A Food Regulator's View of California's Raw Milk Mess, Part 1: Coliform Standard Could Be Revised Upward Next Year, OPDC's Regulatory Challenge

Before I got sidetracked with my Holocaust experience, I had a few things still to report from the Weston A. Price Foundation's Wise Traditions conference. One was a report on a lengthy conversation I had with a well-placed California food regulator about raw milk while in California last week.

I went into the interview expecting a hard-headed ideological attitude, and instead found someone who was more flexible and sensitive than I expected, even if her conclusions were at odds with my own and those of many others who read this blog. She agreed to speak with me on the condition I not reveal her identity on this blog (even whether it really was a "she").

Because she had so many interesting things to say, I am presenting the interview in two parts. In this first part, she assesses the California raw milk situation. In the second, to come sometime in the next few days, she talks more generally about the science around raw milk and disease.

She emphasized that she is not a decision maker, so her opinion is speculative. But she is in a position to observe many of the decision makers, so her predictions carry more weight than many others. The California Department of Food and Agriculture, the author of AB 1735, has been extremely non-communicative about the state's raw milk situation.

Here's what she has to say about California:

The standoff over raw milk in California is likely to be resolved next year via an upward revision in the ten-coliform-per-milliliter standard that is the heart of AB 1735.

"I predict next year there will be a change in the standard," she said. "It will be higher than ten. I don't think the CDFA will oppose it. The CDFA would rather not regulate this one."

Her reasoning? The CDFA never intended to put California's two raw milk producers out of business via AB 1735, despite the view of Organic Pastures' Mark McAfee that its enactment was "a sneak attack."

"I don't think it was a big conspiracy. I think they thought that we'll put it through. They were updating the standards. They wanted to make them all the same (with pasteurized milk). They were not looking to shut raw milk down."

She does acknowledge, though, that, "If that was a regulation that was going to affect big dairies, the CDFA would have been on the phone with the Western Dairy Council."

But, she adds, in a statement that seems almost designed to stir passions, "Mark (McAfee) keeps having problems" with illnesses and pathogens, "whereas Claravale has never had an outbreak."

To the argument that the 2006 outbreak of illnesses linked to Organic Pastures never turned up any E.coli 0157:H7 in his milking cows, she says, "You don't find E.coli in the cows three weeks or three months later. That's why epidemiology works so well. You find (pathogens) at a certain time at a certain place."

She argues that in each of the two California cases of illness attributed to raw milk--Organic Pastures in Sept. 2006 and a herdshare in July 2008--"there is a spike in the coliform counts and the SPC preceding the outbreaks." (The report from the Centers for Disease Control on the 2006 outbreak does note such a spike, but the California Department of Public Health report on the 2008 illnesses makes no such mention.)

Moreover, the tests for pathogen testing, which were a key component of SB 201, are not very reliable, she argues. "It's a lot of money to spend when there's a 50-50 chance you may have a false positive, or negative." Green onions a few years ago gave a false positive, and led to recalls, when it was really something else. "You can be feeling good and putting out a contaminated product."

"She argues that in each of the two California cases of illness attributed to raw milk--Organic Pastures in Sept. 2006 and a herdshare in July 2008--'there is a spike in the coliform counts and the SPC preceding the outbreaks.'"

Given the fact that Mark McAfee posts his standard plate counts on his website, it is pretty easy to determine that "her" statement is patently false. If anything, the results from the September tests show abnormally low bacterial counts:

http://www.organicpastures.com/pdfs/Bac_cts_june_08.pdf

On another subject, I recently realized that it has been quite a while since we've heard about a New York or Pennsylvania farm being forced to recall milk due to potential listeria contamination. Perhaps the PDA and NY Ag & Markets have decided that particular line of harassment hasn't done enough to curb demand and is cooking up some new plan of attack?

Don,
There are 2 entries for Sept 2006. What happened to the other weeks? Still,These SPC counts shown are well under the threshold. My understanding is that SPC counts are only alarming if they jump logs - an increase of 10,000 - 20,000 is a 'spike'; the rest is normal variation?

The say they weren't looking to shut raw milk down. Why then has there been a constant power struggle over the last 7 years? Then she states McAfee" keeps having problems" - no wonder Mark is exasperated with them.

