder preparation in action. Remember that each farm is unique, and there is no solitary procedure that will work perfectly for all farmers at all times.

Factory Farms vs. Sustainable Local Farms During COVID19

Milk is Being Dumped While Stores are Selling Out

Mother Nature has her ways of giving us advice. Sometimes that advice is subtle and sometimes it is brutal.  This time she was pretty direct, and she did not mix her signals.  Consolidated, centralized food systems have not been able to adapt to the rapid changes brought on by the COVID19 pandemic.

The Standard American Diet and its production, processing, logistics and delivery systems have failed.  American farmers that serve this highly consolidated food system are dumping 3 million gallons of milk per day; meanwhile American supermarkets are stripped clean of dairy products. The dairy processing industry which was previously supplying milk to schools and restaurants cannot rapidly adapt to bottling and delivering milk for retail sales.

For many years, the demand for fluid pasteurized milk has been dropping at a rate of ~1% per year. During this long decline, bottling plants have been closed and cheese plants have been opened. When America was asked to stay at home in response to COVID19, much of the food service industry was stopped, restaurants were idled, and schools were closed.

At home, kids wanted cereal and needed three meals every day. They wanted milk! The demand for milk raged upwards. Yet the supermarkets could not meet that demand. Panic-buying made matters even worse, with store shelves remaining sporadically empty for weeks, and even now milk is being rationed in many places.

Meanwhile, dairymen are dumping truckloads of milk. The market price of milk is dropping like a rock from $18 per hundredweight (CWT) to $14 CWT or even lower. The break-even price for dairymen is around $18-$20 CWT. Thus, dairies are continuing to fail at an unprecedented rate while stores are not able to meet the demand for milk.  It is an unmitigated disaster.

“Get Big or Get Out”

This is the 50 year old story of “Get Big or Get Out”. This philosophy of feeding the world and starving the American farmer was started in the early 1970’s by Earl Butz, who was Secretary of Agriculture under Nixon. Butz’s idea was that the most efficient farmers would overtake the smaller farmers, prices would drop, and supply would increase.

This structure concentrates power into the hands of a few aiming at cheap food for all, with an abundance which America would then export into the world markets. We would feed the world.  This design has become part of the America farm culture and has led to a massive decline in the number of dairies.  

Massive Decline in Number of Small Dairies

In 1940, America had over 4 million dairy farms. By the late 1990’s, that number had dropped to just over 100,000 dairies in the USA. Currently, there are only about 30,000 dairies left, and we are losing an additional 5% of dairies every year.   

According to USDA data, there has been a sharp decline in the number of dairies with 30-200 cows; meanwhile, the number of large dairy farms is increasing. From 1992-2012, “the number of dairy farms with at least 1,000 cows more than tripled.” One future-thinking dairy leader has projected that America will have only 100 dairies in 20 years. America would still have its 9+ million cows, but those cows would be contained in massive concentrated animal feeding operations (CAFOs) with 90,000 cows each.

Consumer polls clearly indicate that consumers don’t want their milk coming from 90,000 cow massive CAFO operations. The environmental impact from large CAFO operations is devastating. The manure lagoons are the size of lakes and the smell is horrendous. There are no pastures. The feedlots go on and on forever!  This system has many flaws, and more of those flaws showed themselves to the world in the last 6 weeks during the COVID19 pandemic.

Consolidated Food Systems Lack Resilience and Adaptability

COVID19 has demonstrated that a consolidated food system fails the American public in times of crisis. Consolidated massive operations and their logistics can not adapt and they are not resilient. These operations cannot adjust to changing market conditions and they fail when the consumer demands change. The consolidated milk industry failed to meet the needs of Americans because it was not able to respond and adapt in the face of rapid change. Similar issues have arisen in consolidated vegetable industries and meat industries during this crisis.

The food chain stress test has been performed. The results are in and America’s big food systems have failed miserably.  This has become a serious threat to American national food security!

