This CA Herdshare Shows There Is More Than One Way to Meet Raw Milk Safety Standards
Licensing. It is an issue that lurks in the background for many small dairy farms that sell or distribute raw milk and other dairy products. People frequently assume that licensing is not only straightforward and doable, but essential—a governmental stamp of approval that presumably ensures a certain minimum level of quality or safety. But there’s more to licensing than meets the eye, especially when it comes to raw dairy. In this guest post, California herdshare operator Shawna Barr explores some of the challenges with licensing for small dairies.
by Shawna Barr
We may soon hear from opponents of the proposed California Home Dairy legislation (described in the previous post), suggesting that small farms just get a license like the rest of the dairy farmers in California. I remember the prosecutor in the Vernon Hershberger Wisconsin licensing case, in his closing arguments, say something similar. “Just get a license! Its only a few hundred bucks!” Why should small farms receive special treatment and not be required to follow the rules?
Here is the problem with that argument: dairy licensing requirements in California (and elsewhere) make it nearly impossible to build a financially feasible Grade A milking and bottling facility for three cows. Or for fifty cows for that matter.
My discovery began six years ago, when we discovered how productive a family milk cow can be, and we considered selling our excess milk to eager neighbors. I thought, “I’ll just call the state and get a license. How hard can it be?”
The answer is: very hard. The California Department of Food and Agriculture (CDFA) informed me that I would need a from-scratch building designed specifically to the exhaustive California Grade A dairy guidelines. The price tag was a minimum of a quarter million dollars. If I planned to bottle my milk on site, I would need an additional facility for additional thousands.
As part of this preparation process, we would also need to bulldoze our existing barns and start over.
Since those figures didn’t pencil, we did what many other owners of small farms have done around the state. We formed a private herdshare and began operating under California’s “private home” exemption (allowing milk production for private consumption). Suddenly, like a page ripped from Joel Salatin’s “Everything I Want to Do is Illegal”, we found ourselves operating on the far edges of the law.
That was never our intention, though. We would have much preferred to “just get a license.”
Perhaps most ironic, and frustrating, is the fact that we already have great facilities on our farm that have proven completely adequate for producing high-quality milk on a small scale. Our fully enclosed barn has concrete floors, good lighting, hot running water, and a dedicated clean room for washing our equipment and jarring our milk.
Our cows enjoy clean, dry winter housing, lush green pastures and more than an acre of land each. When co-owners visit the farm every week, they expect cleanliness, sweet smells, butterflies, flowers, green grass, and slick, bright-eyed happy cows. We give them every bit of that.
I concede that micro dairy farms have infrastructure considerations. We have management issues just like large dairies. However, our management methods and facilities can be quite different. In other words, there is more than one way to cleanly and safely milk a cow.
For example, it takes considerably less water to wash a bucket milker with three feet of milk hose and a one-cow parlor than it does to clean a pipeline system and a 100-cow parlor. We use about 10 gallons of hot water to wash up after each milking, simplifying waste-water management. We don’t need flush alleys because we manage manure by hand using deep carbon bedding and a small front-end loader. Most manure falls in the pastures anyway.
Our maximum daily production is about 25 gallons of milk. That is about .3% of what is produced daily on an average-size California dairy. For us, it is easy enough to wash jars in a sanitizing dishwasher, fill and lid them by hand, and place them in an ice water bath to cool. A $10,000 bottle capper and bulk tank is way overkill.
Even in the absence of the required 25 feet of concrete flanking for my barn, and of the paved, curbed and graded lanes that flush into a lagoon, our system is working well. In six years we’ve never had an illness outbreak. Our Standard Plate Counts run under 500 and our Coliform counts are regularly zero. Co-owners enjoy milk that stays fresh for two weeks or more.
Quality and safety standards on the small dairy are essential, and should be at or equal to those required of Grade A dairies. However, those standards are best met when there is freedom to innovate with appropriate methods to match the size and scale.
California does not yet offer that freedom to small herd dairies. There is only one way to legally milk a cow, and it requires hundreds of thousands of dollars in infrastructure. As a result, many otherwise law-abiding small farmers participate in this form of soft civil disobedience. It is our cry for regulatory reform, and perhaps the only means we have to evoke change.