The Family Cow – Raw Milk Safety and Government Manipulation
July 2nd, 2013 | Food Security, Our Food, Raw Milk, Edwin Shank, FDA, food safety, grass-fed, Mark McAfee, PA, The Family Cow
The following article is reposted with permission. It is Edwin Shank’s personal exploration of what may be going on behind the scenes of North American government regulatory departments in regards to their accelerated paranoia around raw milk. The Family Cow prides itself in utilizing cutting edge technology as well as traditional animal husbandry in producing the cleanest, pathogen-free raw milk that money can buy. Please read on…
The Family Cow raw milk is proven pathogen free…it’s back at all the drop-points and farm store…ecstatic parents and children are giving us hugs and high fives…raw milk demand is stronger than ever…maybe we should just let the matter rest. Believe me! A very insistent part of my gut argues to move on and forget it. The wear on our family that week of the recall, was unbelievable, and now we just want to rest.
It affects us this way, I guess, because we really are a community of connections and relationships. It’s the price we pay for making you a part of us. We really do care. We do love your families and we take any accusation or implication about our food safety to heart personally.
But the time to rest is not yet. Dawn and I discussed this at length and we feel The Family Cow Families deserve answers. You shared our stress and suspense that week as true friends. You prayed for us. You also care and deserve to know.
Please bear with me though. I have never struggled with so many conflicting feelings as I honestly try to share the knowledge I have. I started this email five times and aborted all of them at about 500 words. (By the time you’re done with this one you might wish I had aborted it too!)
One of the reasons I’m struggling to answer the “What Happened” question is that we ourselves are puzzled by the conflicting information we received and are still trying to make sense out of it.
But without a doubt, the greater reason I’m struggling is that we are uncomfortable going where this question seems to lead. It is touchy ground. Touchy because to be truly transparent with you, I am obligated to share a strange sequence of events that maybe has nothing to do with anything. But then again, it maybe explains everything. You will have to decide since only God and the State* know and neither of them are talking.
Let’s start with a chart I created to help you understand what we mean by conflicting information about The Family Cow raw milk hygiene. I know most of you are not accustomed to microbiology reports and standards, so as a reference, I include PA raw and pasteurized milk standards along with the standards of three other states where raw milk is legal. It is important for you to at least have a reference point so you can grasp, in numerical form, exactly how clean The Family Cow raw milk was and is. Here is the chart.
This is the scientific evidence of clean milk folks! Do you get a sense of our frustration? Something is funny here. It’s impossible for the same milk to be both hygienic and pathogenic! We test every lot of milk we sell and these low bacteria numbers are not unusual. They are typical of the day to day super cleanliness of The Family Cow raw milk. It’s the result of an intense, intentional focus on a food safety protocol developed especially for the health and safety of your family. (We actually post pictures of Family Cow families and children in our milk house, bottling room and laboratory to reinforce our focus and culture of food safety.)
And then there is the anecdotal evidence of clean. It’s no secret. Family Cow raw milk stays fresh for two weeks…or even longer. This, by itself, is compelling evidence. Those experienced with raw milk know that only super clean raw milk will keep fresh for two weeks. Some experts say it’s impossible, unreasonable even. Smile…you and I both know better!
But all this is beside the point. The “White Elephant Question” is still in the room. Here is the way most of you are asking it. “Was this an attempt by the anti-raw milk regulators to terrorize “scare off” raw milk drinkers (and raw milk farmers too) in an effort to curb the astonishing nationwide surge of raw milk interest?”
I really do not like this question. I’d rather not go there and in fact came very close to refusing to go there. (Notice: I have held back for a month!) An uneasy foreboding warns me that it might not even be safe to air this question. And that is sad. Besides, I do not enjoy being suspicious. I’d rather love and trust.
But then I remember: this is not my question. This is your question. In fact, this is your main question and we faced it probably 50 times a day at first. My guess is that 90-95% of Family Cow families have thoughts along this line. So to be fair, I owe it to you to at least acknowledge the validity of your question and do my best to objectively, openly share the events on the past months in the order our family experienced them. But please do not ask me to form a conclusion. That’s your job.
