Out of the Loop: Proposed Raw Milk Standards Are Nearly Ready for Review, Says Tim Wightman--Beyond "Food Inc."

?"It's all about risk and it's all about letting adults take risks and it's all about us as a society being willing to do the things that made this country great. I'm worried about us." Gov. Ed Rendell of Pennsylvania expressing his upset on NBC News last evening about the National Football League's first-ever decision to postpone Sunday night's football game in Philadelphia because of bad weather.

"You've touched a nerve nationally." Brian Williams, the NBC News anchor, in response.

Tim Wightman of the Farm-to-Consumer FoundationGov. Rendell might well have been speaking about any number of unnerving trends in our society, including the government's crackdown on raw milk and other nutrient-dense foods (though the fact that it was professional football, of course, made it a much bigger deal than food). All of which relates to the ongoing discussion here about standards for raw milk, and what I see as the need to keep sight of the big picture.

I like Maurice Kaehler's use of the Latin derivative of conspiracy, "to breathe together." It captures the overall spirit and sentiment in the many thoughtful comments following my previous couple of posts.

Yes, there is much fear of government takeover of standards, or just the implicit invitation to government involvement that even voluntary standards suggest. Rightfully so. Sadly, our government agencies have become the enemy of the people they govern, but they must be fought intelligently. Anyone who's read my book, The Raw Milk Revolution: Behind America's Emerging Battle Over Food Rights, and has read this blog for a while, knows I'm the last person to want more government involvement in raw dairy, and in other areas of sustainable agriculture. Quite the opposite.

I am encouraging the consideration of standards for one basic reason: to improve product quality and so reduce the number of illnesses ascribed to raw milk, thereby giving government agencies less reason to think about raw dairy. Simple as that. Sure, there will continue to be unreasonable enforcement--after all, it's part of the national health (illness?) agenda--but fewer outbreaks and illnesses will almost certainly cool official attention to raw milk, allowing demand to continue growing, with raw milk producers and consumers reaping the benefits. Moreover, when the busy bodies do their thing, it will be that much easier to build public support and bring crowds to agency hearings and court rooms demonstrating consumer sentiment.

All by way of returning to the subject of raw milk standards, and the thickening plot about what might be in the wings. There has been a good deal of confusion here, and I have been part of the confusion, by suggesting there hasn't been a sustained and organized effort to develop raw milk standards. There has been--it's just that the people suspected here as being part of it--Bill Anderson, Mark McAfee, and myself--have been on the outside, and we haven't even been looking in.

But Tim Wightman, head of the Farm-to-Consumer Foundation, has indeed been very hard at work developing proposed standards. He's been quietly working for well over a year with a committee including Steve Bemis, a Michigan lawyer and a member of the Farm-to-Consumer Legal Defense Fund; Blair McMorran, executive director of the Raw Milk Association of Colorado; and Meg Cattell, owner of a raw dairy, a member of the board of the Raw Milk Association of Colorado, and a veterinarian.

I had heard discussion about the effort months ago, from a couple of the committee members, but was told it was hush-hush until the effort was further along, and so I didn't think much about it. But then I had a conversation yesterday with Tim Wightman, as a followup to the intense discussion occurring on this blog, and learned that his group may well be within days or weeks of disclosing an initial draft of proposed standards.

My first reaction was irritation. There has been lots of discussion about raw milk standards here and at various food conferences over the last year, with part of the lament being that there's been seemingly no follow-through and leadership. Why the heck no openness on the well organized Wightman committee effort? I'll return to that question, because there are some larger questions deserving of attention.

First off, what will the Wightman committee's standards consist of? He didn't want to get overly detailed, since the committee hasn't yet reviewed a complete draft, nor has it even decided whether to make public an early draft, or wait until the standards are further along.

He suggested the standards are holistic and focused heavily on improving soil and animal health as the primary means of improving product quality. "No one in the country has drunk their best glass of milk yet," he said. "Most farms need improvement. There's this quasi-kosher understanding that everything is fine."

The proposed standards are driven by the notion that "except for a very few places, and very few individuals, we have lost the art and wisdom of dairy farming, and must now chart our path to regain that wisdom while producing the best possible and safe products as we move forward."

He said the proposed standards will "set levels of known safety that can be met by any number of husbandry practices, but, the principals for creating balanced soil, nutrient dense forage, and nutrient dense food are woven within these standards and is designed to eliminate the guess work of what is safe and nutrient dense, while evaluating soil and herd health programs for the effective production of excellent, safe, raw drinking milk."

He suggested the standards will run counter to much of the popular thinking about agriculture currently popular in the foodie movement. "They read Michael Pollan and see 'Food Inc.' and they think everything is all right" in sustainable agriculture. "They think if we feed our cows grass, we will be fine. We have to rebuild the soil and animal health. If raw milk illnesses keep cropping up, the state will do something about it, and it won't be pretty."

How will standards be adopted and implemented? Wightman said he sees a two-year review period before the standards are finalized. And once finalized, he anticipates they will be voluntary.

But he noted that "voluntary" is subjective, and that the standards could be used in various ways as an incentive to encourage dairy farmer compliance. For example, the Farm-to-Consumer Legal Defense Fund might use the standards "to audit farms that ask for representation" in legal cases. "If you are not following the standards, it may not bode well for representation."

Anyway, why all the hush-hush? Wightman says the standard-setting hasn't been as hush hush as it seems. He said Canadian farmer Michael Schmidt has been privy to what's been going on. But Sally Fallon, head of the Weston A. Price Foundation, and closely aligned with the Farm-to-Consumer Foundation and Legal Defense Fund, has not seen anything as yet, he said. My sense is that the quiet approach is Tim Wightman's style, to do the work without a lot of distractions, as in farmers and consumers telling him regularly what they think.

My inclination, as I stated at the start, is to try to stay focused on the big picture. The food rights movement is highly fragmented, and it is fighting powerful enemies, not to mention uneducated legislators and judges. Initiatives like the development of raw milk standards won't necessarily happen as elegantly as many people might like. What's important, as much as possible, is that proponents of raw milk and food rights stay focused on the task at hand. The national mood is foul, in large measure over the economy, but also because of a major shift over the last half century away from a respect for individual rights and responsibilities, and toward institutional control, as Gov. Randell identified in objecting to the postponing of a football game.

Yes, obviously we couldn't talk about National Standards too early or there would be a backlash of the magnitude we've seen this past week and ruin the whole plan.


You by any chance didn't ask Wightman why the Standards were being crafted to follow Codex and S510, did you?

No matter how you want to spin this, no matter how many times you say these Standards are to ensure a safe raw milk supply, this is the million dollar question, and one no one has bothered to answer yet.

Still waiting...unless Tim would like to grace us with an answer?

The National Standards as they are known by its working title has not been nor will be written to fit within Codex or s510 or whatever its known as now or any other document or statute.
Codex as it relates to milk production was reviewed as well as 8 other extensive documents from around the world to give an idea of what is known and applied to raw milk production destined for human consumption.
The Nationals Standards will be a stand alone document, with result orientated standards.
It is my goal to have mutiple layers of education for consumers and producers to support these standards as we move foward.
Happy New year to all.
Tim wightman

Interesting. With FTCLDF taking care of our "new rules" on Raw Milk production and FARFA on the new "Advisory Committee" on Animal Health, surely us "small" guys will be so much better represented.

"Agriculture Secretary Tom Vilsack today announced the members of the Secretarys Advisory Committee on Animal Health. The following individuals will serve two-year terms on the committee:"

"Ms. Judith McGeary, a sustainable farmer and attorney on agricultural law from Texas"


I think I'll just take my chances by not participating in any of these "secret communications" to establish rules for my farm here in Indiana.

Before anyone assumes anything...I strongly suggest that everyone takes several chill pills and waits to see the results of Tims hard work. I am sure that "results oriented standards" based on national and international research will give some excellent guidance. Guidance we all need desparately.

Patience is something that all of us need to embrace...then when the standards do come out think about them long and hard prior to passing any judgement or making any comments.

When babies are born there is lots of crying, groaning and yelling before the hugging and kissing and smiling.


I wonder about the standards...and the testing that will be required to meet them. Will they be on a per farm basis, per gallon, per acre?

Having a standard is nice, but measuring is key.

Milk testing...soil testing....water testing. These things cost money...

How will these standards be implemented to put the 10 cow dairy on level with the 40 cow dairy...or the 500 cow dairy? Or is this even a consideration....

Patience.....time will tell everything. The standards will only be good if they can be embraced by all that are serious about this subject. Trust me...Tim is smart and he has listened to many people for a loing time before considering the work he is doing.

Trust you Mark?

Aren't you the person who said he didn't know anything about the e-mail when your name was clearly on it? Trust you? I don't think so.

This whole situation is a fraud. You and your friends lied to us from the beginning.

You're right about one thing, though, time will tell everything!!


Please enlighten me...I have no idea what email you are talking about. I exchange emails often with many people, but I assure you that I have not been made part of the development of any proposed national standards. I have been asked for my thoughts many times and have made my suggestions available....but I am not on the inside of this project. Hell...I even created a website to show the standards I follow...no secrets here.


Please show the email to me that has included in it with any details of proposed national standards. I am as interested in seeing what Tim has done as anyone. I have no idea what it looks like.

What soured your raw milk and got your goose in a gander.....whats up??


Dear blog readers:

Tim Wightman is a secret member of the knights templar. He is part of a globalist conspiracy seeking to impose a communist world order on us using codex.

Do not read his "standards." Do not even attempt to obtain a copy of this dangerous document. It will taint your mind with ideas about "quality" and "safety" that infringe upon my god-given constitutional right to be as self-centered and small-minded as I want.