Biased statements like that are exactly what makes me distrustful - there is no scientific perspective about testing, no objective, supportivel treatment of their customers. I'd like to see paid gov't employees get behind farmers, instead of hearing them tell farmers to get behind them.
-Blair

My guess is she was referring to the 2007 campy outbreak, not the 2008. That state report does show an increase in bacteria counts in that case.

I don't know where the state would have gotten a time series in the 2008 herd share case only because the raw dairy products were not on the state's radar until the outbreak.

Raising the coliform limit seems far more reasonable. It would be far less costly than the requirements of SB 201.

On the 2006 data, obviously the state got different numbers in its testing than did the dairy. I wouldn't say that the regulator is lying about the data as much as she is citing the state's data. If memory serves, the state's data shows high counts in the months leading up to the recall. When the state lifted the recall, the dairy was actually still closed because it had not met the 3/5 requirement for the SPC. Just like in these coliform degrades, it had to test its way back into the market. Perhaps Mark can clarify.

I am delighted and excited to hear that you were able to have a material conversation with a real California governmental regulator and actually hear her or his thoughts.

We fought so hard all last year to have these meaningful discussions and CDFA stood us up on every hearing date. We hope that 2009 will bring a change to this lack of open and meaningful communication.

As far as OPDC having on going illness or pathogen problem, I am completely confused as to what is being referred to? Discounting the September 2006 incident, there have been no other alleged illnesses. So. there are no ongoing illnesses at OPDC. As far as pathogens found in our raw milk.show me one that has ever been found??!! Yes the state found some campylobacter in raw cream after eight days of specialized testing in their labsbut the milk that the cream was taken from was negative. There were no illnesses related to this test or the production time period.

If we had open communications with CDFA perhaps this misunderstanding would not continue. It appears to be just as you have statedan attempt to just hurt our consumers and the rising interest in RAW MILK.

If a different coliform standard is being contemplated by CDFA, then why havent Claravale or OPDC been contacted? This seems like just another behind the scenes move that we will not be involved with. Our input matters and it is relevant.

It is also relevant that the facts are clearly stated. The SPC bacteria counts reported by CDFA during 2006 recall were taken from products on the shelves of stores after a week or more of sitting there.it is simply not fair or factual to say that OPDC product that was produced and sold to stores during the 2006 recall had high SPC counts. This is an untrue statement. Also, all products were pathogen free before and after retail sale. In addition, the SPC counts were lower than permitted for pasteurized dairy products during this period. The old raw milk samples taken from stores were beginning to sour. This is a highly biased statement. Please read the CDFA report, it clearly does not show that the product tested was from the dairy, it was old product and some was even expired. This is clearly just another mean spirited and hateful statement made to hurt raw milk in CA.

It also shows the lack of knowledge shown by CDFA. Sour raw milk is not unsafe raw milk. Anyone that knows anything about biology understands this. Rotten Pasteurized milk will sicken anyone. Soured raw milk will not sicken anyone. Most of the third world drinks sour milk and nearly all of Russian population has historically and even today.

The bottom line is this, if there is a CDFA move to change the raw milk coliform standard we are delighted and invite this change. The sad part is that the consumers and producers know not a thing about this potential change. A coliform standard change requires an act of CA legislature to make this happen. In the final assessment, CDFA must become a part of our democratic society and stop thinking and acting like a Kingdom that rules with edict at their leisure.

PHD does not mean KING of California.

We, the consumers and producers of CA raw milk, are ready to work with CDFA.please meet us at the table. We will drop our lawsuit if we can cooperate on a standard that works. The current model requires raw milk producers to shut down every couple months because of non compliance with standards. Claravale and OPDC have both been degraded and shut down several times each during this year. This is not sustainable.

I am truly excited to hear that this he or she regulator at least has expressed the heart felt message of concern that CDFA intent was not to shut down raw milk in CA. That is a very good first step and awesome news!.

We are ready for more steps in this direction and would welcome dialogue and cooperation. The current raw milk lawsuit against CDFA will expose individual CDFA employees for lying to the legislature. Perhaps ( R ) Assemblyman Tom Berryhills request during AB 1604 hearings in 2008, where he said that heads must roll at CDFA for misleading the Assembly Ag committee will become a reality. We can instead work together and fix this challenge prior to this very embarrassing and perhaps criminal exposure occurring next May 2009.