In order to keep the facts, dates and data as concise, objective and un-sensational as possible, I have put this sequence into time-line format. This way you will, hopefully, be able to relive, as nearly as possible, what our family experienced. As Family Cow Families you are part of us and you will only understand if you put yourselves in our shoes and live it with us.
April 11th – We announce, to 5000 families via e-newsletter, that Mark McAfee is coming on May 18th to “Share the Secret” about the healing powers of raw milk. We note that Mark will be teaching nutrition information that he cannot put on his website or the FDA would fine him. Thankfully the “Freedom of speech” protects him at a public meeting.
April 26th – CDC releases a study aimed particularly at regulated raw milk dairies. They conclude that, because illness occurs at times, even at state-regulated raw milk dairies, therefore, this proves that it is impossible, even with regulation, testing and carefulness, to safely produce raw milk.
May 3rd-5th – Several raw-milk-expert-friends from 4 different states contact and warn us that this obviously biased CDC report is a very strange and unusually bold move. (No other food industry would allow them to get by with officially declaring their industry’s food as impossible to produce safely. They would sue them for libel!) Our friends warn us that it looks to them like a prelude to some kind of action. They warn us particularly because our farm was used as the basis of the study.
May 5th-8th – I am not worried and responded (naively maybe) to several of the concerned friends in this spirit:
“Hi ____, thanks for your kind words and support. To be honest I’m not paying very much attention or losing sleep over what the CDC is saying. They just simply do not matter. They are of no consequence. It’s background noise. While they self-importantly sit in their cubicles shuffling papers, doing studies to conclude that it’s impossible to produce safe raw milk, we just keep doing the “impossible.”
Our April 2013 raw milk sales were 110,000 servings. So if you extrapolate backwards for the last 15 months (use 80,000 servings as the average month because raw milk sales grew 50% in 2012), The Family Cow has supplied over 1.2 million servings of raw milk…Safely. Our growing tribe of ecstatic east coast moms can verify this. Those who say it cannot be done need to get their heads out of the sand and come and see how it is done!
But really, this is just normal revolution history. Think Galileo, the moons of Jupiter and the bishops…Columbus and Magellan and the flat earth experts…Wilbur and Orville Wright…Dr. James Lind and lemons to cure scurvy. Pioneers are always thought to be crazy. Their vision, passion and life’s mission is always declared impossible by the establishment and the rabble until it is done. Wasn’t it Gandhi who said something like: “First they ignore you…next they laugh…then they fight and then… you win!” My personal observation is that we are entering the winning stage.
But we do understand that we absolutely must produce raw milk safely. That is why we installed our own raw milk laboratory, established our test and hold protocol and embraced ProAct computer monitoring for all of our critical control points for raw milk safety. So again, thanks…but don’t worry about us. ~ Edwin
The raw-milk-expert friends reply with increased warnings. Here is one from May 8th.
“Hi Edwin, Rest assured that I am not “worried” about you. I fully understand that they are coming at you in the press, precisely because they’re afraid you just might figure this thing out and minimize risk to such an extent that we can truly say that the Earth does revolve around the Sun! … I raised the issue because I think the current situation might provide you with some opportunities for even more positive publicity about how you are managing your operation, but also because I do know, in a very direct way, just how serious they are about this stuff right now. If you’ve studied scientific revolutions, as it sounds like you have, then you know that the risk is always greatest (i.e. heads roll) just before the biggest attitude changes occur. So while I’m not worried, I also think you should have your eyes and ears wide open right now, because there’s a bit of desperation in the voices of those who are against raw milk and have some power to do strange and unpredictable things. How about if we agree that I’ll keep watching for threats, and you keep doing what you do?”
May 8th – My comments on the CDC study (and the probably foolish challenge for them to come for a visit) are published (with my permission) at a national raw milk forum/blog that I know is monitored by regulators. From there the comments are picked up and reprinted by several other online forums.
May 17th – The State Regulators arrive at our farm store unannounced, take samples from our refrigerator, and inform us that they have established an “association/link/correlation” between two Family Cow raw milk drinkers and two cases of diarrhea caused by campylobacter. They ask us to halt all raw milk sales. (Ask, not tell, because they must have a positive pathogen test to force us to close.) Correlation however does not establish causation, especially with something as common as campylobacter. (It is estimated that there are 2000-3000 cases of campylobacter per month in PA.) So we thank them for their recommendation but politely decline to halt sales. We are totally confident in this decision since all testing for well over a year has been 100% pathogen free, and also since, by our own lab testing, we know exactly how super hygienic the very milk in question is.
