Immunity, the Immune System, and Raw Milk

Four Variables for Pathogenic Illness

Masks, social distancing, handwashing, testing: in the last few months, America has awoken to a whole new reality with an awareness that a compromised immune system is risky and dangerous. We are now talking about immune systems and compromised immunity like never before.  Yet, we haven’t been talking about host immunity, and why people have compromised immune systems.

We are the HOST and we have an immune system that protects us if it is strong. Bacterial, fungal, and viral pathogens need a host to survive and thrive, yet pathogens do not cause illness in every host. Scientists and doctors agree that in order for a pathogen to cause illness, four variables must align:

• A pathogen must be present

• The pathogen must be virulent and capable of producing harmful effects

• The pathogen load must be high enough

• The HOST  must be susceptible to the pathogen

Misplaced Focus on Compromised Immune Systems

Health professionals and the news media have avoided  discussion of our host immune systems, which naturally protect us all the time from pathogenic threats. Instead, they talk about how people with compromised immune systems and comorbidities (such as high blood pressure, diabetes, heart disease, and obesity) are being disproportionally affected by COVID19. Our American lifestyle and diet has predisposed large swaths of our population to having compromised immune systems and comorbidities.

Masks and social distancing aim to reduce the pathogen load, yet this narrative neglects the superior aim of strengthening the host. We have little  control over the strength of the COVID19 pathogen, and we can’t live behind masks forever, as we attempt to reduce pathogen load by social distancing and mask wearing  But what we can do is strengthen the host, and that means strengthening our own immune systems.

The best way to immunity is through

strong immune systems.

It is rare that healthy people with strong immune systems are significantly sickened by COVID19. As more and more antibody testing is performed on broad sectors of our population, it is being found that huge numbers of people already have COVID19 antibodies, even though they had no idea that they’d been exposed.  COVID19 has already become part of their adaptive immune response. “Herd immunity” is building whether we stand six feet apart, wash our hands or wear a mask….it is happening whether we like it or not.  The bigger question is: Are Americans up to facing this HOST threat?

Immune System Primer

The immune system is our body’s defense system that protects us from foreign invaders such as pathogenic bacteria and viruses. Immunity is developed by the immune system, and provides protection against illness from specific pathogens. Immunity from specific illnesses is achieved through both the innate and adaptive immune systems.

Image from MicrobeNotes.com

The innate immune system is a rapid–response, whole body protective system that blocks, controls, neutralizes and eliminates pathogenic threats. Elements of the innate immune system include our skin, white blood cells, killer T cells, the gut microbiome, mucus producing cells, tear duct lactoferrin, mucus membranes, lymphocytes, phagocytes, MAST cells, and cytokines. Our innate immune systems  protect us all the time if they are strong and functioning well. The very last thing you would ever want to do is injure or disable this system. Yet, that is exactly what we do whenever we take symptom relief medications which block mucus production or other natural systems that protect us. Antibiotics have been abused so badly that we now have tens of thousands of people that die every year from antibiotic-resistant bacteria. Our first-world innate immune systems and microbiomes have been damaged and  can no longer protect us.

The adaptive immune system is a slow-response system that creates specific immunity after the innate immune system has been the first line of defense. The adaptive immune system creates a long-term memory of the invader, thereby producing specialized antibodies against each specific invader. Antibodies can be likened to battle-hardened, experienced warriors who are ready to quickly protect against any similar attack that may come your way in the future. 

Vaccines aim to trick the body by introducing dead or weakened pathogens in an attempt to trigger the adaptive immune system to produce antibodies. It is possible to create immunity to a pathogen through vaccination and allowing antibodies to be created by your body’s adaptive immune response. Sometimes this works and sometimes it does not.

Creating antibodies means you must go to battle. Going into battle with a weak immune system is a serious risk! Having a strong, adaptive and resilient immune system is a powerful barrier to protect against bacterial, viral, and other threats.

We Damage Our Immune Systems

At the foundation of the immune system is the gut microbiome, which houses 70-80% of the immune system. In America we have embraced all sorts of things that weaken the gut microbiome: antibiotics, preservatives, GMOs, Roundup residues, high sugar diets, highly processed foods….these are all destructive to the gut microbiome and therefore they compromise the immune system. For instance, antibiotics weaken the innate immune system by disrupting the gut microbiome such that neutrophils and white blood cells are no longer able to react properly when threats arise. Antibiotics also weaken the adaptive immune system by reducing immunity to subsequent infection. Food additives such as preservatives effect immune cells and the inflammatory response, thus contributing to the development of comorbidities. Over the longer life experience, exposure to these foods and threats often manifests as chronic disease including diabetes, obesity, arthritis, asthma, whole body inflammation, heart disease etc.

Raw Milk and Milk Kefir Strengthen the Immune System

Nutrition is of prime importance in strengthening the immune system. Raw milk plays a very important part in building and strengthening both the innate and adaptive immune systems. Studies performed in Europe have shown that children who drink raw milk have decreased rates of asthma, allergies, eczema, ear infections, fever, and respiratory infections. These benefits are likely related to the active immune factors, biodiversity, prebiotics, intact protective proteins and other elements found in raw milk. Pasteurized milk does not confer these protective properties because the beneficial raw proteins and enzyme-based elements are denatured and inactivated by heat. Raw milk also contains antibodies which can be beneficial for the immune system.