Perhaps, David Gumpert can moderate and be the great negotiator to make this all happen. He has my trust.

All the best,

Mark McAfee
Founder OPDC

(Posted by The Complete Patient after Mark encountered technical problems posting.)

If there was a concerted effort to reduce the availability of raw milk to Californians, and put OP out of business...do you think that anyone in the government would actually acknowledge this? Puleeze, David...while its good that you have actually conversed with a 'food safety' official, one must take these words with a sack full of salt (indeed, personal opinions sometimes conflict with 'official policy'). The actions of the CDFA reveal their true motives, and these words from your 'official' are like flatulence, they sound 'good'....but something still smells bad.

There is no respect for the raw milk consumer...and even less for the raw milk producer. If there was the coliform standard wouldn't have magically appeared out of thin air. The inception of 1735 was fishy at best, and when you combine the subsequent actions of the CDFA, all of these 'good tidings' are a farce.

Big Dairy is Big for a reason. Their tentacles run deep in the state agencies that it must deal with (profits are more secure that way). Raw milk will only get a fair shake if the people, applying excessive pressure to the legislature, call these 'boiled milk commies' on their actions. In the light of the Truth, the vermin scurry away.

Words are meaningless, when the action is contrary...

Well, of course there's problems with things she said, but the fact that she's saying (and thinking) things like this are a good sign. I do think one of the things she said is very telling:

"They were updating the standards. They wanted to make them all the same (with pasteurized milk)."

Isn't the thing all the raw milk producers and consumers have been saying is that Raw Milk is a completely different type of product from pasteurized? From what was said (and I'm being generous) it sounds like the CDFA was just attempting to standardize things. I don't like conspiracy theories and I'd rather believe that something was the result of human nature than the result of some concentrated and malicious effort.

Then again, I'm young and idealistic.

Since I don't (yet) have a vested stake in this issue, being neither producer nor consumer, I'm trying to look at what everyone is saying and find a middle ground that makes the most sense.

I don't really believe in any kind of massive conspiracy to deny people their freedom of choice any more than I believe raw milk is toxic and will kill anyone who drinks it.

I find it far more believable that any concentrated effort to regulate raw milk into oblivion is a result of a deeply-seated cultural fear of bacterias. I also believe that raw milk can be quite dangerous when handled and produced improperly. It's a middle ground. People should be able to eat and drink the foods they want, but they should also be able to know what they're getting isn't going to kill them or their children. Extreme examples of this come from the swill dairies of the last century.

I think, another aspect of the struggle comes from conflicting paradigms. It's a matter of:

If it is not allowed, it's forbidden.

vs.

If it is not forbidden, it's allowed.

"I also believe that raw milk can be quite dangerous when handled and produced improperly. "

Alexis, Isn't this true of all food?

To clarify, I was thinking of the dairy closure after the recall. I looked it up and it wasnt related to the SPC, so I was wrong. Sorry Mark. The dairy products were kept from the shelves because of the high somatic cell counts:

http://www.cdfa.ca.gov/egov/Press_Releases/Press_Release.asp?PRnum=06-058

That was a really bad summer for dairy cows. It was bad for me too and I dont have to sit with a bunch of other cows all day. So many cows in the valley died they ran out of the usual means to dispose of them. Milk production was down something like 25% just after the July heat wave. It probably isnt a big surprise that the cows were stressed and the milk had a high somatic cell count. Some folks say a high count increases the risk of pathogens which is why I assume the state measures it, but I certainly dont know for sure. (I'm not sure whether to laugh or cry, by the way, about brushing off 1M+ fecal coliform counts as bureaucratic fear over soured milk.)

I expect the reference to multiple outbreaks also has to do with the 2007 campy case that I referred to above, this was OP, not the herd share. I am surprised that Mark hasnt heard about this case. To create that report, scientists would have descended on the dairy in Dec of 07 to do testing. They did find a common strain in the stool of a sick person and in cow(s) at the dairy. Bill Marler posted the report some months ago:

http://www.marlerblog.com/Cluster%20of%20Campylobacter%20infections(1).pdf

On another point, the issue of big dairy getting a phone call about proposed legislation: of course they would because the dairy organizations make a point of having friends in government. Friends will call you if something is coming down the pike that affects you. If you have no friends there, who is going to call? No one. They dont know you or they dont like you. They have no obligation to call. Its really not a big versus small issue. Its an issue of how people are playing the game. Big may certainly help, but big could be antagonistic as well and, thereby, be less effective.