Is this the same Mr. Wrightman who was Mr. Hartmanns expert witness? Here is what the judge thought of that:

Michael Hartmann presented little credible evidence to contradict the State's case. The opinions of his expert, Mr. Wightman, regarding the condition of the Hartmann dairy barn and dairy plant is accorded little weight. His opinion that someone possibly "could produce "quality milk under those conditions was revealed to be baseless because, among other things, he did not observe the conditions present in the dairy barn and dairy plant on May 26, 2010, or June 16, 2010; he did not apply his own standards to the operation; and he did not satisfactorily reconcile farm conditions with his published statements that the "milking area should be kept clean" and that milking and holding areas should be "scrupulously free of manure."

Here is full order:


Any standards worth having are worth being done in the open. CA and WA have standards and there still have been outbreaks and recalls. My strong suspicion is that a farmer with a cow or goat or two selling to his or her neighbors (and drinking it too) needs no standards and needs no government involvement in any way. Standards are necessary when a product goes commercial and off the farm for sale. As someone wisely said - follow the money.

Bill Anderson, excellent!!

Bill Marler, Hartmann has issues. Standards are needed if raw milk is to be respected and protected. Tim was placed into an impossible position

Bill Marler.

The FAA has the model. Ultralights need little regulation. Boeing 757's need much.

I agree with you,.... size matters.


Hey all, and a Merry Christmas to ya - I know its been ages since I've been here.

Interesting discussion - as I for one have been "out of the loop" for months only to come back and find that the more things change, the more they stay the same...

We are politicians - most of us, anyway. Who has actually read the bill? Who looks at who is listed in the "To" field on emails? Nope - we have our "experts" to turn to - just like the legislators we all pitch a B.... about - and then whine when people start getting sued.

When I was in massage school, everybody wanted to develop the AMTA to "legitimize" therapeutic massage - and so we could be "respected" IE: be like the AMA for massage therapists. There were several of us that said if we created such an organization it would come to rule our lives in the same way as the AMA did medical personnel.

Now, we have state licensing, "educational requirements," fees, dues, memberships, coop advertising - and our median income for an hour's work has dropped from close to $100 down to less than $10. Go figure. FAR less income, tons of useless money-grubbing/control-napping "regulations" and NO freedom. Yup - that's a deal alright!

The way to legitimize something is not to pay someone else fees and memberships so you can go from being the slave of one organization to being indentured to another. The way to legitimize something is to PROVE YOUR POINT and let them all hang. Its just easier to schlep cash to someone else rather than do the work one's self.

Farmers/ranchers - and I don't care if you raise corn, cows or cabbage - have been through this happy horse S... before, and now are lucky to bring in enough money to eat and keep the farm. And still people pay others to beg for more of the same. Even worse, they BEG to pay them to get screwed!!

This, and a couple enlightening "new developments" mentioned (especially after 6+ years of constant harping for people to follow the cash instead of the glitter) is just one more of those "things that make you say "Hmmmm....""

No surprises. Just hmmmm........

The shepherd may guard the ewes but culls the lambs and pays [for] the ram...

Have a most excellent New Year - crawling back under my rock now -


PS - let me know if we get kissed this time

Barney, first of all, if these people were going to do something in secret they would not be sending emails to each other thru this blog that you would see. Secondly, re: Scott Trutmann not pushing his standards ideas, I can assure you there is no one that could make Scott shut up unless of course maybe his wife?!?. Thirdly, I do not consider any of us struggling farmers just because we provide raw milk which is basically what you said in a post under the previous blog entry. The lobbyist money for WI has come from our members and some of the 800 people that showed up at the public hearings.

Lastly, what do you care what standards these people come up with. You and Lola have made it clear that you are not under the jurisdiction of DATCP, the courts or any other authority. Surely you are not going to willingly participate in or follow any standards any group comes up with anyway. If I was a conspirasy theorist I would say you are both uncover FDA attempting to spread confusion to divide and conquer the raw milk movement!!

Bill, and what is commercial?? 50 gallons a week, 100 gallons a week, 500 gallons a week. My guess is, it is any amount that allows a farmer to make a decent living and be properly compensated for his efforts. When I follow the money it leads strait to the dairy industry and the regulators it manipulates and controls.

I'll push my luck and see if David will refer to me on his next post : )

The root of "entrepreneur" is French = "one who undertakes (some task)"

The root of "enterprise" = "to undertake, grasp, take hold"

Wikipedia definition for entrepreneur - "An entrepreneur is a person who has possession of a new enterprise, venture or idea and is accountable for the inherent risks and the outcome."


The only thing that limits man or women is the tyranny of a dull mind.

"In the province of the mind what is believed to be true is true or becomes true within limits to be learned through experiment or experience. In the province of the mind, there are no limits."
- J. Lilly

Let's get on with it!!!!!

Bill Marler,
I'm surprised you would castigate expert witnesses just because you or a judge don't agree with the testimony. For the record, one of your expert witnesses in the case by families suing Organic Pastures Dairy Co. a couple years back had this to say about raw milk:
Its pretty much the same story over and over, there is no mystery in this process. Raw milk is virtually always contaminated with bovine feces... "Of course, if that were the case, hundreds of thousands of people would become ill every day. There were other questionable statements as well, as I discussed in a blog post
But the case was settled, so we never got to hear what a judge might have had to say.

Tim Wightman made the expert judgment that even though the Hartmann Farm didn't live up to the standards articulated in his handbook and video, it still could produce safe raw milk. That was his opinion.The judge in the case didn't appear open to anything Hartmann's side had to say.

I'm curious, this effort by the raw milk community to organize and show it cares about quality got you a little worried, Bill?



Commercial law:
"A broad concept that describes the Substantive Law that governs transactions between business entities".

Am I a "business entity"?Are the people who get milk from me "business entities"?

If we choose to be we are .We are free to deal with each other as people without referring to commercial law.
In the world there are two economies.One ,the official economy, is the economic activity that takes place between "entities" or legal persons.The other is the unofficial economy.It is economic activity that takes place between people.In many countries the unofficial economy dwarfs the official economy.The official economy is a colonial economy.It is always trying to lay claim to pieces of the unofficial economy.


"Christie calls on us citizens to decolonize our minds, to think independently, to question everything, to defy the message that we have been defeated:

The lies we are told are not the truth we feel. By being alone and resigned and helpless, ...spending the rest of your life trying to calibrate and get along, sedating your rage or letting it blast forth at the wrong targets -- certain interests are served.

They are the interests of The Way Things Are. There is a reason why we are taught to be alone, resigned and helpless. But we're not. Somewhere, we still know that."

We are free to participate in the official economy,call what we do a business,fight for the right to make a comfortable living and admit that it is really all about money.Or we can throw out the colonial ideas we have and and work together as people to make the world be the way we wish it to be.

People want to be able to eat the food they choose to eat,but to be practical,they only can choose the food they eat from that which is available.The colonial economy likes to give us the illusion of choice so we will be happy.If we work within the colonial economy,all we will get is the illusion of choice.If we stop working for money,but rather work for each other in the unofficial economy,we can actually have access to the kind of food we choose to eat.

David - I am not sure what you mean by "I'm curious, this effort by the raw milk community to organize and show it cares about quality got you a little worried, Bill?" Worried about what?

I think it is fantastic that there is that discussion, I just think it should be in the open.

"I think it is fantastic that there is that discussion, I just think it should be in the open."

Too bad the DATCP and FDA regulators don't have their discussions in the open, hey Bill?

I wonder what goes on behind closed doors in some of those government agencies. We certainly know from hints that were dropped last year that pressure from the Wisconsin dairy industry played a major role in the crackdown on raw milk in late 2009. One is left to wonder what kind of communications took place between the leaders of industry and government regulators leading up to that crackdown.


Follow blindly, and question nothing, and see where that takes you !!

This post just further validates my concern that 'voluntary' standards will be made mandatory through the FTCLDF's suits and advocacy. And it pretty much sounds like a legal certainty in light of the Hartman case.

But on the other hand they got themselves into this. Tim's previous writings are more process oriented than results oriented. No farm is perfect and the legal process doesn't have flexibility for lapses in production standards, even if raw milk protective factors do. But they can avoid further legal embarrassments if their standards are truly results oriented and explicitly give room for variety in production standards and environment, especially those the state and conventional thought deems inappropriate.

The highest quality milk I've ever drank was created by explicitly NOT following the conventional methods of milk production, including some that Tim has advocated.

One wonders, will there be room for the miguel's and milk farmer's of the industry in the FTCLDF? Or will they just morph into another AMA? It is quite possible that the result of all this may be the increased availability of raw milk, but at the cost of farmer livelihoods and freedom. Like I've said before, the state's primary concern is control and power. They can and will make peace with raw milk should the farmers capitulate to slavery.

Liberty or Death.

Bill Anderson

Max Kane was able to get some emails through FOIA between DATCP and FDA that were VERY revealing.

Mark - I LOVED this comment of yours:
"Bill Marler will start to pick on CAFO's and there will be peace on earth."

Those are where the REAL problems lie!

I would love to see more respect on this blog by commenters.
(no name calling or put-downs)

I have mixed feelings about the impending standards.

On one hand, I am bothered by fact that they are being called, "national standards" and were drafted in secrecy - without the knowledge of FTCLDF members, in particular.

On the other hand, when I was beginner to milking animals, I appreciated it when others posted their standards - it was a great way for me to see what others were doing, try various systems and then settle on my own process.

The key point though was there were many posted standards that did not work for me - and usually the issue was scale related - I started out hand milking one goat. I wanted to do it as safely as possible but did I really need a separate septic system in order to be clean?

Another issue that often cropped up was the tendency for folks to add a lot "fluff" to the standards -
Reading through list of "issues" found on the Hartmann farm, and some of the dubious Meadowsweet "infractions" had me scratching my head.
If might be "nice" to have a requirement that there will be no cobwebs on the rafters of an outlying barn - but is it really pertinent? Are there pathogens in cobwebs? How far away does that barn have to be to matter? if you say 300 ft., then what happens if a farm has a neighbors barn within 300 feet? If you don't know the answer, don't make it part of a standard.
I like Salatin's example from "You Can Farm" - Good enough is just perfect.