Raw milk kefir is packed full of biodiversity and contains immune factors from the raw milk. Raw milk kefir is a powerful immune-building food which has been shown to stimulate and modulate the immune system, have a beneficial effect on the composition of the gut microbiome, and reduce allergies. Fermented milk has also been shown to reduce the duration of respiratory infections and colds in the elderly.

Raw Milk Is Similar to Breastmilk

Researchers have likened the protective effects of raw milk to those of breastmilk. Breastmilk is raw milk! Many “agents with beneficial anti-microbial or immune-modulatory effects are shared in bovine and human milk, such as immunoglobulins, cytokines, growth factors, lactoferrin, oligosaccharides, and milk fat globule membranes.”

A recent study of breastmilk from mothers with COVID19 in New York found that the breastmilk contained antibodies to COVID19. This means that infants of mothers infected with COVID19 would receive immunity-building properties directly through breastmilk. Similar effects have been demonstrated with hyperimmune cow’s milk, which has been shown to contain specific antibodies that may boost the immune system. When cows are purposely exposed to pathogens during the dry period, their colostrum contains antibodies to those pathogens for their calves at birth. Research at UC Davis is now investigating whether hyper-immune milk can be produced to protect humans from COVID19.

Raw milk is the first food of life. Its role is not just nourishment; raw milk protects the baby by building the immune system and contributing to a powerful gut microbiome. Over thousands of years of evolution, raw milk has been tested and refined by the trials of successive generations which allow only the best to thrive. The numerous immune system factors present in raw milk intentionally strengthen the baby’s weak immune system, with elements needed for both the innate and adaptive immune systems.

Personal Responsibility for Our Immune Systems

Personal responsibility is critical in building strong immune systems. A strong gut microbiome should be the goal of anyone looking for long-term immune system strength and the subsequent immunity that this brings. Doctors cannot help us with this. We must take responsibility for our own health by purposely building and keeping our immune systems strong. We can care for our gut microbiomes by providing them with whole foods which nourish our biodiversity. Like breastmilk, raw milk and raw milk kefir are self-contained immune system building super foods. Four variables must align in order for a pathogen to make you sick. You have control over the HOST variable and perhaps can reduce the load variable. You are very much in charge of your health and your ability to adapt to all threats, today and into the future.  Drink up your delicious raw milk and thrive!

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.

Meet a Renegade Wisconsin Raw Milk Dairy Farmer!

We’re giving a big “Welcome!” to Wisconsin’s Grassway Organics, the latest farm to become LISTED by the Raw Milk Institute. Chaz and Meghan Self have been farming at Grassway Organics since 2016, producing raw milk as well as pasture-raised chickens and eggs, beef, turkeys, and hogs. They’ve also innovated with “Pizza on the Farm,” where they serve up wood fired pizzas to their local community.

Although Wisconsin is the Dairy State, dairy farms all over Wisconsin are failing at an unprecedented rate. The state lost 773 dairies in 2019 alone! Conventional dairies are floundering amidst low prices that make it nearly impossible to break even. Like many other dairy farmers, Chaz and Meghan Self have found that producing raw milk provides a way to stay viable while providing a product that consumers are clamoring for. With raw milk’s extensive health benefits, and increasing evidence that raw milk can be produced safely, more and more consumers are choosing to drink raw milk.

Even though consumers are demanding raw milk, Wisconsin’s laws make it very difficult to produce raw milk. By law, only “incidental sales” of raw milk are allowed in Wisconsin. Chaz and Meghan Self are hoping to lead a change, thereby allowing healthy, low-risk raw milk to move into the mainstream in Wisconsin.

Grassway Organics has worked diligently to become LISTED by the Raw Milk Institute, developing their own Risk Assessment and Management Plan and even building their own on-farm lab for bacteria testing. They are testing their milk frequently to ensure that it meets the RAWMI Common Standards for low-risk raw milk. Grassway Organics will be a great addition to the Raw Milk Institute’s community of farmers.

FAQ About Raw Milk and COVID19

Got questions about raw milk and COVID19? We’ve gotcha covered!

• Can I catch COVID19 by drinking raw milk?

• Does raw milk strengthen the immune system?

• Does raw milk support lung health?

• Is raw milk healthier than pasteurized milk?

• I thought raw milk was unsafe. Isn’t pasteurization necessary for safety?

• Where can I find tested, low-risk raw milk?

• What if there aren’t any Raw Milk Institute LISTED dairies near me?

Check out questions and answers about raw milk and COVID19 here:

RAW MILK RISK MANAGEMENT WORKS!

There is a growing body of evidence that raw milk is a low-risk food when it is produced carefully and intentionally. Previous papers, such as “Recent Trends in Unpasteurized Fluid Milk Outbreaks, Legalization, and Consumption in the United States,” have shown that the rate of raw milk related outbreaks is decreasing, meanwhile the consumption of raw milk is increasing.

In a new paper published in the January 2020 Journal of Epidemiology and Infection, Cat Berge and Ton Baars have investigated the use of intentional raw milk production and testing practices in the USA, Canada, and Germany. Berge and Baars compared test data from raw milk intended for pasteurization to test data from the Raw Milk Institute, the German Vorzugsmilch system, and the British Columbia Herdshare Association. The test data show that raw milk being intentionally produced for human consumption is fundamentally different from pre-pasteurized milk that is taken from bulk tanks. It was concluded that "raw milk can be produced with a high level of hygiene and safety.”

This paper provides further proof that, with farmer training, careful production practices, and ongoing testing, low-risk raw milk is achievable! This is great news, since raw milk has been shown to have protective effects against asthma, allergies, eczema, respiratory infections, ear infections, and fevers.