"People should be able to eat and drink the foods they want, but they should also be able to know what they're getting isn't going to kill them or their children."

I agree, people should be able to consume the foods of thier choosing. As for the 2nd part of your statement, no food has any guarantees for safety. Recent history proves that, to include the pharmacuticals, vaccs, etc.

The movie, Super Size Me, showed what the poisons fast foods inject into people can do to the human body; http://en.wikipedia.org/wiki/Super_Size_Me yet, I did not hear of any govt entities shutting down fast foods or forcing changes. Granted, I would assume the average person doesn't consume 5000 cal per day; but over a period of time, wouldn't the consumed toxins be the same in the end? If a chemical doesn't affect one person, but affects another, should that chemical be outlawed?

Sylvia & Elizabeth, I agree completely!

There's a measure of risk in eating any kind of food or taking any drug. I'm meerly saying that there should at least be enough regulation on Raw Milk to keep a disaster like the swill dairies from happening again. I have every confidence that milk from cows who are pasture-fed and well-cared for is healthy and safe! If it wasn't we wouldn't still be drinking milk after thousands of years.

A large part of being able to be confident about food safety is self-education too. I'm astonished at how many people are, and the level to which people are divorced from the source of their food. You don't have to be on the farm helping to produce the tomatoes or raise the cows, but a little knowledge about how these things are done can go a long way.

I knew someone in college who asked me this question in all seriousness: "So... beef, is that like, pork or pig?" I just blinked at him in confusion.

Thing is I don't know how to fix this system of big agribusiness and marketing that supports unhealthy lifestyles. All I can think of is that nothing but good things can come from supporting small-scale producers and whole/natural foods. I have no idea where to start taking down a giant, so I'd rather concentrate my efforts and my ideas on supporting the Davids of food production.

Oh! I just realized something too. That attitude I've got I've been using to re-forumlate my diet and it's working amazingly well. I don't tell myself that I can't have something. I read ingredients of course and I'll know if something is bad for me, but I don't tell myself I can't have it. What I do, however, is make sure that part of every meal is healthy and whole food. As a result I eat less of the unhealthy stuff and I don't feel deprived. Interesting thing too is a healthy diet supports itself. I can't stomach most sodas and potato chips anymore, too salty and sweet for me.

So, to my mind, if concentrating on including and encouraging the good and healthy is working so well for me to keep me away from unhealthy things, how far could such an attitude go towards changing the face of agriculture?

" (I'm not sure whether to laugh or cry, by the way, about brushing off 1M+ fecal coliform counts as bureaucratic fear over soured milk.)"

Now I'm confused. Sorry if this has been covered before. Is the coliform test performed by California able to distinguish between fecal bacteria and bacteria that orginates in the mammary glands?

Elizabeth,
This is a good question. I don't know the answer, but I did want to comment on the use of the term "coliform". The semantics and sources of "coliform" are often confused. I know dairy producers who insist that all coliforms are are fecal coliforms, and others insist that all coliforms are pathogens. Not so.

I think 'coliform' is generally thought of as bad bacteria by the general public (even though technically they should specify which kind of coliform), but "Total Coliform" "fecal coliform" and "e.coli coliform" (or other specific pathogens) are used as more technically accurate terms by lab people. If you watched the video about the testimony during the CA hearings, you heard Dr. Beals say that it's called beneficial bacteria when it's in the milk, and 'coliforms' when that milk is in a test vial.

I found a distinction here, but it still leaves room for confusion:

http://www.doh.wa.gov/ehp/dw/programs/coliform.htm

(it talks about fecal e.coli in water but e. coli strains are also found in mammary samples, ground samples, and fecal samples. And some of these fecal strains are good guys, especially E. coli strains, which compete w/e.coli 0157:H7....google e.coli nissle 1917, or e.coli J5, for example. -Blair )

There are three different groups of coliform bacteria; each has a different level of risk.