Many standards I've seen are based on some arbitrary idea -
awhile back the State of Florida was chopping down citrus trees on private property if they were within X number of feet from a tree infected with canker. One day it came out that the state had no idea how many feet canker could spread. Irreplaceable trees had been destroyed based on a guess. We also learned that the inspectors who were going around checking trees for canker, were actually spreading the disease. This was not so long ago that they can claim they shouldn't have known better.

So who will make judgements about compliance? How will this be done while guaranteeing the biosecurity of property? Will it be financially lucrative for any
"inspector" to find infractions? Will the standards be written with the schmuck behind the counter at Department of Motor Vehicles in mind - meaning, are we mindful that we will be subjecting someone, somewhere to a grumpasaurus/tyrant inspector? Standards that are vague or subjective give too much power to such people.

My last concern is who stands to be enriched by these standards? And why is it that most "standards" in my life require me to buy something?
I've already seen that happening - in recommendations that all cleaning must be done with products specifically labeled for "dairy".
Wrong answer. I've read the ingredient labels on that poison. What an irony that so called safety standards create unsafe exposures for dairy workers, the animals and possibly those who drink the milk to toxic substances.

OK, I'll put the soapbox away now.

Pete, I read your post after I wrote mine, I know it repeats some of your points..
I wasn't ignoring you.

Bill - "I think it is fantastic that there is that discussion, I just think it should be in the open."

It will be in the open. Give us a break to get this past the first-draft stage.

Happy New Year.


I am not an FDA agent, nor do I work for any other governmental agency. I am a certified organic, grade A Wisconsin dairy farmer who happens to love raw milk and cares about what happens to small, family farmers in this state and in all states.

I never said I wasn't under the jurisdiction of DATCP; on the contrary, I have a milk producers license, a contractual agreement with DATCP which gives them the right to conduct, among other things, unwarranted search and seizure on my farm. If I did not have a contract with them, they would not be able to do this. Any issues would then be under the jurisdiction of the local DA and could only be investigated with a proper search warrant.

What I have done is question the methodology of how your legal team is "fighting" for raw milk in Wisconsin. It is my understanding that the incidental sales clause has been on the books since 1957, and the original intent of the legislation was not to ban raw milk sales outright, but to relegate them to on-farm sales only for grade A producers. DATCP does not have the authority to deviate from the original intention of the legislation and "reinterpret" what incidental means. Why isn't your legal team challenging DATCP's authority? They have at least two "interpretations" of incidental - is the old interpretation correct, or the new one? I can't be positive, of course, that this would win in court, but IMHO would be the place to start.

Instead, your legal team has two lawsuits pending, at least one farm cannot sell raw milk any longer as a condition of receiving a retail food establishment license, and you're trying to "solve" the problem with one unsuccessful attempt at passing horrible legislation, with the second attempt coming down the pipe. Seems like a lot of hullaballo, when the suggestion I made above, if successful, would be faster and more decisive.

Understand, dissension is not dividing the raw milk movement, secrecy and a one-size-fits-all attitude is. Dissension is not a bad thing, our country was founded upon a multitude of voices. Now, listen to what we're telling you and give us the credit we deserve.

"We certainly know from hints that were dropped last year that pressure from the Wisconsin dairy industry played a major role in the crackdown on raw milk in late 2009."

The crackdowns weren't due to pressure from the "Wisconsin dairy industry" - they were due to pressure from Organic Valley, specifically. The "Wisconsin dairy industry" didn't give a hoot about raw milk until the raw milk bill came on the scene.

I am willing to take these proposed guidelines under advisement only as "general advice", not "standards". These people aren't Masters of the Universe - there are a myriad of ways a quality product can be produced.

It is a chilling thought that the FTCLDF would deny representation to producers not adhering to a rigid and arbitrary set of standards, though. I would suggest that contributions to that organization should feel a similar "chill" from such "outlaw" farmers.

It has been said before, but I'll say it again. Test the product - not the facility.

When the public comes to visit your facility and farm....what do they see?????

Is it clean and green or filthy, cluttered and looking pretty darn marginal????

Standards "change the mindset" of the effort on the farm. The farmer starts to think differently about what he looks like and who he serves. It sets into a plan the objectives of the imputs needed to do a better job. When an inspection happens, by human nature, the inspected wants to be proud of his facilities. Standards change the sociopolitical dynamics of interactions among people. Standards bring the farmer into the society and closer to the consumer. The slack PMO CAFO FDA standards have alienated and marginalized the farmer and excused filth because of that great modern farm and farm family killer...the pasteurizer.

I agree that it is possible to get a sample of very clean raw milk from an absolutely filthy environment... ( you take the milk directly from a very cleaned off udder and focus very carefully on that one little sample with great effort ) . But this can not be reliably repeated at midnight or 0400 everymorning every day of the year. It becomes an effort that is to difficult and not easily repeatable.

On the contrary, an organized clean environment that is designed for ease of cleaniless and ease of milking and cow comfort changes the equation and brings the right kind of bacterial and environmental conditions into play for a fairly easy and reliable milking of cows with very good results on a reliable basis.

These good conditions are sensed by inspectors and consumers alike. No...a cobweb in the corner has no effect on milk quality...but it is a symptom of the mindset.

That is why we need good standards. A first draft of national standards is a first draft of national standards. It will get its public airing....Tim will get all beat up by some and he will be praised by others as well.

Let the process take its course. We will all get our say in do time. Ever seen a process developed by committee....it is mostly all screwed up and looks like a bunch of bad compromises. Let the small group of focussed minds come forward to present the first draft. Then the world can respond. I can not imagine a final draft that everyone loves either. Standards by their own definition will set up fences and tell people things that they do not want to do or hear.

Let me be the first to follow the recommendations when they are completed and vetted.


"No...a cobweb in the corner has no effect on milk quality...but it is a symptom of the mindset."

What is the mindset that wants to eliminate diversity even when there is" no effect on milk quality"?

Isn't this zero tolerance policy the policy that leads us to use all kinds of toxic chemicals simply for the appearance that we are in control?Is a" weed" in the pasture a symptom of a certain mindset?

We should be spending our time taking care of things that directly effect milk quality.I'm sure there are people who would pay as much as $18.00/gallon for milk so that the farm looks like a picture book farm,but most of us would tolerate a few cobwebs on the farm if we didn't have to pay someone to constantly be sweeping the rafters.Or maybe you are suggesting that we can eliminate those pesky spiders with some kind of toxic spray.

I will here echo some others comments, by way of agreement

It's gratifying to hear that the committee's goals are to be holistic and focused heavily on improving soil and animal health as the primary means of improving product quality, but I confess to being annoyed anyway, at the notion that any person or group must set standards at all, a term which implies, no, actually it more than implies, it carries a de facto stipulation, that anything outside that particular box is automatically less. Why not suggestions, or education, or even advice, or recommendations? Why always standards?

All this big picture thinking is, to me, fundamentally wrong, at least the way we tend to approach it, because it leads us into the trap of centralized directives--exactly what buried us to begin with. What the big picture ought to be teaching is that what we need most is to devolve, and then devolve some more. We need to allow individuals to make their own way, to make their own decisions, and to allow trust and relationship to rule over external standards and rules. That is essentially what the local movement is all about, and what miguel and others are attempting to achieve by teaching us how to assert our right to act as private individuals outside the states commerce laws.

Now please know that I fully expect to learn something, maybe a very lot, from the committee. I look forward to that. Im also especially anxious to see if these standards manage to bridge the gap between medical/government and "alternative" paradigms. (Will the standards, for example, accept that a hosts condition is significant as a disease vector, while simultaneously satisfying medical/government source-pathogen phobia?) And I fervently hope that potential customers (and government officials, and the standards writers) are not led to infer from the mere presence of the standards that a farmer can do no better than by conforming to them.

In the meantime, please check out these two 10-minute video segments showing how yet another "oddball" idea seems to be working to improve farm outcomes. Take note especially of how the ideas grew from very local observation:



What is this desperate need to equate a resistance to "Standards" as an advocation of the production of unclean milk in dirty facilities?

No one is advocating that, Mark. You're reading something into it that's not there. We just disagree with this seemingly one-size-fits-all mentality.

If someone buys a run-down farm and wants to sell raw milk under these standards, are they expected to spend $$$ and go further into debt to prevent their farm from looking "pretty darn marginal"?

Now you're focusing on outward appearances, and outward appearances are not necessarily correlated to milk quality.

Let's think for a moment. Mark, on his own website, says he's the CEO and Managing Member of OPDC, he doesn't call himself a "farmer".

Let's look at the other Managing Members of OPDC:

Eric McAfee, Founder and Managing Member
Eric is an entrepreneur, venture capitalist and merchant banker who has founded eleven companies in renewable energy, oil & gas, networking, and software. He founded and serves as managing director of Silicon Valley-based merchant bank, Cagan McAfee Capital Partners . The aggregate value of the companies Eric has founded have high market capitalizations in excess of $4 billion. Eric is a graduate of the Stanford Business School Executive Program and Harvard Business School Private Equity and Venture Capital Program.

Adam McAfee, MBA/CMA, Founder and Managing Member
Adam founded and serves as Managing Director for Park Capital Management, a Silicon Valley-based private and public equity investment firm specializing in high-tech and renewable energy companies. He has twenty years experience as an investment advisor and corporate controller. He worked for eleven years with technology innovator, Apple Computer, Inc. in corporate finance for the Worldwide, R&D and Sales divisions. He is a Certified Management Accountant and registered as an Investment Advisor. He graduated with an MBA from the University of California, Irvine and Harvard Business School Private Equity and Venture Capital Program.