Food security is seriously jeopardized with milk going to just a handful of milk processors. That’s the future of “Get Big or Get Out” and it is smelly, ugly, and does not work to serve America. Additionally, with so much of this system relying on imports and exports, when countries close their borders, this system cannot function.

Consumer Connected Farmers Are Thriving

The local farmer-to-consumer system has also been tested during this time of crisis, and the results have been quite different. Farmers who sell directly to consumers are thriving. The comparison of this market to the CAFO-driven market is dramatic.  

Farmer–to-consumer sales are highly adaptive and resilient, because the farmers are connected to their consumers. They know and hear one another!  Farmers can adjust quickly to changes in consumer demand. During the COVID19 pandemic, many dairy farmers who sell directly to consumers saw a huge increase in the demand for milk. They were able to meet this demand by diverting milk which would have been used to make butter and cheese into bottled milk instead. Both the farmers and consumers benefited from this ability of the farmers to adapt to the changing demand.

Farmers who sell directly to consumers produce fresh foods which are unprocessed or less-processed. These fresh foods support and build immune systems through nourishing healthy gut biomes. Up to 80% of the immune system makes its home in our gut and is powered by a biodiversity of bacteria and the whole foods that feed them. These foods come from sundrenched rich soils and local ethical farmers that connect directly to consumers. This food system is thriving and growing.

In contrast, highly processed foods with long shelf life, which are filled with preservatives and antibiotics, are destructive to the gut biome. Consumers have begun to understand this.

Within the dairy community, farms such as cow share programs, micro dairies that produce raw milk, and dairies with their own processing plants have been able to quickly adapt and respond to the changing demand from consumers and stores. These food systems are responsive, adaptive, nutritionally rich, and economically alive.

You Vote With Your Food Dollars

America must make a decision about its fate. Food systems are very much a part of our America. Will America thrive, be resilient and adapt to threats? Will America continue to become even more economically, environmentally, and immunologically compromised and depressed? Or will America embrace smaller local farms who produce nourishing whole foods? Will America embrace disease-prevention and whole food nutrition? Will it build or suppress its innate and adaptive immune systems?

Each dollar spent on food directs America’s future. Where we direct our food dollars is a very personal question. Will we have healthy children or not?  Will we take personal responsibility for our own health with whole food nutrition or will we continue to vote for “Get Big or Get Out”?   

The food system stress test results are in. Let’s move beyond “Get Big or Get Out.”  Let’s invest in illness prevention with farm-direct local, unprocessed, whole foods that build our immunity. It’s a personal gut microbiome choice. Let’s adapt and become resilient. The alternative is a dead end.

RAWMI Ripple - September 2019

September 2019 Edition

Dear Friend,

Welcome to the Fall 2019 edition of the RAWMI Ripple. Herein you'll find information about the latest in the world of raw milk, including recent training, lessons learned, a newly LISTED RAWMI dairy, and the battle for national legalization of raw butter.

RAWMI Farmer Training in Washington State and British Columbia, Canada

Earlier this month, RAWMI trained farmers in Washington State and Vancouver Island (in British Columbia, Canada). RAWMI presented two 4-hour, farmer-centered training classes, covering raw milk risk management from Grass-to-Glass. Nearly 50 farmers attended the training classes. The farmers in attendance represented production of cow milk, goat milk, and sheep milk! Both of the training presentations were recorded on video, to allow RAWMI to soon have a training video available for all raw milk farmers and prospective farmers.

RAWMI specifically chose to do training in Washington State in order to reduce the raw milk illness outbreak rate.  The training attendees were from Washington State, Oregon, and British Columbia, Canada.  While in Washington, RAWMI also visited Dungeness Valley Creamery, one of the largest raw milk dairies in Washington.

On Vancouver Island in British Columbia, RAWMI's training class was attended by farmers from Vancouver Island as well as mainland British Columbia.  This class was presented in association with the British Columbia Herdshare Association, which is a non-profit organization working towards the legalization of raw milk in British Columbia. While on Vancouver Island, RAWMI visited four dairies.