Total coliform, fecal coliform, and E. coli

"Total coliform, fecal coliform, and E. coli are all indicators of drinking water quality. The total coliform group is a large collection of different kinds of bacteria. Fecal coliforms are types of total coliform that mostly exist in feces. E. coli is a sub-group of fecal coliform. When a water sample is sent to a lab, it is tested for total coliform. If total coliform is present, the sample will also be tested for either fecal coliform or E. coli, depending on the lab testing method."

Total coliform bacteria are commonly found in the environment (e.g., soil or vegetation) and are generally harmless. If only total coliform bacteria are detected in drinking water, the source is probably environmental. Fecal contamination is not likely. However, if environmental contamination can enter the system, there may also be a way for pathogens to enter the system. Therefore, it is important to find the source and resolve the problem."

So whenever anyone says 'coliform' ask them what they are talking about. Including the labs, where 'fecal coliform' is often referred to when testing water, but it may actually be a total coliform test, or a pathogen test.

This post is more a question than an answer - but I think most dairies do a total coliform count AND a standard plate count, and if it is high, they have to test for specific pathogens to understand if it's the good guys or the bad guys.

-Blair

Elizabeth -- The California legislation does not. In my comment I was referring to data collected from Dairy A products during the outbreak. Some had very high fecal coliform counts (and I mean fecal, not total, though the total count was obviously high too).

Blair, Thanks. So if I tested the pasteurized yogurt in my fridge, I would get a high total coliform count but (presumably) a zero fecal coliform count?

Am I correct in assuming the standard plate count gives the fecal coliform count, and the somatic cell count gives the total coliform count?

Amanda, Are you saying that fecal coliforms were found in Mark's milk that had soured on the store shelves before testing?

Elizabeth

Elizabeth,

The report of the 2006 outbreak described coliform counts in some of the products. It also mentioned that a couple (a few?) of the samples tested had very high levels of fecal coliforms. One sample had 1.4M. It is not clear from the report which products were taken from the shelves and which (if any) from the dairy. The CDC report says that some were taken from the dairy itself (thus not likely spoiled, though it doesn't give counts for these separately).

On the more general point I mentioned earlier about making some "friends" in government to stay in the know, obviously "big dairy" or any big industry is going to have a much more complex strategy that likely includes things like fear and intimidation. I don't want to come off as a big industry apologist. My point really is that successful industries have political strategies. Raw milk may have a strategy but I would play it differently.

Amanda

Amanda, Yes, I am nit picking about one detail in your note. High fecal coliforms in a milk sample is a pretty damning accusation. If the state found this in a few of Marks samples, I would want to know more before throwing this in his face. What exactly was sampled, and where? Specifically, was it the raw cream he outsourced? If not, then given everything I have read about the cleanliness of Mark's operation, i would need repeat findings, independently verified, before believing it was actually true (soured milk or not).

Blair, I think I have figured it out. There are both coliform bacteria and non-coliform bacteria. The pathenogenic bacteria are also coliform bacteria, but not all coliform bacteria are pathenogenic. The non-coliform bacteria are non-pathenogenic. I don't know what is in yogurt, either coliform or non-coliform, or both, but whatever it is, it is obviously non-pathenogenic.

Enough for me, thanks for your help.

Elizabeth,

I am simply citing the 2006 report: I have mentioned it here before and no one has seemed concerned at all about it. I am also expressing dismay that the results would be written off as "spoilage." I can't find the report online, so I've uploaded it here (see the top of page 6):

http://tinyurl.com/5qcerv

Creating a fecal coliform distribution was not the point of the report so it will not satisfy your need to see repeated testing for it.

I'm glad we can agree this issue is a big deal. It's not the outsourced cream, but there was outsourced product in that recall period. Whether the high counts came from outsourced product may also be impossible to know even for the dairy involved unless all of a product class was outsourced at that time. In any case, as a consumer of the product mix from that period, I certainly would expect that any outsourced product be held to the same standard of production and safety that we are promised with the whole product line.

Keep in mind too that this discussion is all in the context of Deep Throat's comments about high coliform counts and the response that the high counts were due to spoilage. There were something like fifty bottles tested in the recall and the distribution for them is not given in the report, though the report does describe the distribution somewhat. The distribution would be interesting data. Perhaps Dairy A has it and can post it. However, fifty samples still wouldn't be enough to create some sort of "Sep 2006 coliform distribution" (or fecal coliform distribution), so I don't think you'll ever get the data you are seeking.