I in all honesty can't say I know, personally, any other farmers with investors like that.

Mark is a corporate monopoly that controls, what, 95%?, of the raw dairy industry in California. Standards are good for monopolies, as they increase the costs associated with entering the market, and thus make it much less likely that any competition will enter the market. Mark will say standards are good for raw milk, but I'd bet that Eric and Adam McAfee will say they're good for business, too.

(The above information is right off of OPDC's website - "meet our staff". And if you look at the staff he has, you'll see why Mark doesn't have to worry about cobwebs in corners, he has a gaggle of employees to worry about that for him.)

I am more than happy to listen to what this group comes up with, but I'll need to see some evidence-based justification. The "30 feet from the barn" type of stuff just won't fly with me. There is nothing whatever to support that figure. It is simply pulled out of the air like the Florida citrus canker example someone gave. In Miguel's link, another example is cited: "we have no say in the matter because we live more than 300 feet from the proposed subdivision". Thus we obviously won't be bothered by it and cannot object to its being built. This is yet another absurd arbitrary measurement incorporated into "standards". Real life is much more nuanced than that.

What would happen to dairies that have existed for years without causing illness? Would they get grandfathered in? Or would they have to spend money to upgrade? I can see why Goatmaid and Violet are upset.

Farmers are more known for tending sheep than behaving like them. I don't think this group comes anywhere near to being conspiratorial, but it has the appearance of paternalism as well as a touch of arrogance.

Attention to cobwebs is easier when you have a labor force...when you pay people to work on your farm...milking cows, cleaning water troughs etc. Small farms, ones without employees have a hard enough time getting the important stuff done...keeping everything fed, milked etc.

Most raw milk dairies I have been to haven't been pig stys...but the are far from immaculately kept properties either.

There are so many hours in the day.

I find it offensive that those who equate cobwebs in the barn with someone who doesn't take the production of milk seriously....and can only come from someone who really hasn't put in a good days work actually working the farm. Sitting at a desk and telling people what to do doesn't count....no matter how many pictures are taken out in the field. This is the problem with large industrial farms....even industrial raw milk farms. Getting your hands dirty, and making sure they are clean gives one a different perspective. Pulling a teat isn't the same as tapping a keyboard.

I'm willing to give the group a chance...but from comments before it seems like this will be just another effort to let crap milk farms enter the raw milk market. It seems that with standards in place more large 'farm owners', with hired labor milking their herds, will be given an 'in'. I wonder how many truly small farmers are on the 'committee'.

Also something to think about...what happens when the first farm with the seal of approval makes someone sick....after all 'reducing' incidences is the goal...not elimination of them. Won't that 'tarnish' all the rest that have invested in the new mark?

Bill Anderson - I fear that FDA and DATCP discussions are more transparent, and are subject to open meeting laws and FOIA, or the state version. Since you seem to be blessed with a working copy of the new standards, post them here for all to see.

I post all my ideas about raw milk safety on my blog or at www.realrawmilkfacts.com.

Mr. Marler's request seems fair, since the cat is now out of the proverbial bag and you've obviously got people concerned. You could at least let us know when we can expect a "first draft" of the thing.

David, you still have not responded to my question about being afraid of standards. I think I have tried to be constructive in this debate. I have openly published (and been punished) for laying out pros and cons of raw milk consumption and thoughts on how it might be produced and sold safer:


I have also tried to be clearer that perhaps some governmental sites on the numbers of outbreaks related to both raw and pasteurized milk:


I have recently poked around in the cheese issue - raising the ire of young Bill Anderson:


I am, however, most heartened by your previous post David. It is time to stop the anti-science, conspiracy talk and deal with the realities of outbreaks and illnesses and how to prevent them:


David, I do not fear much. I certainly do not fear raw milk producers, like Mark, admitting errors in the past (2006 E. coli Outbreak) and looking for solutions.

Something I have been pondering on the beach:

Why are sprouts and raw milk not treated equally?


Oops, looks like it is kind of a done deal. FDA and all secret societies would be proud.

Subject: Raw Milk Working Group completes report

Posted: Wednesday, December 22, 2010 9:26 am | Updated: 9:35 am, Wed Dec 22, 2010.

By Jim Massey | Editor | 0 comments

MADISON - Nine months after Wisconsin's Raw Milk Policy Working Group began its task of coming to a consensus on the contentious raw milk issue, the committee completed a report that will be sent to state officials early next year.
The working group hashed out several final issues before reaching a consensus at its Dec. 17 meeting. The consensus statement said that if Wisconsin law allows the sale of raw milk on the farm, "the Legislature should incorporate the comprehensive set of regulations, education and information outreach initiatives developed (by the working group.)"
Richard Barrows, a retired UW-Madison and UW-Extension agricultural economics professor, said he was "pleased and proud of what the group accomplished."
"It has been a very, very long, polite conversation," Barrows said. "People came to a consensus even though they started with very different opinions. It was a testimony to (former state agriculture secretary) Rod Nilsestuen's faith that reasonable people can find common ground on a really controversial issue."
The final recommendations cover everything from the licensing of raw milk producers to the containers the milk can be sold in. The group worked out final details last week on the recommended processes for filling raw milk containers on the farm, on-farm antibiotic testing and how the program's costs should be covered.
Barrows said it probably will be the middle of January or the first of February before the report is submitted to the new Department of Agriculture, Trade and Consumer Protection secretary.
"The secretary will share it with the board and it is the custom in the department to share it with the Legislature," Barrows said.
The 55-page draft recommendations include 35 parameters under which raw milk sales would be allowed on Wisconsin farms. They include:
* Raw milk sales would be allowed only on the farm and directly to consumers.
* Producers and farms licensed and permitted to sell unpasteurized raw milk would be governed by a detailed set of laws and regulations. The regulations would include such items as how the containers are filled and refrigerated; how often the milk should be tested and for what potential pathogens; and would establish the licensing procedure for producers.
* Producers selling raw milk on the farm would not be exempt from liability or personal injury or damages incurred by consumers from consuming the milk.
* A producer selling raw milk would not be required to hold a Grade A dairy farm permit.
* A raw milk farm permit would not be issued to a producer if any of the cows on the farm were milked by hand or if the milk was stored in cans.
* The on-farm sale of raw goat milk and raw sheep milk would be prohibited.
* A producer would be allowed to advertise the sale of unpasteurized raw milk, but only for purchase and delivery at the farm where the milk is produced.
* The DATCP and University of Wisconsin would be required to prepare a best management practices manual for producers selling fluid unpasteurized milk and a consumer's guide for the safe handling of milk.
* After the law takes effect, the governor shall appoint a seven-member committee to monitor the effectiveness of the law, including food-safety and public-health issues related to the sale and consumption of unpasteurized milk. Within four years after the law takes effect, the committee shall make recommendations to the governor and the DATCP on any changes needed to the law.
One of the final sticking points the committee discussed before signing off on its recommendations was the on-farm processes allowed for producers to fill containers with raw milk to sell to consumers at the farm.
The group agreed that three processes be allowed: customers could bring their own container to be filled at the bulk tank; producers could provide a container that would be hand filled from the bulk tank and put into a refrigerator; or producers could provide a container that would be mechanically filled and put into a refrigerator.
Some committee members expressed concern about allowing raw milk to be refrigerated prior to the sale, saying a poor refrigerator could result in the milk getting too warm and developing pathogens.
But Willi Lehner, a Blue Mounds cheesemaker, said it would be incumbent upon the producer to make sure the refrigerator maintains the proper temperature.
"The farmer wants to put his best foot out there," Lehner said.
Steve Steinhoff, a retired DATCP Food Safety Division administrator, agreed.
"The whole inspection system depends on the producer being a good business person and being scrupulous," Steinhoff said. "That's the way it is."
The working group also discussed the program's cost estimates and potential producer fees, but opted not to recommend specific fees that eventually would have to be set by the Legislature.
Dodgeville cheesemaker Mike Gingrich said if policymakers want to control the underground market for raw milk, they need to set up procedures and license fees that would make it feasible for sellers.
"If the costs are too high in practice (the rules) won't be used," Gingrich said.
The report will suggest that raw milk license fees be "consistent with the DATCP policy for other dairy industry fees."
Elizabeth Kohl, a DATCP senior policy analyst and the working group's facilitator, said if the Legislature approves a raw milk policy, it would take 14 to 15 months for the administrative rule process to be completed before the new law and rules take effect.

"If the microbes are unhappy with what they are doing, they are going to evolve away from what you want them to do. A key part of the future is going to be designing a system where they are not grossly unhappy."

Substitute "microbes" with raw dairy farmers and you've got another interesting statement.

In the past 3 threads I've posted statements that cover a lot of territory. I am going to be the broken record and repost one.

"A more useful assumption with any new tech (law/standard) is that it is neutral, and so are the people creating it and using it. Your job is to maximize its advantages and minimize its harm. That cant be done from a distance. Particularly for environmentalists, the best way for doubters to control a questionable new technology is to embrace it, lest it remain totally in the hands of enthusiasts who think there is nothing questionable about it.'

Hoisting the 'he/she is corporate" petard is provocative at best and aggravating at worst. So is holding them to be a "fixed" or "demonized" entity. Those who are don't survive or crash until they do change. I have been on the receiving end of what I still feel to be very lame and regressive corporate decisions. Their loss. Also time for me to move onto the next adventure.

MBA's hot and heavy out of school operate by the book and soon find themselves swimming in their own hubris. Again working farmer's markets have taught me a lot in this respect. I am acting on directives from a recent MBA grad yet the market and direct feedback from customers dictate a more elastic and adaptable course of action. I am caught in the bottleneck. I know how to respond. The MBA is still on disconnect and operating by book/ degree. I bring this up with customers who were business people with experience under their belt. The first question usually asked was "Did they just graduate with their MBA degree" as to them what they heard was systematic until the person fell on their face enough to learn otherwise.