Just a few of the 32 participants at the British Columbia, Canada training

S & D Smith Dairy - RAWMI LISTED Dairy #19

Congratulations to S&D Smith Dairy in Yorkshire, Ohio for becoming the 19th RAWMI LISTED dairy! S&D Smith Dairy is a herdshare, operating on nearly 200 acres of certified organic land. Their herd consists of 12 to 16 Jerseys. Welcome to the RAWMI family! 

Pre-LISTING Audit of British Columbia Dairy

While in British Columbia Canada, RAWMI performed an on-site audit of a raw milk dairy that has applied for RAWMI LISTING. We studied the dairy's entire milk production system, from grass to glass, and witnessed the morning milking routine. The dairy farmer also allowed RAWMI board member Sarah Smith to get hands-on in going through the udder prep and milking routine, so Sarah got to milk a cow for the first time!

The Canadian dairy farmer was doing a great job of producing clean, low-risk raw milk. RAWMI was able to provide some constructive feedback for small improvements, and looks forward to LISTING yet another raw milk dairy in Canada.  

Board Changes at RAWMI

Due to other time commitments and priorities, Sylvia Onusic and Peg Coleman have resigned from the RAWMI Board of Directors and moved onto the Advisory Board. The RAWMI Board thanks Sylvia and Peg for their service on the RAWMI Board of Directors. The current RAWMI Board of Directors includes Mark McAfee (Chairman), Sarah Smith (Secretary), and Joseph Heckman, PhD.

Lessons from Churchtown Dairy Listeria Incident

In July 2019, RAWMI LISTED Churchtown Dairy in New York had a positive detection for Listeria monocytogenes. This positive detection came during a routine product sample test performed by New York State dairy inspectors. Although no illnesses had been reported, Churchtown dairy immediately issued a voluntary recall of all milk and embarked on comprehensive testing of their cows and facilities in order to determine the source of the Listeria mono.

With the assistance of RAWMI, Churchtown discovered that Listeria mono was growing inside a crack in an inflation liner on one of the milk claws. Churchtown was able to address the problem and was re-approved for raw milk production within a few weeks. Churchtown is commended for their quick action in addressing this matter in a transparent way.

In raw milk production, it is important to ensure that rubber inflation liners are changed frequently, as per the manufacturer's suggested cycle life. Any cracks in inflation liners can provide a place for biofilm growth between the liners and the stainless steel shell; that area does not get cleaned with typical Clean-In-Place protocols.  Biofilms are symbiotic colonies of bacteria that can adhere to the inside of the milk lines, valves, crevices, etc. Biofilms provide a safe haven for pathogen growth, and thus an important aspect of safe raw milk production is the prevention of biofilm growth. If you ever see milk or fluids running in the vacuum line, you have a problem and it should be immediately investigated. You probably have a crack in an inflation.

Raw Milk Posters and Brochures

In response to a request from RAWMI LISTED farmers, RAWMI has developed a series of raw milk posters and a brochure that details the benefits of being RAWMI LISTED. The posters and brochure can be used at the point-of-sale or online to increase awareness of the benefits of raw milk and RAWMI LISTING. These posters are already making a big splash for raw milk via RAWMI's Facebook page! Email sarah@rawmilkinstitute.org if you want to make use of the posters and/or brochures.

Unexpected FDA Testing of RAWMI LISTED Dairy

In late April 2019, the FDA sent a team of inspectors to Organic Pastures Dairy Company (OPDC), which is a RAWMI LISTED Dairy in California. The stated reason for the inspection was twofold:

• Assure compliance with a 10-year-old court order which mandated that OPDC not ship raw dairy products over state lines, and

• Assure that OPDC (as a processer and food handler) was in compliance with the new FDA Food Safety Modernization Act (FSMA) regulations.