Amanda

The California Department of Health Services report states: Colostrum and chocolate colostrum had FECAL coliform counts ranging from 320,000-140,000,000 MPN/g.

Maybe Mark McAfee can clarify if the colostrum came from his cows or was he still outsourcing?

cp

Amanda,

The plate counts for the 2007 outbreak are on page 10 of this report.

http://tinyurl.com/Campylobacter

No doubt, everyone is aware that "bacterial indicator" tests such as fecal coliforms are important in water quality (standards are set for recreational water, swimming pools, well water, etc.). Although pathogens are the concern, pathogen testing is not a major component because it is laborious, expensive, and unreliable. This link has some amusing examples of how to interpret fecal coliform tests:

http://www.oasisdesign.net/water/quality/coliform.htm

Amanda, I don't always have time to read the comments on this blog, though I usually manage to read all of David's posts. So I don't know who Deep Throat is or what he/she has posted here. I assume Dairy A is OP? I also probably missed your previous postings about the fecal coliforms.

I could use a point of reference. What would the fecal coliform count have been on fresh milk from the swill dairies? What would it be from a large conventional confinement dairy today? And why would it go up in raw milk as it sours - don't the good bacteria outcompete the bad?

I could also use some clarification on the outsourcing at OP. My understanding is that only cream was outsourced. Are you claiming that liquid milk was outsourced as well?

Is the coliform number that the dairies in California are now held to (10) for total coliforms or for fecal coliforms?

I tell people who drink conventional pasteurized milk that they are likely drinking a small amount of sanitized manure, and that clean raw milk contains no manure, so it does not need to be sanitized. I will need to change this statement if fecal colifoms, in however small a number, are routinely found in pastured raw milk.

Elizabeth,

You have missed a lot of information if you only read Davids posts and not all of the comments. Months ago, Amanda posted an article on her blog she had written about her discovery that Mark McAfee had outsourced colostrum from an organic dairy (for pasteurization) that ended up losing its organic dairy status. The colostrum was being outsourced during the same time frame as the alleged 2006 E.coli 0157:H7 OP raw milk.outbreak.

This means that Mark McAfee bottled colostrum at his dairy, which he purchased from another dairy, and sold it with the OP label as if the colostrum came from his cows. Maybe this is why they never found the matching blueprint of E.coli 0157:H7 at the OP dairy. At the time CDFA was collecting samples from OP farm (October and November of 2006), it would have helped if they knew that Mark had outsourced colostrum. It would have given them the opportunity to do a thorough investigation of the other dairy also.

In the 2nd two weeks of October 2006, when test samples were done on OP products, fecal coliform was found in OP colostrum (or should I say colostrum with the OP label). In other words, poop was in the raw colostrum. E.coli 0157:H7 contamination results when cow poop is in the product.

To summarize, maybe this how and why 6 children in California became ill from E.coli 0157:H7 after consuming OP raw dairy products.

cp

Elizabeth

Your question, Am I correct in assuming the standard plate count gives the fecal coliform count, and the somatic cell count gives the total coliform count? is incorrect.

The Plate Loop Count or standaerd plate count is a measurement of the total number of bacteria present in the milk and is non specific to the type of bacteria and is irrelevant with respect to the safety of the product.
High counts are usually due to improper cleaning as well as inadequate cooling. The plate loop count increases exponentially and under the right conditions bacteria in milk will double every thirty minutes. This is perfectly natural and an indication of milks self preserving qualities.

Coliform Mastitis (E. Coli, Klebsiella sp., Pseudomonas sp., Serratia sp.) is described as an environmental bacterial infection of the udder. Escherichia coli is the pathogen primarily responsible for coliform mastitis.

Antibiotic treatment is ineffective and does not shorten the duration of infection nor lessen the clinical signs. Its use more then likely acerbates the problem in that it destroys much of the natural flora in the udder designed to keep these environmental pathogens in check.

Environmental bacterial infections are highest in what is considered well managed herds. ie. In herds with low somatic cell counts (SCC), a.k.a. Leucocyte counts or white blood cell counts, and where antibiotics are incorporated into herd mastitis management protocol in the form of dry cow treatment.