A lot of time our "bark" is worse then their "bite." Don't feed the buzzard until it's necessary

Two dairy farms in California selling retail. One large. One small. One "out there." One "quiet."
2 different models of philosophy, business and operations. Each one valid. Each one up to now succeeding.

There's enough to go around!

* The on-farm sale of raw goat milk and raw sheep milk would be prohibited.

Since when does it matter what dairy animal the milk comes from? I see a pretty glaring problem here.


I agree with you, and would like to see the science they used to decide raw cow's milk should be allowed, while raw goat's and raw sheep's milk should be prohibited. Hopefully, that will be revealed and open for discussion.

Some educated guesses are inherent in producing any guidelines or "standards." Most importantly, avoid dogma. For example, I think the raw milk movement was misguided when they promoted dogma that pure "grassfed" would be the "be all end all" to milk quality and safety. Similarly, a 300 foot barrier is likely arbitrary, and subject to other important factors, as you said. Regarding the cobwebs - who cares, unless it's a proxy for some general filthy conditions.

Similar to what's going on with other industries, each of these "standards" can be researched and improved based on data (combined with common sense). I applaud the efforts by the WI group and Tim Wightman's committee, and look forward to seeing more details, even if some of their recommendation might make no sense at first glance. This is also a great opportunity to reach out collaboratively to university scientists to conduct research to improve the standards using input and data from the stakeholders: raw milk farmers and consumers.


Kirsten and all,

That one rule alone with regards to goat and sheep milk will nullify ANYONE out there in Wisconsin who wishes to start a raw milk artisan cheese business using goat or sheep milk.

Uninteded consequences anyone. . . .

This whole working group concept with standards stinks.

Have they talked to any sheep or goat milk producers?

In two years I plan to milk our Icelandic sheep for three months out of the year and create a very rare and choice aged artisan cheese. "IF" these standards were applied on my farm . . . . I would not be able to build upon this business concept.

Square peg into round hole is what I think of when it comes to these standards. Standards should be simple, "VOLUNTARY" and as follows: A farm should be visibly clean and tidy to all customers. A farm should have open business hours and welcome the public to see your husbandry/quality/health of your animals and most importantly. . . . a plate count of pathogens should be very low if you are clean and on grass. This should be done monthly. It should not matter then if you milk by hand in a stainless steel bucket or use mechanical milkers. This is a no brainer.

You can't excuse filth and dirt . . . . your animals will notice this (and become ill due to the stench and filth eventually) as well as driving away your potential customers ~ that is, if you allow your customers to visit your farm (which we do gladly) for inspection before buying any of our products.

Standards only lead us into deeper regulatory burden. Let our customers decide. After all as I told Milky Way . . . . There is a double standard with regards to CAFO's and small farms She blew me off and said that I was not on point . . . . How can I not be on point when there are countless cases of salmonella from CAFO eggs and poultry . . . . not one of these factory farms have been shut down and I bet they still stink to high heaven but if you get a some hint that there "MIGHT" be a link between a raw dairy (even though not all who were sick consumed raw dairy) . . . . the small farm that produced the "suspect" food has product confiscated and shut down until futher notice.

Lykke always responds to my questions about CAFO's is that "It is not so simple" . . . . how is that so and please elaborate. . . . . Are you in the payroll of one of these corporations . . . or are you being bribed in some way by these same corporations?

We must bring back our local farms and teach our kids how to cook from scratch again . . . . it will take another 7 million small farmers who care about husbandry and wish to produce the highest quality products to change the current mindset of everyone who eats the SAD. Only then will we as small farmers, have the clout to stand up to TPTB and crush the monopoly of the CAFO's. I pray it is not too late.

Kind regards,



The bullet about goats/sheep appears to be the most non-scientific part of what WI released from their not-yet fully published 50 page report. I suspect you'll find support from a number of sources to modify that part of the report (assuming they are open to discussion).


I just hate this term from MW's post:


Reminds me of the wordings behind NAIS.

So we are not farmers (producers) and consumers . . . . but we are "Stakeholders" for what stakes?

What are you talking about . . . and please quit using this term . . . . we small farmers told you (the government) we hated this word when we protested NAIS and please quit using it . . . . why is it still being used?


So why was it even included? To exclude a majority of very small producers of very high quality artisan products?

That bullet alone discredits this raw milk standard. There is really no science that justifes this.

Kind regards,


Did you really think that this working group would come up with something hat wasn't heavily influenced by those that boil milk.....

Consider the source, and follow the money, and you'll see why this was a sham.

Bill Marler,
Sorry I haven't responded sooner to your question, been traveling...I raised the question about your seeming nervousness because your first comment on this issue was to question Tim Wightman's credibility in helping develop raw milk standards, based on his being an expert witness in a court case. Seemed negative and counterproductive for the reasons I stated in a previous comment. Based on your consistent disparagement of raw milk producers and consumers as people who care little about safety, I wondered if the development of standards associated with safety might be threatening to your view of the raw milk world.

I appreciate your involvement in the discussion here, just remain puzzled. You said you weren't nervous, just wondering about how open the Wightman committee's process is. To suggest that FDA and DATCP are open in their decision making, and compare their approaches to what is happening with Tim Wightman's ad hoc committee... all I can think is, once again, you're stretching to absurd lengths to find ways to discredit. And the various articles you link to--those have nothing to do with standards. One consists of your proposed regulations to limit distribution of raw milk...a list that was mostly followed by Wisconsin lawmakers last spring in passing legislation,, and which you pushed the governor to veto (which he did).

Long answer to your question, but basically, it's difficult to conclude you want anything but negative outcomes for the growing number of people who simply want the freedom to access raw dairy products, and are seeking to demonstrate ever more firmly a safety orientation.

Sue Diederich,
You make great points about the pitfalls of standards (along with a number of other individuals). Makes me wonder if "standards" is the best term to use at this point in time, since it can lead down such a discouraging thought/regulatory process so early in the game. I guess I prefer to think about this, as Dave Milano suggests, as something related more to education. Wightman seems to be talking about a new paradigm for thinking about dairy production, of the sort that has received extensive attention in Acres magazine, and a few other places. I just hate to see us get too far ahead of ourselves.


Well, David, I guess you and Dave Milano are right. I will settle down and wait for the results from Steve et al.

I'm very disappointed that the so-called "Raw Milk Working Group" has come out with a purposely divisive non-starter of a document. I'm confident that Tim's working group will come out with something much better than DATCP's - but honestly that's a pretty low bar.

I think the fact that the WI Raw Milk Working Group even sanctioned cow's milk is remarkable, and likely testimony to the big fuss being made by raw milk drinkers over the veto of the raw milk legislation last April, and the DATCP crackdown. But I agree with you, it's likely purposely divisive--get raw dairy producers fighting among themselves, while DATCP et. al. wash their hands clean of the entire mess and walk away.,,or if this current proposal is approved, the state will have eliminated many raw milk producers, and can work on the remainder via ever-tightening regs.



Violet said,

"I just hate this term from MW's post: "STAKEHOLDERS"

That's a term we use to get grants; duly noted that perhaps it is not a good term to use if working with raw milk producers and consumers to find funds to study raw milk safety and benefits.


"So why was it even included [goats/sheep]?

No idea, will be interested to see their science behind it.


David....nice point made about the use of the term "standards"

David, I think I understand your concern now. My beef with the raw milk proponents, specifically with you and Weston Price, has been the denial of the epidemiology of the outbreaks, and the attacks on the actual victims by some of the folks who comment here. Until recently, you must admit, that the tenor on this blog, and in the raw milk community generally, has been that the outbreaks never happened and/or the victims brought it on themselves - that somehow all these outbreaks and recalls are simply some grand conspiracy by the FDA, Big Ag and one trial lawyer in Seattle. Frankly, all of that is so absurd that it makes easy fodder for a blogger, who also happens to be that lawyer.

I am heartened to see that people like Mark are admitting past outbreaks and working hard to prevent the next. I think if the raw milk movement stopped denying science and victims, and stopped the threatening rhetoric towards disabled veterans doing their jobs, regulators would work with you on standards, or just simply leave very small producers the hell alone.

I think Tim and the rest are on to something, but like everything else, it is done better in the sunshine.

"Lykke always responds to my questions about CAFO's is that "It is not so simple" . . . . how is that so and please elaborate. . . . . Are you in the payroll of one of these corporations . . . or are you being bribed in some way by these same corporations?"

WTF - I'm anti-CAFO and have said so many times. When I post here, I get attacked by Truly Concerned and others - notably, they disappear when I'm not posting on this board - they only come on to attack - check the archives - have you seen Truly Concerned post anything of substance here other than to attack Lykke? No.

Bill Marler sums it up. Search your hearts and do well with your efforts to be honest and care about the product you produce regardless of what the CAFOs are doing.

Wow. My brothers and I started with next to nothing and huge debt All we had was ambition and work ethic.

I am terribly proud of my brothers who are all self made very bright Americans.

I started off the day welding a broken cow feeder then I met with my controller to finish up budgets for 2011. Then I drove 3 hours to attend two farmers markets in San Luis obispo talking to customers and educating consumers

Not sure what that makes me. I am not interested in being a farm slave. I am liberated educated motivated and provide paychecks for 25 families

I am a new kind of farmer. One that gets respect and one that spends time all along the food chain. Not just locked up on the back 40 acres.

If farmers want to become liberated. They will need to learn how to do more than milk cows and drive tractors.


If society is indeed sincere about reducing illness then eliminating the use of hormones, GMOs, prophylactic antibiotics, chemical inhibitors and pesticides etc. aught to be the first order of business. Adopting a holistic or permaculture approach in agriculture is an important step that will hopefully encourage society as a whole to recognize the value of living in harmony with all life forms, rather then fear and attempt to control and annihilate those which they poorly understand.