However…to double check on the State’s pending lab work and to keep them honest, we select a 2nd pint of our raw milk (with the same cap date that the State took) and rush it via courier to a third-party state-certified laboratory. (We do third-party-verification testing when under State surveillance… false positives and human error are always possibilities, we know. “Trust but Verify” only seems to be expedient.)
May 18th – The Family Cow team, together with the WAPF, holds the Mark McAfee “Share the Secret” meeting. David Gumpert, author of the just released Life, Liberty, and the Pursuit of Food Rights, is also there to update us on the Vernon Hershberger raw milk trial. (Wisconsin is trying to put this Amish father of 10 in jail for selling raw milk.) It is a great all-day success with several hundred enthusiastic moms, dads and children in attendance including 10-15 other raw milk and cheese farmers. (We are especially honored to have two ex-apprentices from Joel Salatin’s PolyFace Farm in VA with us.) Some families drive 4 hours one way just to be there. People came from all over PA plus some from NYC, NJ, VA, and MD. My wife Dawn and my daughter Gwendolyn and some of our Family Cow team serve a 100% organic feast of grass fed roast beef and woodland pork, organic homemade breads, raw butter and cheeses and free Family Cow raw milk pints were served to everyone. I think we gave away 250-300 pints.
May 20th – Early this morning, the third-party-laboratory that we use to double check the State’s work calls us. They shock us by announcing that they cannot do the pathogen testing for us. I ask, “Why not…what’s going on?” They report that a State inspector has ‘decertified’ their lab. I ask “why and when?” They say that about a week prior, the State insisted that they need to update their SOP paperwork and that their lab will be decertified till it’s done and state-approved. The lab also informs us that they are the only lab in PA that is certified to do official campylobacter testing. We regretfully tell them to discard our raw milk sample as it is clear we are out of options.
May 23rd-24th – I feel moved to write “The Hangman” newsletter. The letter is a call for support for the Vernon Hershberger family who are in the middle of their raw milk trial, but it is also a semi-desperate effort to warn you of our suspicions and a personal cry of help and support for our family. We, in spite of our normal optimism and goodwill, even toward the government, increasingly sense an uneasy foreboding that this just might be a set-up. (I guess, the coincidence of our double-check lab being shut down along with these other coincidences is starting to send the chills down our backs.)
May 26th – We start breathing again. We have heard nothing and this is day 9 since the State took the sample. Pathogen tests do not take anywhere near this long. (3 days is normal, 4 days max) Also the sample had a “best by” date of 5/26 and is now outdated. We must have been just imagining things. We feel a little silly.
May 28th – The State calls and reports a pathogen find. They issue an immediate cease-and-desist order, and put out statewide press releases. They have had the sample 11 days. The milk they tested had a “best by” date of 5/26. It has been out dated for two days.
June 4th – After a week of extensive additional pathogen testing on our raw milk, stress levels through the roof, lost sales and after all 9 separate tests come back 100% pathogen free, we are given the go ahead to resume sales.
We lost over $15,000 in sales during the week we were shut down, but even worse, (and I’m ashamed to say now) at one low point, we almost lost our resolve to go on. I mean, after all, if it was a setup, (and we do NOT know that it was) but IF it was, how can we ever fight a thing like that? It was your prayers, emails of love and continued confidence and unwavering dedication that brought us around! Thank you forever!
So that is what we know, folks. I’m not going to say much more. You will have to decide what you think. I honestly do not know what to think. I do understand and acknowledge that all of this could have been a total coincidence. I’m not casting any blame… just telling you how it felt to live through it.
Whatever your conclusion, please, we ask that you do not adamantly accuse any government agency of wrongdoing no matter how convinced you are. Our family tries very hard to honor and respect the government where we can. So please honor us in this.