RAWMI Ripple - January 2020

January 2020 Edition

Dear Friend,

Welcome to the January 2020 edition of the Raw Milk Institute (RAWMI) Ripple. Herein you'll find information about the latest in the world of raw milk, including a new meta-analysis on the protective health effects of raw milk, the Interstate Milk Freedom Act, RAWMI training, and additional resources for raw milk education.

Meta-Analysis of Raw Milk Effects on Asthma, Allergies, and Infections

A recent issue of the Journal of Allergy and Clinical Immunology: In Practice published a peer-reviewed meta-analysis of eight health studies related to raw milk. A meta-analysis is a quantitative statistical analysis which combines the results of multiple scientific studies, thereby allowing the researchers to derive overall conclusions about that body of research.

The November 2019 paper, titled “The Beneficial Effect of Farm Milk Consumption on Asthma, Allergies, and Infections: From Meta-Analysis of Evidence to Clinical Trial” was written by a team of researchers from the Netherlands and Germany. The meta-analysis concluded that, when taken as a whole, the body of data from the previous studies shows that raw milk consumption in childhood has a protective effect on asthma, current wheeze, allergic rhinitis (hay fever), and atopic sensitization (allergies to environmental triggers).

When the previous raw milk studies were criticized, the detractors instead attributed the protective health effects to the farm environment rather than raw milk. However, the 2019 meta-analysis shows differently: “The effect particularly on asthma was observed not only in children raised on farms (OR, 0.62; 95% CI, 0.58-0.82) but also in children living in rural areas but not on a farm (OR, 0.60; 95% CI, 0.48-0.74). This demonstrates that the effect of farm milk consumption is independent of other farm exposures and that children not living on a farm can theoretically profit from this effect.” 

Interstate Milk Freedom Act HR 5410

It is currently illegal to sell raw milk across state lines in the United States. The FDA’s ban on interstate raw milk harms small farms as well as informed consumers, who purposely seek out raw milk for its health benefits and superb taste. The Interstate Milk Freedom Act HR 5410 seeks to prohibit federal interference with the interstate sale of raw milk. This bipartisan bill was sponsored by Representatives Thomas Massie (Republican from Kentucky) and Chellie Pingree (Democrat from Maine).

“Federal agencies, such as the FDA, that are part of the executive branch do not and should not have the power to shut down trade between peaceful farmers and willing consumers. It is Congress’s job to legislate,” said Rep. Massie. “Our Interstate Milk Freedom Act would make it easier for families to buy milk of their choice by reversing the criminalization of specific dairy farmers.”

“So many people across the country want to make sure their food is fresh and local—including fruits, vegetables, and even their milk,” said Rep. Pingree. “Raw milk is currently the only food banned for interstate commerce—an onerous regulation that hurts small farmers for selling milk straight from their cows to the consumer.”

It is time for the ban on interstate raw milk to be overturned. Ask your representatives to support HR 5410.

Northeast USA RAWMI Training

Studies have shown that raw milk has superb nutrition and protective health effects, but raw milk needs to be carefully and intentionally produced in order to ensure that it is a low-risk food. Through education, outreach, and research, RAWMI is working towards universal access to safe raw milk for everyone.

Earlier this month, RAWMI held raw milk training sessions at Rutgers University, the Northeast Organic Farming Association (NOFA) Massachusetts, and NOFA New York. These presentations focused on raw milk benefits as well as risk management for the production of safe, low-risk raw milk. 50 dairy farmers attended these three training sessions.

On February 6, 2020, RAWMI will be providing a 3&1/2 hour presentation on raw milk risk management at the Pennsylvania Association for Sustainable Agriculture (PASA) conference in Lancaster Pennsylvania. Mark McAfee, Sarah Smith, Dr. Joseph Heckman, and Edwin Shank will be presenting at this event.

International Milk Genomics Consortium Conference

The 16th International Milk Genomics Consortium (IMGC) Symposium was held on November 12-14, 2019 in Aarhus Denmark. This conference focused on milk and health from a sustainability perspective, with a wide variety of presentation topics including environmental challenges in milk production, effects of breastmilk and ruminant milk on the gut microbiome, structure and function of milk, and the superb nutrition of whole foods versus supplements.

The Raw Milk Institute was an official sponsor of this IMGC Symposium and provided sponsorship to Dr. Joanne Whitehead in attending to present her peer-reviewed, published raw milk risk analysis poster depicting the positive impact of “high standards, farmer training and frequent testing” on raw milk risk reduction.

New Resources for Raw Milk Education

The Raw Milk Institute has developed several new resources for educating people about raw milk.

RAWMI’s letter to medical professionals about the benefits and safety of raw milk provides a comprehensive summary of the latest science on the nutritional and health benefits of raw milk, therapeutic use of raw milk, the negative impacts of pasteurization, and the safety of raw milk.

In response to a request from RAWMI LISTED farmers, RAWMI has also developed a new trifold brochure about the benefits of raw milk. This brochure can be used at the point-of-sale or online to increase awareness of the benefits of raw milk. Email sarah@rawmilkinstitute.org if you want to make use of this brochure.

LISTED Farmers Quarterly Meeting

RAWMI LISTED farmers are able to connect and share with other raw milk farmers during quarterly video conferences. At the most recent video conference, farmers from 11 RAWMI LISTED dairies discussed issues including challenges to exclusive grass-feeding, recent problems and lessons learned, marketing, and the erosion of the “organic” label.