Bill Marler

Epidemiologists clearly recognize that testing for pathogens is an ambiguous process. It seems that they and their fellow regulators have little problem dismissing or ignoring the results of such testing in the event that those tests fail to support their findings in an investigation as per the bean sprout incident that Sylvia referenced.

Is there no room for reasonable doubt in their world?

As an observational science, epidemiology is regarded by some researchers as inherently flawed and open to false results in that, methodological vigilance is often absent and likewise subject to the whims and biases of the investigator.

Ken Conrad.

Hi Lykke,

You need to recheck the archives. It looks like you are sloppy and lazy as well.

The real issue is that since you have made yourself out to be the omniscient and omnipotent regulator. You really want everyone here to hang onto your every word as truth from god and want them to kiss your ass.

It's ok for you to lob grenades. When the shrapnel hits you you get offended. Too bad.

Grow up and come to the blog like an adult.

Cobwebs & spider webs seem beautiful and conjure up thoughts or images of Charlotte's web or a newly made morning web sparkling with dew on a beautiful old-fashioned barn. Imagine, a spider doing his job as nature intended.

I cannot equate a cobweb with someone who doesn't care about her farm and loves her animals.

And then I think of a farmer who feels blessed to milk her own cows and loves riding her tractor in peace & harmony.... without someone trying to meddle between she & her customer, a friend. I think of a farm girl who would rather be outside in the field fixing a broken down piece of equipment, not blogging.

Raw Milk Policy, regulations, standards, or licenses serve only their authors and Regulators: open to reinterpretation, abuse, and capriciousness as has already been demonstrated. Should raw milk farmers sign up for a state raw milk license too? Would it not be similar to signing up to go on vacation at Auschwitz?

In defense of Mark McAfee, I want to say that I greatly appreciate his success as an organic dairy farmer. In addition to being a great organic farmer, Mark McAfee is an excellent teacher. That is why I invited Mark McAfee to speak as a farmer representative to the Committee on Organic and Sustainable Agriculture program - Know Your Farmer Know Your Food, held November 2010 in Long Beach, CA. Mark McAfee served as excellent farmer/spokesperson to address our group. Mark was also very generous with his time and organic food donations. It was an amazing event with lots of crop scientists, soil scientists and government officials drinking up on Organic Pastures Dairy. Read the whole story here:
Meet My Organic Farmer

I did not mean my comment about spiders as an attack on Mark.I meant to defend the idea of biodiversity.When we are asked to choose between a healthy bio diverse farm and a pretty,orderly less diverse farm, I hope we will be able to make the right choice and be able to defend the decision to those who matter.That would be the people who eat the food from that farm,not someone who has no direct connection to the farm.

Every farm should come up with it's own standards and be able to explain them.Let people decide what they are happy with.

As we get a little farther into the collapse of the agricultural systems that require huge inputs of fossil fuel,what we will value most of all is an agriculture that is diverse.We all will need to be making big changes in the way we get our food.Let's not eliminate any of our options.Let everyone come up with their own unique system . That is how we will evolve to new ways of surviving the big changes that lie ahead.

At OPDC we have and love our spiders, lots of cobwebs on the wire fences, coyotes, birds, gophers rats and all sorts of wild things in all of their biodiverse splender and awe....

But we do not invite the coyotes, cobwebs, birds, gophers, rats and all sorts of other wild things into our creamery.

However, I do invite the Kefir cultures and beneficial lactic acid producing raw milk bacteria and all of their biodiverse splendor and awe to make a home in the cracks of our creamery floors and drains. That is one of the reason we have never had a pathogen found by any test in our enviromentals at the creamery. It is my job to create and promote conditions that lower risk and increase the chances of only the good in the environment.

For every place... their is a place for all things. I also invite FDA and CDFA and DHS inpectors into our creamery ( more like they invite themselves...but is a different story with a different moral ). They are less awed by creatures that they find and see!! and I strike a very happy balance and medium between all the creatures and all the visitors.... and that is why I have peace.

Thanks Joe....

After thinking about being called a "non farmer"....It has me thinking???

Does any one have a definition of a farmer as a person that serves his consumers and the entire food chain?? Not a nearly extinct farmer that just works the soil and gets paid like dirt because that is the only part of the food chain he serves???

What do you call a person that works at all levels of the food chain and invests in consumer relationships and education because he knows: the soil and the plants and the cows, the chickens, the people, nutrition, products, bacteria, risks, food safety, trucks, logistics of distribution, chillers, bar codes, policies, laws, AR/AP, HR, niching, value added, branding, labels, politics, blogging etc... Any ideas???

My guess.... the "organic farmer" certain people wish they could be, but few have endeavored to become. Everyone of the farmers that I know that connect to their consumers do what I do. A farmer on the back forty is a slave to markets and his bank line of credit renewal date....he takes what those who are engaged with people choose to give him.... if anything.

Any ideas??? What do you call this person??? We need a new name for this new farmacist and leader for our new future? If his title is not organic farmer then what is it???

Ya...you struck a nerve with me.

My first job out of high school was as a commercial welder in a Tungsten Mine,......I know work, I know dirt, and I know risk.

This one is for Bill Marler...I agree. He is very knowledgable about disease and infection. Perhaps one the most knowledgable of all lay non medical people in the world. He knows the legal ins and outs of every piece of science going.

One more thing....it would be an absolute triumph to have Bill Marler and Mary Martin give input to the national standards for raw milk production etc... in fact,they need to sign off on them.

Think about that...it is genius and it is truely a creative genius strategy....they may even have some really good ideas.

Bill.... we need you to sign off on the new national standards for raw milk...in fact we want you to contribute all you can to the process.


Agriculture should be moving towards diversity and resilience.Can we establish goals yet?I don't think we know enough to establish goals,but we can say that we should move away from monoculture and towards diversity and away from large inputs of fossil fuels and towards renewable forms of inputs.The problem I have with establishing "standards" is that they will be seen as goals and we will work towards those goals and stop there.Diversity and resilience is health whether we are talking about bacterial communities or economies.The idea that we can standardize diversity strikes me as a bit funny.

Your comments are most often the most optimistic on this blog.
That's a wonderful thing. It's inspirational, motivating, and just plain "feel good" while others may not be so much so.

But they have really good points. There is not one good way. There are many good ways.
Sometimes it seems like you take their concerns as an attack on your way. In my case, at least, differing opinions aren't meant that way.

When I mentioned Hartmann and the cobwebs ---
it's hard to tell from the data that has been released, but it appeared they were not in his milking parlor or milk room. If you peruse the list of infractions, you will see that the problems listed bounce back and forth between milk room and barns and "holding areas" . I think that was intentional - meant to deceive a skimming reader to think that all of this was found in milk processing areas.

I've also noticed that you've taken my comments into the world of black and white - as if the world were either hospital clean or vomitorium filthy - I'm guessing you've never been in the military- having some psycho drill sergeant white gloving your spotless barracks and calling it "atrocious". I think anyone who has served will know what I'm talking about right away. If they want to find "dirt", they will.
The more vague the "standard", the more likely they can paint you as a pig.

For instance, in court they said there were flies - no pictures. So technically, it means they might have seen more than one fly. Two flies on a farm. OMG.

City folks who come to a farm are often appalled even when conditions are - for a farm- pristine.
OMG. Manure! That's not clean. So you have a spotless barn, and unless there is someone running behind each and every cow every time she poops - someone, somewhere is going to consider that the barn is filthy.

I'm not attacking you. I admire what you've done. I don't aspire it, but I hold you in high regard.
Can you PLEASE give the little guys the benefit of the doubt? They are not pigs just because they don't have the same staff or farm set up that you do. Please, just try a little harder to hear their concerns.


I think you are very correct in your concerns, beyond the "standards", to be differentiating between commerce and agrarianism.

I hate to invoke the name because lately it brings some very close minded thinking to mind, but
Thomas Jefferson, and the political theorists of his time, did have an understanding of a clear line between "industry" (commerce?) and agrarianism.

One of the main reasons I embraced FTCLDF was that they seemed to honor that distinction.
Where is the line between the need to monitor those who may be blinded by the pursuit of profit
from food vs community sharing of food?

Cow shares, pot lucks, and even lemonade stands
(which I consider "playing" at commerce or education about commerce - NOT commerce) are clearly outside the scope of these regulatory agencies and I would like to hear confirmation from FTCLDF that the pursuit of standards does not mean they are abandoning the importance of these distinctions.


Got it...thank you!

Happy new year!!



Ever hear of the "New Agrarian" movement . . . . That is what we are and I will leave it at that. Let the regulators and the ones who were with us two weeks ago . . . . so we thought but are now embracing something very menacing . . . . Chew on this for a while.

Mark, you are not a farmer like myself . . . . you are trying to be a "Celebrity Farmer" . . . . First of all if you aspire to be this then you must make yourself likeable on camera and write books.

Kind regards,


If farmers become celebrities when they connect to their consumers then so be it. Likeable to who??? I guess it depends on the audience. Only my consumers like me. The FDA and the balance of conventional ag detest me.

I could care less about being liked. Healing people through food is what matters. I guess I stand with Tim. Popularity is not important. Doing the right thing is important regardless of the labels placed on you.


I am very wary of people who consider their light to be whiter than other's.

Let's keep the bullshit it the pasture where it belongs.

I found the verse I referred to last Thursday morning:
John 19:11 "Jesus answered him (referring the Pilate), You would have no authority over me at all unless it had been given you from above."

You might want to read Josh McDowell's book "More Than a Carpenter"

I believe most everyone has the same goal in mind. As a group of individuals with different personalities and working styles, butting heads can produce unnecessary hardships and cause failure in achieving goals.