Somatic cell counts are used as a tool to manage mastitis infection and are simply an indicator of non specific organism whose presence appears to aggravate and cause udder inflammation. SCCs reliability is dependent on the inflammation factor and is therefore unreliable at detecting organisms in a healthy udder.

Ken Conrad

Elizabeth -- CP covered it pretty well. You can find discussions of outsourcing in April (after Apr 15 I think) of 2008 here on this blog.

Thanks Ken, It seems that fecal coliform testing would be useful at a raw milk dairy.

Thanks Amanda and CP on the clarification on outsourcing at OP. I thought it was cream, sounds like it was colostrum. At any rate, a high fecal coliform count on an outsourced product certainly makes more sense than on an OP product. There has been frequent mention here of the hot difficult conditions for CA cows in the summer of 2006. I can see why this would stress the animals, but I cannot see why this would raise the fecal coliform count. The outsourcing seems to be the problem there. However, unless liquid milk was outsourced, it does not explain the illnesses. It is a real shame that the state never got a chance to test the outsourced dairy.

" It is a real shame that the state never got a chance to test the outsourced dairy. "

True, but the following year the state went back, and found pathogens in the dairy cattle feces.

http://tinyurl.com/Campylobacter

What do you think about that?

A study just came out on raw colostrum :

http://www.ncbi.nlm.nih.gov/pubmed/18991543?ordinalpos=1&itool=EntrezSystem2.PEntrez.Pubmed.Pubmed_ResultsPanel.Pubmed_DefaultReportPanel.Pubmed_RVDocSum

Foodborne Pathog Dis. 2008 Nov 9. [Epub ahead of print] Links
A Survey of Bacteriological Quality and the Occurrence of Salmonella in Raw Bovine Colostrum.
Houser BA, Donaldson SC, Kehoe SI, Heinrichs AJ, Jayarao BM.

Abstract In recent years, bovine colostrum has gained popularity as a human food because it is an excellent source of bioactive proteins, which have been claimed to inhibit viral and bacterial pathogens, improve gastrointestinal health, and enhance body condition. A study was conducted to determine bacteriological quality and occurrence of Salmonella in colostrum collected from dairy herds (n = 55) in Pennsylvania. Colostrum samples were analyzed for standard plate count, preliminary incubation count, laboratory pasteurization count, Staphylococcus aureus, Streptococcus agalactiae, coagulase negative staphylococci, streptococci, coliforms, and non-coliforms. A standardized polymerase chain reaction assay was used for detection of Salmonella in colostrum. Salmonella were detected in 8 of 55 (15%) of colostrum samples. Streptococcus agalactiae (1000 colony-forming units [CFU]/mL) was detected in one colostrum sample. The mean standard plate count (977,539 CFU/mL), preliminary incubation count (12,094,755 CFU/mL), laboratory pasteurization count (615 CFU/mL), Staphylococcus aureus (306 CFU/mL), coagulase negative staphylococci (164,963 CFU/mL), streptococci (256,722 CFU/mL), coliforms (323,372 CFU/mL), and non-coliforms (111,544 CFU/mL) counts in colostrum were considerably higher than raw bulk tank milk counts reported previously from Pennsylvania. Analysis revealed that farm size did not influence the bacteriological quality of colostrum. Collection, handling, and storage of colostrum need to be addressed to improve bacteriological quality of colostrum intended not only for feeding calves but also for human consumption

Elizabeth,

The outsourcing could have been the cause of the 6 children becoming ill in 2006 after consuming OP raw milk products. The outsourced colostrum was bottled at OPDC. That means the outsourced colostrum was run through OPDC bottling machines and then these same machines are used later for OPDC milk. It only takes a very minute amount (as little as 10) of deadly E.coli 0157:H7 bacteria to make someone become ill. 250,000 can fit on the head of a pin.

The children who became ill consumed raw whole and skim milk as well as colostrum.

Think how you would feel Elizabeth if your child became ill with E.coli 0157:H7 after drinking raw milk and then you discovered your farmer was deceitful and brought in product from another dairy with out telling you about it.

Trust your farmer is a huge part of the raw milk movements mantra to assure safe, clean raw milk. Relying on integrity alone for safe raw milk appears to be risky.

cp