Ancient Baby Bottles Reveal Ruminant Milk Being Fed to Children

Raw milk has been nourishing children for millennia! The oldest baby bottle-like vessel found thus far is nearly 8,000 years old. Recently, three independent lipid analyses of residue from ancient baby bottles has been performed. These analyses have provided evidence that ruminant milk (such as cow, sheep, or goat milk) was being fed to children thousands of years ago.

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

Legalize Interstate Raw Milk

Did you know that it is currently illegal to sell raw milk across state lines? The FDA’s ban on interstate raw milk harms small farms as well as informed consumers, who purposely seek out raw milk for its health benefits and superb taste.

Raw milk that is carefully and intentionally produced for direct human consumption is a low-risk food, and recent improvements in raw milk risk management methods and training have led to a significant reduction in raw milk-related illnesses and outbreaks.

Numerous scientific studies have shown that raw milk is correlated with decreased rates of asthma, allergies, eczema, otitis, fever, and respiratory infections. Raw milk consumption is also correlated with improved lung function and gut health.

It is time for the ban on interstate raw milk to be overturned. The Interstate Milk Freedom Act is a bipartisan bill that would prohibit federal interference with interstate transport of raw milk. Ask your representatives to support HR 5410.

Letter to Medical Professionals about Raw Milk

The Raw Milk Institute has written a letter addressed to medical professionals about the benefits and safety of raw milk. This letter provides a comprehensive summary of the latest science on the nutritional and health benefits of raw milk, the negative impacts of pasteurization, and the safety of raw milk.

Feel free to share this letter far and wide! It can be used to educate your family doctor or other healthcare professionals about why you choose to drink raw milk. And it can also be given to interested family and friends who want to know more about raw milk.

Raw Milk Institute Board of Directors

RawMilkInstitute.org

December 2019

To: Medical Professionals and Healthcare Providers

Re: Raw Milk as a Low-Risk Therapeutic Tool

EXECUTIVE SUMMARY

Several medical associations, including the American Academy of Pediatrics, Canadian Medical Association, and Australian Medical Association, promote a position against consumption of raw milk or raw milk products.  The stated reasons for this position are that raw milk may contain dangerous pathogens  and that raw milk does not possess any benefits over pasteurized milk. However,  these conclusions are outdated and in conflict with the most up-to-date peer-reviewed and internationally-published research.

It is true that raw milk produced as “intended for pasteurization” and sourced from  Concentrated Animal Feeding Operations (CAFOs) is generally unsanitary and unsafe to consume raw.  Such milk is being produced in conditions where animal health is compromised, antibiotics are utilized, hormones are used to stimulate higher levels of milk production, there is an abundance of manure, and there is a corresponding high rate of pathogens.  This type of milk is generally commingled with milk from multiple dairies, which increases the risk of pathogenic exposure. This type of raw milk is actually defined under the Grade A Pasteurized Milk Ordinance.  At the Raw Milk Institute, we agree that consumption of this type of raw milk is high risk.

However, raw milk that is carefully and intentionally produced for direct human consumption is a low-risk food with superb nutritional benefits. This type of raw milk is wholly different from raw milk being produced in unhygienic conditions. Raw milk intended for direct human consumption is produced in sanitary conditions, with much care to ensure that the animals are healthy and that the milk is clean. This type of raw milk is tested often and held to rigorous standards to ensure that it is being produced in a way that discourages pathogen growth.  

Carefully produced raw milk has numerous health advantages over pasteurized milk. Whereas pasteurized milk is now recognized as a top food allergen and difficult to digest, raw milk is actually a health-supporting food with rich therapeutic potential and is easily digested by most consumers.  Like breastmilk, raw milk is a living whole food which provides excellent nutrition along with health-supporting enzymes and probiotics. Raw milk has a superior nutrient profile, whereas pasteurized milk has diminished nutrition with denatured proteins and fats. People who are lactose intolerant can often consume raw milk with no maldigestion, due to the presence of a variety of living bacteria which facilitate production of lactase enzyme in the intestines. Numerous scientific studies have shown that raw milk is correlated with decreased rates of asthma, allergies, eczema, otitis, fever, and respiratory infections. Raw milk also aids in recovery from antibiotic use, and provides many gut-healthy probiotics and enzymes.

Carefully produced raw milk is a health-promoting food that has been maligned because of the simple fact that people are confusing it with commodity milk that has been produced with the intention to be pasteurized. Doctors and healthcare professionals routinely warn patients that raw milk is unsafe to consume, but there is ample evidence that this conclusion is not applicable to carefully-produced raw milk. For the health of your patients and clients, please consider the following information about the benefits and safety of raw milk.

Nutritional Benefits of Pasteurized Milk vs. Raw Milk

Pasteurized milk is now known as one of the foremost allergenic foods [1]. Scientific evidence against pasteurized milk is mounting: for instance, a study of nearly 800 European children found that children who consumed pasteurized milk were more likely to show signs of milk allergy, whereas children who consumed raw milk were protected from milk allergy [2]. The process of pasteurization denatures and destroys many nutrients, so much so that synthetic vitamins are added back in after pasteurization.

The CDC argues that, "Most of the nutritional benefits of drinking milk are available from pasteurized milk" and "the heating process of pasteurization inactivates some enzymes in milk but scientists do not believe these enzymes are important in human health"[3].  These conclusions are clearly outdated and in conflict with the most recent research. Current science has shown that pasteurization has a negative effect on the nutritive qualities of milk, and the impact is not inconsequential.