The inspectors spent four days examining paperwork and swabbing surfaces in the on-farm creamery plant. They tested everything and everywhere: they swabbed under door mats, inside drains, behind doors, behind sinks, and all other surfaces. In total they took about 200 samples, and each was labeled for the location that it was taken. It was a massive search effort to find pathogens.

The team at OPDC had previously attended FDA FSMA training in 2018 and had already written their food safety plan for the FDA. They also had their RAWMI Risk Assessment and Management Plan and years of testing data to back it all up.

A couple weeks after the FDA inspection, OPDC received a report indicating that the FDA had found NO pathogens in any of their tests.

OPDC credits the environmental conditions inside of their dairy and creamery for the absence of pathogens. Aggressive beneficial cultures from the production of raw kefir, raw cheeses, and cultured butter populate the environment in the creamery, thereby displacing and outcompeting pathogenic bacteria. Thus, the creamery has its own facility biome and strong immune system!

In pasteurized dairy plants and creameries, pathogens are a real problem because sterility is the goal. Instead of using a system where beneficial bacteria outcompete pathogens, death to all bacteria is the goal. These attempts at a sterile environment encourage resistant forms of bacteria and pathogens to develop, as they adapt and overcome sanitizers and heat. However, just as is the case within the human gut, the presence of beneficial bacteria which can outcompete the pathogens is ideal. Of course, raw creameries should be clean, but they will also benefit from having beneficial bacteria which help prevent pathogenic bacteria from taking hold in the overall environment.

Importance of Methodology and Statistics in Challenging Canada’s Prohibition of Access to Raw Milk

The case challenging Canada’s prohibition of access to raw milk continued September 16-18 in Toronto. This case was brought forward by petitioners for Glencolton Farm.  Two experts, a regulatory authority for the Canadian government and an emeritus professor in dairy science, were cross examined by the attorney for Glencolton, with assistance from microbial risk assessor and former RAWMI board member Peg Coleman.

As noted in the May 2019 Ripple, RAWMI supported work by independent statistician Dr. Nick Azzolina which confirmed not only that there is no significant increase in outbreak rates with increasing access to raw milk, but also no increase in rates of illness or hospitalizations. With additional support from the Weston A. Price Foundation (WAPF) through the SRA Whole Truth, Whole Milk Campaign, Dr. Azzolina and Peg prepared a technical manuscript recently submitted to the prestigious journal Risk Analysis that includes more context and additional results for rates of illness and hospitalizations over time. For the Toronto case, this high level statistical analysis in both a report and a manuscript submitted for peer-review is directly applicable. Because of this work, expert witnesses for the Canadian government and others cannot make speculations about increasing raw milk outbreaks and illnesses without admitting that their views are based on opinion or flawed studies that are not based on a valid statistical analysis of data.

Other important questions arose in Toronto at last week’s cross examinations by the attorney for the Glencolton Farm petitioners, many regarding methodology for risk/benefit analysis. In cross examination, the experts attempted to dismiss all studies demonstrating benefits on the grounds that the mechanisms of benefit were not fully known. However, their dubious reasoning was challenged on the basis that risk predictions are also highly uncertain, and the mechanisms causing one person to develop illness and another to remain healthy are only partially understood. The reality is that uncertainties exist for predicting benefits as well as predicting risks, and formal methods are available for unbiased assessments.

It has been documented by Loss et al. (2015) that there is a significantly lower risk for children consuming raw versus pasteurized milk for monitored health outcomes including respiratory illnesses, fever and diarrhea. That same year, McCarthy and colleagues (2015) determined that pasteurized milk has unintended adverse consequences for immune system development linked to higher risks for allergy and inflammation than determined for raw milk. The advances of knowledge for raw milk benefits and risks, and their mechanisms, are the subject of another manuscript in preparation through the Whole Truth, Whole Milk Campaign. Thanks to WAPF, RAWMI, and other donors for supporting such rigorous independent analysis using well-described methodologies essential for peer-review, thereby strengthening the scientific basis for future decisions about raw milk in Canada, the US, and around the world.