Groups are enriched by diversity, and a variety of personalities builds a stronger team. Nurturing the strengths of all participants, can increase performance, creativity, and harmony within the group. Sharing knowledge only brings more strength.

There is great strength in numbers. Dividing leads to failure.

Everyone has their own way of doing things. If the end result is a safe healthy product then that would be the right way for that person. I would hope that all listens to others so they can learn: what works for one person doesn't mean it will work for all. There is no one-size-fits-all in Nature.

It seems the goals are the same; freedom to choose what is consumed and producing a safe product.


"Living by the Rule of Law
by Roger Hayes

Few of us would disagree that the world would be a better place if we all lived by the rule-of-law but can the same be said about living by the rule of statute? The writer thinks not.

In making the case that the law benefits our society as a whole but statutes benefit special interest groups and have become a negative factor in our lives let me first put forward my views as to what the differences between laws and statutes are. Here follows a summary of my interpretation of the differences (not necessarily in order of importance, sometimes repeated and definitely not exhaustive) please feel free to challenge me if you disagree."



- Consent is often given by the individual due to ignorance of the fact that their consent can be withheld and their assumption of the existence of the authority of others over them. If the people found out that they can reject oppressive statutes by withholding their consent the ruling class would panic because they would lose control. Watch this space.

- A loss of control by the ruling class would not result in anarchy it would merely result in a shift of power back to the people where it belongs. This process is underway as a consequence of our greater understanding of the difference between laws and statutes.

- The European Communities Act 1972 is a statute. It is unlawful because it is contrary to our constitution which guarantees our right to self-governance. Just because the political establishment refuses to acknowledge and obey our constitution and the rule of law does not make them invalid. If they ignore our constitution and the rule-of-law then we have a right (and a duty) to ignore their statutes all of their statutes including the ones giving them the authority to tax us.

- This writer is not a member (citizen) of the European Union because membership is determined by consent and I am withholding my consent to being governed by a foreign power."

I was quite upset with the "tractor in the back forty" remark . . . . somehow this is very insulting to us truly "Small" farmers.

The best farmers that I know work so hard with the small piece of land that they have. It may not bring in a huge income, have a statewide or national impact or even sway our legislators and regulators but we do impact positively on our communities and local health.

When someone makes a comment like that it just marginalizes those of us who are trying to make a difference in a very small way. Magnify this by millions and it makes a huge difference in local foodsheds all over the US.

We may be small but we value our freedom to work with our animals/plants and to create our own customer base. Our government should have no power over our truly small farms.

I have a huge problem with a big farmers who are in the know on standards that may impact my own farm in the next few years and make comments like the one above.

"Get Big or Get Out".

Well I don't wish to get big and I don't want to get out so where does that leave me and so many other great small farmers out there? Standards have a way of rewarding the big guys who have the money or feel the need to take government handouts and grants to implement the individual septic systems, individual wells, high tech composting, etc., etc. . . . mandated by these new rules. I am sure that these rules and standards will not be cheap. and hey, in Wisconsin ~ I would not even be able to milk my sheep to make raw aged artisan cheese . . . . I can't even imagine how many small goat artisan cheesemakers out there are in Wisconsin who can't even make raw cheese with these rules . . . . is that what we really want?

All of us are different in our approach to farming . . . . but there is one standard that should always be #1 ~ the health of your animals and customers come first. If you cut corners, one or the other will suffer.

I hope everyone has a most productive and blessed New Year!!!!

Kind regards,



So glad I touched a nerve...quite often when one is emotional they write how they really feel, rather than letting the prudent mollification of the brain temper their response. (part of the reason I didn't respond right away...that first draft was definitely too mean spirited, and would've been counterproductive).

I'm sorry, and it's sad, that you feel that the majority of raw milk producers in this country are ignorant slaves to their farms. Your statement is quite telling. I bet if they did know how you really feel, you wouldn't get such a warm welcome on your many 'business trips' around the country. I had always thought that the dedication to a herd, and the willingness to sacrifice personal freedom for the production of raw milk was a noble commitment. Obviously you do not.

Yes, those that just 'own' a farm can be considered farmers. But, I have a hard time believing that you don't have a employee who really does most of your welding for you, and the choice to fix the feeder was one of convenience and pleasure. Good try though.

Personally, I think you have more in common with a CAFO owner (at least those that aren't run by huge corporations) than a family run raw milk farm. While the decisions that are made are completely different, and the premise each starts out with is dissimilar, it's still boils down to the industrialization of agriculture, and the use of a labor force to maximize profit. I've heard other business owners trumpet the number a families that they support with their payroll....quite often it's just a excuse they give to justify the massive profits that they put in their own bank account.

Care should be taken as the commercialization of raw milk increases. Real family farms, smaller more intimate endeavors, where the actual family works it, is a better way to grow the raw milk market. It's more personal and has significantly more meaning. Ten 40 cow operations is better than one 400 cow factory. It gives the consumer more of a choice...spreads real wealth among more families...creates a more secure food supply...and limits the reach of a possible 'incident'. Sure it's harder to get those jugs on the chain supermarket shelf...but there are many who feel that they don't belong there in the first place.

Now I don't want to beat you up too bad. There is room in this movement for a diverse spectrum of opinions. You have your place, and due to your situation, it will be high profile, but you must recognize that you don't speak for a majority of the folks who are currently serving the market. I feel strongly that what we need is more of people like myself, lola, pete, Violet ...who understand that more isn't always better.... rather than a string of OP franchises across the country milking herds of hundreds of cows.

So next time your on that plane heading toward your next European vacation, think about the 'schlep' that's trudging to the barn for the nth hundreth day in a row, so their customers can have the benefit of raw milk. It might not change the way you do what you do...but it could change the way you think about the others that have the same passion for real milk.

PS I enjoy my market days too. It's one of the few chances I get to just hang around and talk with others (at least those that don't moo). Sure I have to bust it myself to get everything ready to go, rather than having someone else do it for me, but it's hardly the chore you seemed to make it out to be.

PSS Happy New Year to all, including you Mark. I hope that 2011 brings each and every one of you what you want most!


You can make aged raw milk artisan cheese in Wisconsin. You just need to be a licensed Wisconsin cheese maker and do it in a sanitary licensed facility. I know a number of successful artisan cheese makers in Wisconsin who make raw milk cheese.

I am a licensed Wisconsin cheese maker. The training I recieved in obtaining the license was somewhat helpful, but unfortunately it was geared towards industrialized cheese makers and not artisan cheese makers. The best educational experiences I had on cheese making were from French master cheese maker Ivan Larcher, who specializes in artisan raw milk cheese.

This is my main gripe about the existing regulations -- they are not designed to promote food safety or quality. Rather, they are a set of rigid rules that are applied in a "crime and punishment" manner.

An example for you:

We cannot legally make (for sale) soft-ripened raw milk cheese anywhere in the U.S. because of the 60 day rule. Even in states where there is legal state-tested certified raw milk (Wisconsin will very soon be one such state) all cheese made from that milk must be aged 60 days.

This makes absolutely no sense from a food safety perspective. Promoting competative micro-flora, acidifying the milk, removing moisture, and adding salt all have inhibitory effects on pathogenic organisms. Fluid raw milk is probably THE highest risk dairy product because it is a high moisture, high pH product. Cheese, even if it is aged for only a few weeks, is going to be safer than the fluid drinking milk.

Additionally, some varieties of cheese actually become more risky as they age. A cheese like brie or camembert, when it is 1 day old, has a pH of about 4.6 -- very acidic. As the yeasts and molds grow on the surface, they consume the lactic acid, thus raising the pH, and activating proteolytic enzymes (which breakdown proteins and release ammonia) turning the cheese gooey under the surface. By the time the cheese is 60 days old, the pH will be alkaline -- over 8.0.

A soft cheese such as this is safer when it is 30 days old than when it is 60. Most pathogenic contamination of such cheese comes from the processing enviroment and not from the raw milk. Pathogens in raw milk rarely survive the cheese making process. If the cheese is contaminated when it is 1 day old, it is much more likely that the pathogen will perish during the aging process than if it is contaminated when it is 60 days old. This is because of the changes in pH that occur during the aging process.

So why are the rules going to allow for fluid raw drinking milk but not soft-ripened raw milk cheese?

Its because the farmers pushing for raw milk legalization don't care about cheese. And frankly, many of them don't care about food safety either, in my experience. This "free-for-all" mentality will only lead to the downfall of raw milk as outbreaks create a public backlash. Public opinion is currently on our side. It will not be if we are making people sick.

As a cheese maker, I care about food safety immensely. I cannot produce a high quality and safe cheese unless I am very thorough about sanitation and cleanliness. I recognize the importance of the quality of the raw milk. One cannot make world-class artisan cheese without world-class milk. But producing world-class milk requires regular testing and monitoring of the milk quality. Protein and bio-film buildups on milking harvesting and storage equipment will lead to deleterious effects on the quality of the cheese. Coliform contamination of the milk (because there is sh*t in the milk) will lead to rancidity and poor quality cheese. Yet, I have seen in other states (where cheese maker are not required to prove their competancy) cheese that has awful coliform contamination and yet is offered for sale. I would not be surprised if that cheese maker has made some people sick.

It is one thing to complain about standards and regulation because they are designed only for industrialized cheese makers. I would share this opinion with you. The problem is particularily accute in Wisconsin.

However, if the regulators were interested in helping small scale artisan chese makers make a high quality and safe product, then I would welcome the regulation. It doesn't need to be a "one-size-fits-all" approach. That is just how things are now, because of our American obsession with bigger, better, faster, cheaper, etc...

I look at parts of Europe where the artisinal scale of production and the local traditions (some of them thousands of years old) are protected by AOC, DOP, and PDO standards. (Protected designation of origin). These PDO standards are voluntary, but to abide by them provides a distinct marketing advantage. I would not be opposed to such a regulatory system in the United States if it was designed to help artisan cheese makers.