Pasteurization of milk has been shown to:

• Reduce the bioavailability of calcium and phosphorus [4, 5],

• Reduce the presence of copper and iron [6],

• Reduce Vitamins A, B Complex, C, and E [3, 7, 8],

• Destroy beta-lactoglobulin, thereby decreasing intestinal absorption of Vitamins A and D [9, 10],

• Destroy probiotics [11], including lactobacillus and pediococcus, and

• Inactivate beneficial enzymes, including lactase, alkaline phosphatase, and lactoperoxidase [12, 13].

In many ways, raw milk can be likened to breastmilk: they both contain a wide array of beneficial nutrients, enzymes, vitamins, and minerals, in their natural form which is most easily utilized by the body. Both raw milk and breastmilk are designed to provide excellent nutrition and strengthen the immune system . It is widely acknowledged that breastmilk is the best food for the early years of life, however raw milk is a natural next step after breastfeeding. Raw milk, and especially raw milk from pastured animals [14],  is a great source of calcium, iron, Vitamins A, D & K, phosphorus, zinc, conjugated linoleic acid (CLA), and omega-3 fatty acids, plus many beneficial enzymes and probiotics.

Raw milk contains many types of beneficial enzymes, yet these enzymes are inactivated by pasteurization. For instance, raw milk contains protease enzyme, which aids in digestion of proteins [13], and lipase enzyme, which aids in digestion of fats [15].   Lactoperoxidase is a naturally occurring antimicrobial enzyme in raw milk [16]. Alkaline phosphatase enzyme is attached to the fat globules in raw milk; intestinal alkaline phosphatase enzyme is associated with decreased inflammation and lower rates of cardiovascular disease and Type-2 diabetes [17]. These and numerous other beneficial enzymes in raw milk are inactivated by pasteurization.

Beneficial probiotics in raw milk are diverse and abundant. These raw milk probiotics have a number of known health benefits. For example, raw milk contains a variety of living bacteria which facilitate the production of lactase enzyme in the intestine, which has been shown to help with lactose digestion in lactose intolerant people [18]. Lactobacilli "typically inhibit pathogenic organisms, reduce lactose intolerance, increase the immune response and often are gastrointestinal isolates... Other milk and dairy isolates that exhibit probiotic properties include strains of Lactococcus lactis as well as a variety of Pediococcus, Leuconostoc, Enterococcus and Streptococcus isolates... Strains of P. freudenreichii, and to a lesser extent P. acidipropionici, have begun to attract attention as potential probiotics as a consequence of studies revealing an ability, either alone or in combination with other probiotics, to reduce pathogen adhesion to mucus, increase bifidobacteria counts in the gut, aid in restoring a healthy gut microbiota, improve bowel movement, alleviate inflammatory disorders and reduce allergy development in infants" [19]. Probiotics are destroyed by pasteurization.

Health Benefits of Raw Milk

From 1893-1999, the American Association of Medical Milk Commissions  (AAMMC) certified clean, safe raw milk for human consumption and even medical therapeutic use. This certified raw milk was recognized to be of therapeutic benefit for infants, children, and adults [20]. This milk was used effectively in hospitals around the United States and was used to treat a wide variety of chronic diseases, including cardiovascular disease, renal disease, liver disease, hypertension, edema, asthma, arthritis, tuberculosis, and diabetes [21, 22, 23].

Dr. Charles Porter MD published the book Milk Diet as a Remedy for Chronic Disease, which details his use of a raw milk diet in the treatment of over 18,000 patients over the course of 27 years. Dr J.E. Crewe MD, one of the founders of the Mayo Foundation, successfully used raw milk in his medical practice for over 15 years, and said that the "results obtained in various types of disease have been so uniformly excellent that one’s conception of disease and its alleviation is necessarily changed... When sick people are limited to a diet containing an excess of vitamins and all the elements necessary to growth and maintenance, they recover rapidly without the use of drugs and without bringing to bear all the complicated weapons of modern medicine" [22].

More recent scientific studies have shown that raw milk is associated with a number of tangible health benefits:

• A study of over 8,000 European children showed that raw milk consumption is associated with significantly lower rates of asthma and allergies [24].

• A study of over 900 European children concluded that, "Continuous farm [raw] milk consumption in childhood protects against asthma at school age" [25].

• A study of over 14,800 European children concluded that there is a "significant inverse association between farm [raw] milk consumption and childhood asthma, rhinoconjunctivitis, sensitization to pollen, a mix of food allergens, and horse dander" [26].

• A study of over 3,000 USA adults concluded that, " Raw milk, if the main type of milk consumed in childhood, was also associated with reduced risk of atopy" and current raw milk consumption in adulthood intensified this beneficial effect [27]. 

• A study of over 3,000 USA adults concluded that, "raw milk consumption, particularly early in life, is associated with better pulmonary function in adulthood" [28].

• A study of over 900 European children concluded that, "Early life consumption of raw cow's milk reduced the risk of manifest respiratory infections and fever by about 30%" [29].

• A study of over 4,000 European children found that consumption of raw milk was associated with a strong protective effect against eczema [30].

These studies specifically compared raw milk to pasteurized milk, and have concluded that raw milk has significant health benefits over pasteurized milk.

Safety of Raw Milk

It is important to note that there is no such thing as a perfectly safe food [20]. An analysis of foodborne illnesses from 2009-2015 showed that the top food categories commonly linked to illnesses were chicken, pork, and seeded vegetables [31]. Pasteurized milk is not perfectly safe, either, and is implicated in foodborne illnesses and outbreaks every year.  CDC outbreak and illness data since 1972 shows at least 82 deaths from pasteurized dairy products.