The Battle for Butter

After years of waiting for the FDA to respond to a formally submitted “Citizen Petition”, there is now an exciting food fight finish on the horizon! Years ago, the FDA denied a Citizen Petition to legalize access to raw milk on a national level and to allow raw milk to be sold across state lines.  The FDA's letter of denial was lacking in scientific basis; it denied peer-reviewed literature that was published through the National Institutes of Health, and even denied that the European PARSIFAL study related to raw milk. The PARSIFAL study of over 14,000 children found that there was a statistically-significant lower rate of allergies, eczema, and asthma in kids who were raised in a farm environment and consumed raw milk. Yet the FDA insisted that “farm fresh milk" was not raw milk!

Additional EU studies followed after PARSIFAL and confirmed the findings. Raw milk is a powerful immune system building food. The FDA refused to accept any of this data even though it was PUBMED published and peer reviewed.  The FDA position clearly indicated their bias against raw milk, so a different approach was needed to increase consumer access to raw dairy products.

Together with the Farm to Consumer Legal Defense Fund, a third FDA Citizen Petition was submitted in 2015. This petition was about legalization of the shipment and sale of raw butter across state lines. Instead of taking down the whole raw dairy wall, we decided to focus on the weakest brick in the wall: RAW BUTTER! The rest of the bricks would come tumbling down later, after RAWMI had done its work to make raw milk very low risk and safe.

Raw butter is an exceptionally nutritious food. For instance, the enzyme alkaline phosphatase (ALP) is found in the butter fat membrane that covers fat globules. ALP decreases inflammation in the body; it is associated with good health and less chronic illness, such as cardiovascular disease and Type-2 diabetes. Raw milk has 4% butter fat, but raw butter contains 86% fat and thus it is very high in alkaline phosphatase.  ALP enzyme is destroyed by pasteurization. Americans are being denied access to raw butter which is a very powerful anti-inflammatory food, meanwhile we are suffering from more chronic illness!

Butter's low moisture, low pH levels, high fat content and salt levels inhibit pathogen growth and the FDA science concurs with this argument. Raw butter has had a near perfect track record of zero illnesses and no deaths for 60 years. The FDA is supposed to respond to Citizen Petitions within 180 days, but the Raw Butter Petition has had no response from the FDA for more than 3 years.

Now, RAWMI and the Farm-to-Consumer Legal Defense Fund are taking raw butter into the federal court system to force the FDA to respond and address each of the petition demands. The FDA should have no rational or reasonable basis for argument against raw butter and its legal access by all Americans. The courts should side with the facts and order the FDA to start regulating raw butter the way they regulate 60-day aged raw cheese, allowing it to pass freely all over America.

Additionally, RAWMI has been actively involved with working towards a change of Pennsylvania state law to allow raw butter to be produced and sold in Pennsylvania. According to those involved in the project, the new law appears to have broad support and will likely pass into law next year. 

Safe raw milk makes ultra-safe raw butter with powerful health benefits. We are looking forward to this food fight and the positive Ripple effect is can have on all the other raw dairy products. We're taking it one step at a time as we inch closer and closer to our vision of universal access to safe, low risk raw dairy products for all people.

RAWMI Training  

RAWMI will be providing a 3.5 hour presentation on raw milk risk management at the Pennsylvania Association for Sustainable Agriculture (PASA) conference. This conference is February 5-8, 2020 in Lancaster Pennsylvania. Mark McAfee, Sarah Smith, Dr. Joseph Heckman, and Edwin Shank will be presenting at this event.

RAWMI will be providing a 2 hour presentation on raw milk risk management at the Utah Farm and Food Conference on February 9, 2020. This conference is in Cedar City, Utah. Mark McAfee will be presenting at this event.

RAWMI has applied to present at several other upcoming conferences. RAWMI is also working on a web-based version of the raw milk risk management training, for farmers and others who aren't able to attend training in-person.

Take care all of you RAWMI producers, consumers and all of you interested in raw milk!