Truly Concerned,

Have you come up with any ideas to add to conversation yet? Curious minds want to know your thoughts.


See these WI farmstead goat and sheep cheese makers. All of them make raw milk (and pasteurized milk) cheese:


Milk farmer and Bill Anderson,

You really need a small, diversified farm to produce artisanal cheeses. Think of cheeses wrapped in grape leaves or coated in wood ash. Think herbed cheeses. This kind of thing would drive the regulators crazy if it came from the same farm on which the cheese was produced. Everything must be purchased from outside, with the effect that beside adding expense, the cheese producer cannot be sure of the ultimate quality of the cheese he or she is producing.

Mark McAfee's farm is similar in some respects to a monoculture farm. He essentially produces cows and grass. Diversifying into goats is a good idea. It's not much more pressure on the pastures, and breaks the worm cycle for both animals.

I agree about biodiversity, Kirsten. I've never been to Mark McAfee's farm, but based on what I know about it I don't think it is a monoculture. Sure, the dairy is the mainstay, but there are almond trees and hedgerows that have wildlife. The goats sound like a good idea too.


I really didn't mean to slam Mark's farm. By American standards it's much better than the one farm-one product model that exists on many farms. Goats can only improve it. (Wonder what species grow in his hedgerows?)

I do want to point out the current absurdity that if I want to produce an herbed goat cheese, I would have to get my rosemary/thyme/garlic/lavender somewhere else according to current regulations, even though I have plenty growing here. Commercial dried spices are allowed to contain adulterants, including insect parts and rodent feces. I am pretty certain that if I were allowed to use my own dried herbs, that sort of thing would be kept to zero.

If there is a place to rectify this situation in the Wightman recommendations, it would be helpful.

"Its because the farmers pushing for raw milk legalization don't care about cheese. And frankly, many of them don't care about food safety either, in my experience. This "free-for-all" mentality will only lead to the downfall of raw milk as outbreaks create a public backlash."


Just because we are against regulations does not mean we do not desire to produce clean, healthy raw milk.

Regulations don't produce safe food, that is neither their purpose nor within their ability. Fortunately the history of regulation also teaches us that we are more likely to have safe food through freedom.

Pasteurized milk is heavily regulated and yet is also the source of many outbreaks and sicknesses. It is dishonest to claim that a lack of regulation is responsible for outbreaks, as if regulation would have fixed the matter. It will not.

As far as small artisan producers go, our present problem isn't a result of a lack of regulation, but rather that we are having to rebuild an entire industry and the new and existing players don't have sufficient knowledge in many cases. (neither do the regulators by the way) This situation wasn't cause by a lack of regulation either, but rather it was regulation that destroyed the many dairy farms that used to dot our countryside who had the knowledge.

The food safety problems we have today are a product of large centralized corporate production. This production environment itself is a product of regulation, regulation that killed off small producers, and protects the big dirty ones. Regulation cannot fix our food safety problems, despite several generations of regulation we still have food safety problems. But we will not have a rebirth of small artisan production in the presence of regulation.

Regulation, licensure and other fascist controls are antithetical to liberty.

We choose liberty.


"Does any one have a definition of a farmer as a person that serves his consumers and the entire food chain?? Not a nearly extinct farmer that just works the soil and gets paid like dirt because that is the only part of the food chain he serves???"

Wow. That's almost as heartless in contempt as Lykke's response to Violet several weeks ago.

So, the only part of the food chain I serve is dirt? None of my customers count, or that in addition I also produce and sell beef, rabbit, three kinds of poultry, chevon and vegetables1? Not all of us have the best opportunities or income or partners to buy into or partners to help us grow beyond our present capabilities such as you have; and not all of us are driven by money and getting rich as quickly as possible; not all of us started as young as you did. Does that mean we are to be marginalized as serving only dirt?

"Doing the right thing is important regardless of the labels placed on you."

Well, this labled "dirt farmer" thinks she's doing the right thing in trying to expose and advance raw milk at a price that as many people here can afford... and feeling content with my labor, hard and backbreaking as it may be... and just as passionate about raw milk as you are, if not more so.

"Ten 40 cow operations... gives the consumer more of a choice... spreads real wealth among more families... creates a more secure food supply... and limits the reach of a possible 'incident'."

Gotta agree with this, but then I'm just a marginalized farmer whose only goal is to serve dirt.


The cheese making process as you are well aware is said to predate recorded history with the process having matured into a highly sophisticate enterprise by the time of the Roman Empire. It is said that Britain has approximately 700 distinct local cheeses; France and Italy have perhaps 400 each.

Do you believe that such a diverse variety of cheeses could have developed under todays current punitive regulatory enforced standards?

Are you implying by your desire for standards that the cheeses of the past including the raw milk, which by the way, were developed and produced under your defined "free-for-all" mentality were of inferior quality?

Ken Conrad

Couple of comments on Mark's comments and other news:

1) "nearly extinct farmer" - USDA's Vilsack was on NPR this morning and said there are 1.3 million farmers in this country who sell as much as $1000 per year "who probably don't make a profit" and therefore need to have jobs outside the farm; another 350,000 in the middle with sales in the low-six figure range (who also need to have non-farm jobs), and a final 300,000 in the big-ag range which produce 80+% of the country's food (no comment about off-farm jobs, since the government supports them). The total is about 2.2 million. Seems to me that the big-ag guys are the ones that are nearly extinct.

2) "paid like dirt" - Mark didn't say nearly-extinct farmers serve dirt, or simply work in the dirt, or even eat dirt. Let's be fair: Mark is totally correct, according to Vilsack - nearly 60% of the nation's farmers probably don't make a profit. Among those 1.3 million are several who post on this blog, and I'll bet some of us are making some money now and then. If so, we appear to be the exception. Especially those producing raw milk (not including me, I just do hay and drink the raw milk) are bucking fierce legal and regulatory headwinds. They are the pioneers, forging ahead by looking back to the best of the past, literally saving society. My hat is off to y'all.

3) The NPR segment was about how farming is one of the few bright spots in the economy. Mostly, of course, this was about selling gobs of soy to the Chinese, but he did manage to say that in addition to continuing to help soy farmers do this (bless his heart, all the soy should be shipped out), "we" (our beneficent government doling out our tax dollars) need to keep in mind that the small and medium sized farms also need help and support. I say, all the help that small and medium farmers need is for government to get the hell out of the way. How about a new needs-test for regulation: if you're getting government support, you should be regulated. If no support, then no regulation. Oversimplified, I realize, but worth some thought.

Finally, I'm continuing the comment on this thread because, in part, I'd like to see us break 100 comments :-).

Happy New Year all.


Your new needs test for regulation is a great idea. I am not however going to hold my breath waiting for it to be implemented.

Those millions of farmers that are supporting their farming operations with off farm income are doing so as a result of, and in defiance of, the governments punitive cheap food policy. Our governments are merely a reflection of societys greed and have been manipulated by the greedy to systematically and aggressively use regulation as a tool to manipulate the independent small farmer out of existence in order that they can acquire absolute control of the food industry.

Our success can only be measured by the amount of sacrifice we are willing to endure in order to preserve our independence and freedom. If we take handouts from the government and capitulate to their rules and regulations we will become slaves. It's an age old balancing act and a never ending struggle.

Ken Conrad

"Wow. That's almost as heartless in contempt as Lykke's response to Violet several weeks ago."

Okay, regarding my heartless comment to Violet a few weeks ago, I apologize. As an excuse, realize the general frustration and saddness watching raw milk farmers support the Hartmann dairy despite its problems (the hypocrisy and lack of responsibility was enough to make any open minded regulator-type give up). If you don't get that, stop reading this comment. Subsequent to my rudeness toward Violet, I tried to relate to her situation and find common ground with mutual goals. That is perhaps the best we all can do.

Others have said it, and I am simply going to reiterate it.

Standards are of a necessity "one size fits all" and they go quickly to regulatory devices, and then, those who have set the standards are those who profit from the implementation of the standards. For example, by certifying, auditing, verifying and charging for those 'services'.

Here's the thing, if FTCLDF will use the standards as a coercive factor by representing those who subscribe to these standards as criteria for representing folks in a legal brush, then haven't they just set themselves up with the same 'job security' that all inspectors insure?

This simply looks like GAP (good agricultural practices) for raw milk and even for direct trade of raw milk. If you're unfamiliar with the requirements of GAP, then please send me an email, and I will send you a document on it.

When you set the parameters under which production and management of individual farms may occur, you have set yourself up to be a regulator by virtually ensuring you will be the arbiter of legal requirements placed by the states in the future.

And we still have the problem of reconciling HP2020 to the 'standards'. That means the same people who have devised them are likely to sit down with the FDA and come up with another "exemption" just like the Tester amendment. And from what I have surmised in the 'discussion' of these standards, the tie in with Cullen Agritech, or raw dairy Monsanto, should not be dismissed so lightly. The correlations evident are very strong.

I think most small farmers are sick of complexes representing them. This same thinking is what set up DFA....Forget it. What we need is open markets and direct trade and the relationship between farmer and consumer.

The thing about testing is that testing in and of itself isn't definitive. There have to concurring tests to validate the results from the initial test or you are not likely to get accurate results. Also, what Aajonus espouses as necessary to building an immune system is important to consider in all of this discussion as well.

This is the organic certification issue all over again. Where did that get us? 2500 page manuals for a $25 per head additional 'benefit'. No thanks.

I think we are smart enough to decide what we want to eat without a panel of "experts" to instruct us. We don't need any more hoops to jump through to effectively regulate our enterprises. Yes, consumers need to be educated, but we don't need an 'illustrious body of experts" to educate them.

Sorry guys, keep your standards, guidelines, suggestions, what have you. I'll meet my own standards, which include the right to control my property, processes, production, and my consumption of food as "I" see fit.