The CDC outbreak and illness data which is used to assert that raw milk is unsafe does not distinguish raw milk intended for pasteurization from raw milk that is carefully produced and intended for direct human consumption. The FDA has no standard for raw milk intended for human consumption. It has only the Pasteurized Milk Ordinance (PMO).  It is known that raw milk intended for pasteurization often contains pathogens; studies have shown that up to 24% of this type of milk tests positive for pathogens [32]. Additionally, the CDC data used to implicate raw milk includes outbreaks and illnesses from “bathtub cheese” (i.e. Mexican-style Queso Fresco made illegally at home); queso fresco is inherently more dangerous than raw milk, and is associated with more serious outbreaks and illnesses. The CDC data reports only two deaths from raw dairy products since 1972, and both of these deaths were associated with queso fresco.

Nearly 10 million people in the USA were consuming raw milk regularly as of 2007 [33], and the number of people consuming raw milk is likely to be higher now given the growing popularity of raw milk. An independent assessment of raw milk risks from 2000-2007, which excluded queso fresco-related illnesses and outbreaks, concluded that there was a "a roughly 1 in 94,000 chance of becoming ill from drinking unpasteurized milk during that period... During the 2000−2007 period, there were 12 hospitalizations for illnesses associated with raw fluid milk. That’s an average of 1.5 per year. With approximately 9.4 million people drinking raw milk, that means you have about a 1 in 6 million chance of being hospitalized from drinking raw milk" [34].

Furthermore, recent improvements in raw milk risk management methods and training have led to a significant reduction in raw milk-related illnesses and outbreaks.  The Raw Milk Institute, founded in 2011, has developed farmer training and Common Standards for raw milk which is intended for direct human consumption. These rigorous standards and training result in low-risk raw milk, as documented in a 2018 peer-reviewed paper titled, " Recent Trends in Unpasteurized Fluid Milk Outbreaks, Legalization, and Consumption in the United States." This paper concluded that, "The rate of unpasteurized milk-associated outbreaks has been declining since 2010, despite increasing legal distribution. Controlling for growth in population and consumption, the outbreak rate has effectively decreased by 74% since 2005" [35].

A Balanced Viewpoint About Raw Milk

Commodity raw milk and dedicated raw drinking milk are categorically different foods.  It is clear that raw milk produced with the intention to be pasteurized is likely to contain dangerous pathogens. However, raw milk that is carefully produced for direct human consumption is subjected to rigorous testing and standards. Evidence has shown that this type of raw milk is a low-risk food.

Raw milk has superior nutrition and significant health benefits over pasteurized milk.  Raw milk contains greater bioavailable nutrients than pasteurized milk, as well as a wide array of beneficial enzymes and probiotics which are known to have benefits on the immune system and gastrointestinal tract.  Raw milk consumption has been correlated with increased resistance to allergies, asthma, respiratory infections, otitis, and eczema.  Thus, raw milk can be an important therapeutic tool.

If you would like more information about raw milk, please feel free to contact the Raw Milk Institute by email at contact@rawmilkinstitute.org .

The Raw Milk Institute is a 501(c)3 non-profit organization dedicated to mentoring and training farmers in the production of safe, low-risk raw milk.

References

[1] Frequently Asked Questions About Food Allergies. Food and Drug Administration website as of November 7, 2019. https://www.fda.gov/food/food-allergens/frequently-asked-questions-about-food-allergies

[2] Atopic sensitization in the first year of life. Journal of Allergy and Clinical Immunology. 2013; 131(3):781-8. Depner M, Ege MJ, Genuneit J, Pekkanen J, Roponen M, Hirvonen MR, Dalphin JC, Kaulek V, Krauss-Etschmann S, Riedler J, Braun-Fahrländer C, Roduit C, Lauener R, Pfefferle PI, Weber J, von Mutius E; PASTURE Study Group. https://www.jacionline.org/article/S0091-6749(12)01975-6/fulltext

[3] Raw Milk Questions and Answers. US Department of Health & Human Services, Centers for Disease Control and Prevention website as of November 6, 2019. https://www.cdc.gov/foodsafety/rawmilk/raw-milk-questions-and-answers.html

[4] A Comparison of Raw, Pasteurized, Evaporated, and Dried Milks as Sources of Calcium and Phosphorus for the Human Subject. Department of Food Economics and Nutrition, Kansas Experiment Station, Manhattan. 1928. Kramer MM, Latzke E, Shaw MM.

[5] Assessing the effects of severe heat treatment of milk on calcium bioavailability: in vitro and in vivo studies. Journal of Dairy Science. 2010; 93(12): 5635-43. Seiquer I, Delgado-Andrade C, Haro A, Navarro MP. https://www.ncbi.nlm.nih.gov/pubmed/21094734

[6] Effect of processing on contents and relationships of mineral elements of milk. Food Chemistry. 1994; 51(1): 75-78. Zurera-Cosano G, Moreno-Rojas R, Amaro-Lopez M. https://www.sciencedirect.com/science/article/pii/0308814694900507

[7] Influence of thermal and other manufacturing stresses on retinol isomerization in milk and dairy products. Journal of Dairy Research. 1998; 65(2): 253-60. Panfili G, Manzi P, Pizzoferrato L. http://europepmc.org/abstract/med/9627844

[8] A systematic review and meta-analysis of the effects of pasteurization on milk vitamins, and evidence for raw milk consumption and other health-related outcomes. Journal of Food Protection. 2011;74(11):1814-32. Macdonald LE, Brett J, Kelton D, Majowicz SE, Snedeker K, Sargeant JM. https://www.ncbi.nlm.nih.gov/pubmed/22054181

[9] Intestinal uptake of retinol: enhancement by bovine milk beta-lactoglobulin. American Journal of Clinical Nutrition. 1989; 49(4): 690-94. Said HM, Ong DE, Shingleton JL. https://academic.oup.com/ajcn/article-abstract/49/4/690/4732752

[10] Evidence for beta-lactoglobulin involvement in vitamin D transport in vivo--role of the gamma-turn (Leu-Pro-Met) of beta-lactoglobulin in vitamin D binding. FEBS Journal. 2009; 276(8):2251-65. Yang MC, Chen NC, Chen CJ, Wu CY, Mao SJ. https://febs.onlinelibrary.wiley.com/doi/full/10.1111/j.1742-4658.2009.06953.x  

[11] The growing role of probiotics. Harvard Men's Health Watch. 2018. Harvard Medical School. https://www.health.harvard.edu/staying-healthy/the-growing-role-of-probiotics

[12] Alkaline Phosphatase Testing for Milk Pasteurization. Dairy Foods Science Notes. 11-07. Department of Food Science, Cornell University. https://foodsafety.foodscience.cornell.edu/sites/foodsafety.foodscience.cornell.edu/files/shared/documents/CU-DFScience-Notes-Milk-Alk-Phosphatase-11-07.pdf

[13] Proteolytic Systems in Milk: Perspectives on the Evolutionary Function within the Mammary Gland and the Infant. Journal of Mammary Gland Biology and Neoplasia. 2015; 20(3-4):133-47. DC Dallas, NM Murray, J Gan.

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4637187/

[14] The Role of Trees and Pastures in Organic Agriculture. Sustainable Agriculture Research. 2015; 4: 47-55. J Heckman. http://www.ccsenet.org/journal/index.php/sar/article/view/50105

[15] Lipases in bovine milk and the relationship between the lipoprotein lipase and tributyrate hydrolysing activities in cream and skim-milk. Journal of Dairy Research. 1975; 42(2): 255-66. HB Castberg, T Egelrud, P Solberg, T Olivecrona. https://www.ncbi.nlm.nih.gov/pubmed/237941

[16] Contribution of the lactoperoxidase system to the keeping quality of pasteurized milk. Journal of Dairy Research. 1999; 66(1):73-80. Barrett NE, Grandison AS, Lewis MJ. https://www.ncbi.nlm.nih.gov/pubmed/10191475

[17] Dairy products and the French paradox: Could alkaline phosphatases play a role? Medical Hypotheses. 2016; 92:7-11. Lallès JP. https://www.sciencedirect.com/science/article/abs/pii/S0306987716300500?via%3Dihub

[18] Effect of a single dose of lactase on symptoms and expired hydrogen after lactose challenge in lactose-intolerant subjects. Clinical Pharmacy. 1992; 11(6):533-8. Sanders SW, Tolman KG, Reitberg DP. https://www.ncbi.nlm.nih.gov/pubmed/1534729

[19] The complex microbiota of raw milk. FEMS Microbiology Review. 2013: 37(5), 664-98. Quigley L, O'Sullivan O, Stanton C, Beresford TP, Ross RP, Fitzgerald GF, Cotter PD. https://academic.oup.com/femsre/article/37/5/664/541439

[20] Securing Fresh Food From Fertile Soil, Challenges to the Organic and Raw Milk Movements. Renewable Agriculture and Food Systems, Cambridge University Press. 2017. J Heckman. https://www.cambridge.org/core/journals/renewable-agriculture-and-food-systems/article/securing-fresh-food-from-fertile-soil-challenges-to-the-organic-and-raw-milk-movements/18325E375E068A538E07EF4E6F6ABA22

[21] Porter, Charles Sanford. Milk Diet as a Remedy for Chronic Disease. Burnett P.O., California, 1911. https://archive.org/details/milkdietasremedy00portiala/page/n1

[22] Use of Milk in the Treatment of Human Disease. Proceedings of the 29th Annual Meeting of the United States Live Stock Sanitary Association. 1925. Crewe JE. https://www.usaha.org/upload/Proceedings/1897-1929/1925_TWENTY_NINTH_ANNUAL_MEETING.pdf

[23] Macfadden, Bernarr. The Milk Diet: How to Use the Milk Diet Scientifically at Home. 1923.

[24] The protective effect of farm milk consumption on childhood asthma and atopy: The GABRIELA study. Journal of Allergy and Clinical Immunology. 2011; 128 (4): 766-73. Loss G, Apprich S, Waser M, Kneifel W, Genuneit J, Büchele G, Weber J, Sozanska B, Danielewicz H, Horak E, Joost van Neerven RJ, Heederik D, Lorenzen PC, von Mutius E, Braun-Fahrländer C; GABRIELA study group. https://www.jacionline.org/article/S0091-6749(11)01234-6/fulltext

[25] ω-3 fatty acids contribute to the asthma-protective effect of unprocessed cow's milk. Journal of Allergy and Clinical Immunology. 2016; 137 (6): 1699-1706. Brick T, Schober Y, Böcking C, Pekkanen J, Genuneit J, Loss G, Dalphin JC, Riedler J, Lauener R, Nockher WA, Renz H, Vaarala O, Braun-Fahrländer C, von Mutius E, Ege MJ, Pfefferle PI; PASTURE study group. https://www.jacionline.org/article/S0091-6749(15)01731-5/fulltext

[26] Inverse association of farm milk consumption with asthma and allergy in rural and suburban populations across Europe. Clinical and Experimental Allergy. 2007; 37(5):661-70. Waser M, Michels KB, Bieli C, Flöistrup H, Pershagen G, von Mutius E, Ege M, Riedler J, Schram-Bijkerk D, Brunekreef B, van Hage M, Lauener R, Braun-Fahrländer C; PARSIFAL study team. https://www.ncbi.nlm.nih.gov/pubmed/17456213

[27] Early-life farm exposures and adult asthma and atopy in the Agricultural Lung Health Study. Journal of Allergy and Clinical Immunology. 2017; 140 (1): 249-56. House JS, Wyss AB, Hoppin JA, Richards M, Long S, Umbach DM, Henneberger PK, Beane Freeman LE, Sandler DP, O’Connell EL, Barker-Cummings C, London SJ. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5429211/

[28] Raw Milk Consumption and Other Early-life Farm Exposures and Adult Pulmonary Function in the Agricultural Lung Health Study. Thorax. 2018; 73(3): 279-82. Wyss AB, House JS, Hoppin JA, Richards M, Hankinson JL, Long S, Henneberger PK, Beane Freeman LE, Sandler DP, O'Connell EL, Cummings CB, Umbach DM, London SJ. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5758444/

[29] Consumption of unprocessed cow's milk protects infants from common respiratory infections. Journal of Allergy and Clinical Immunology. 2015; 135 (1): 56-62. Loss G, Depner M, Ulfman LH, Joost van Neerven RJ, Hose AJ, Genuneit J, Karvonen M, Hyvärinen A, Kaulek V, Roduit C, Weber J, Lauener R, Pfefferle PI, Pekkanen J, Vaarala O, Dalphin JC, Riedler J, Braun-Fahrländer C, von Mutius E, Ege MJ; PASTURE study group. https://www.jacionline.org/article/S0091-6749%2814%2901274-3/fulltext

[30] Which aspects of the farming lifestyle explain the inverse association with childhood allergy? Journal of Allergy and Clinical Immunology. 2006; 117 (6):1374-81. Perkin MR, Strachan DP. https://www.jacionline.org/article/S0091-6749(06)00651-8/fulltext

[31] Surveillance for Foodborne Disease Outbreaks - United States, 2009-2015. US Department of Health & Human Services, Centers for Disease Control and Prevention. https://www.cdc.gov/mmwr/volumes/67/ss/ss6710a1.htm

[32] Two Types of Raw Milk: A Comparison of Pathogen Contamination Rates. British Columbia Herdshare Association. 2019. http://www.bcherdshare.org/education/two-types-of-raw-milk-lab-evidence.pdf

[33] Population Survey Atlas of Exposures, 2006-2007. Foodborne Diseases Active Surveillance Network. US Department of Health & Human Services, Centers for Disease Control and Prevention. https://www.cdc.gov/foodnet/surveys/FNExpAtl03022011.pdf

[34] Raw Milk Reality: Is Raw Milk Dangerous? 2019. Kresser C. https://chriskresser.com/raw-milk-reality-is-raw-milk-dangerous/

[35] Recent Trends in Unpasteurized Fluid Milk Outbreaks, Legalization, and Consumption in the United States. PLOS Currents. 2018; 10. Whitehead J, Lake B. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6140832

Upcoming Raw Milk Risk Management Training

We’re spreading the message far and wide! In early 2020, the Raw Milk Institute (RAWMI) will be presenting in Massachusetts, New York, and Pennsylvania. These presentations will focus on raw milk benefits as well as risk management for the production of safe, low-risk raw milk. The Massachusetts and New York training presentations will be shorter and serve more as an introduction to the topic of low-risk raw milk, whereas the Pennsylvania training presentation will be a half-day workshop that digs deep into the details of how to produce low-risk raw milk.

RAWMI is a non-profit organization, and we’re on a mission to improve the safety and quality of raw milk and raw milk products. Studies have shown that raw milk has superb nutrition, is easier to digest, and is correlated with lower rates of allergies, eczema, and infections. Raw milk helps to build the body’s immune system through numerous beneficial bacteria and enzymes, but raw milk needs to be carefully produced in order to ensure that it is a low-risk food.

Through education, outreach, and research, we’re working towards universal access to safe raw milk for everyone. Come join us for RAWMI training in 2020!

Battle for Butter

Together with the Farm to Consumer Legal Defense Fund, RAWMI is taking the Food and Drug Administration (FDA) to court over legalization of raw butter! Currently, it is illegal to ship or sell raw butter across state lines. The FDA is denying Americans access to raw butter, which is a very powerful anti-inflammatory food, meanwhile we are suffering from more chronic illness! The FDA was petitioned about changing the raw butter laws in 2016; they are 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.

BENEFITS OF BUTTER

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.

BUTTER AND PATHOGENS

The FDA’s position is supposedly based on safety, but the science shows otherwise. Butter's low moisture, low pH levels, high fat content and salt levels inhibit pathogen growth. Safe raw milk makes ultra-safe raw butter with powerful health benefits.

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. Give Americans access to raw butter!

For more information, here are the official Press Release and Filed Complaint from the Farm-to-Consumer Legal Defense Fund:

FTCLDF Press Release

FTCLDF Filed Complaint