We understand if this incident is upsetting and you burn to do something, anything, to help us in this food rights battle. Believe me, there is a lot you can do! But it is easier and more peaceful than you imagine. Simply support our family and raw milk even more than before! Make raw milk your active political statement! We need it… this battle is wearing! Continuing to support raw milk is absolutely the most effective action to confound the food police. Nothing defeats and discourages them more than to see raw milk farmers prospering and even more families switching over in spite of their efforts. It literally drives them crazy.
Also effective: Forward this letter to others who could support us and other raw milk farmers. This type of support is, without a doubt, the most effective, most powerful, most peaceful method of change that exists anywhere. Love and positive energy is always stronger than anger and negatives. We do not and simply cannot and will not accuse the government. We just simply do not know.
But, in spite of all we don’t know…we do know two things very emphatically.
One is that we are keeping our eyes and ears open wider than ever. (And you will not be surprised to learn that we have established a plan that does involve multiple back-up labs.)
But the most important thing we know is that our family vision is still on course. We have not flinched (well, not very much). We have faith that we are on track to our true north and we will not vary. We forge ahead with our life’s mission, and passion and by God’s grace, continue to grow the cleanest, safest, tastiest, purest, healthiest raw milk from grass-fed Jersey cows and deliver it straight to your family.
It is hard to make a perfect thing better… but we’re working on it!
The Shank Family
Love ~ The Family Cow Farmers
~Edwin & Dawn Shank and Family
We realize this article may only serve to raise more questions. But in light of the complexity (and the fact that we have work to do to grow your food!) we will not be able to answer more on this subject. Feel free to email us with your thoughts, we will read them all but we regretfully will not be able to respond.
In the section below, we tried to answer a few questions that you may have.
Q. But weren’t there several campylobacter cases confirmed to be caused by Family Cow raw milk?
A. Adamantly, No. There was no illness confirmed to be caused by our milk. There were several people who were confirmed with campy who were also customers of ours. But that is not at all abnormal given the broadness of our customer base and the prevalence of campy in the general populace. (It is the most common diarrhea causing bacteria in the world.) If any of you had a food establishment that feeds as broad a demographic as we reach, and if I had access to the government’s PulseNet database, and wanted to make your life difficult, I’m sure I could ‘find’ and publish several ‘links’ any given month of the year from among your customers.
PS. If you’re new to our farm and family, I’m sure this letter could look like we just can’t admit the possibility of error on our part. If you are thinking that way, please read our story of how The Family Cow raw milk came to be the safest, cleanest, most thoroughly tested raw milk that money can buy anywhere. (Our average hygiene test proves our milk to be 10 to 20 times cleaner and safer than pasteurization milk and the State’s test back us up on that, so I’m not just blowing smoke.) Reading our trial-by-fire history might help to balance your impression of us.
*The Regulatory Tangle
It is difficult to concisely explain the regulatory complexities surrounding raw milk, even in PA where raw is legal. In the above article I have broadly used the word State for any and all government regulatory agencies federal and local not specifically the state of PA. Here are a few notes to (imperfectly I’m sure) attempt to explain the position and influence of various agencies as we understand them. Take it for what it is worth. I apologize to any agency if I imperfectly describe your position.
FDA – Food and Drug Administration: Federal agency that publicly states their agenda in “Healthy People 2020” to reduce the number of states where raw milk is produced and sold legally by 2020. The FDA position is that no one at anytime, anywhere should consume raw milk. They argue that we the people do not have a right to choose which foods to feed our families. It is anyone’s guess at how they fund, plan and strategize to accomplish this no-secret goal.
CDC – Center for Disease Control and Prevention: Federal agency that also opposes raw milk in any form. The CDC works hand in hand with the FDA
PDH – PA Department of Health: State agency that opposes raw milk. Some of PDH personnel double as CDC personnel. Of the three PDH people that I’ve had the personal privilege of knowing, two of them also hold positions at the CDC.
PDA – PA Department of Agriculture: This agency is for the most part our friends. It them that we can thank that PA has legal raw milk. The PDA inspects, test and permits around 160 raw milk farmers and cheese makers across the state. There are some personal variations with in their ranks of course, but the PDA in general could be described as raw milk friendly. (as long as we stay within their guidelines) For example: The inspector that comes out to the Family Cow, was raised on raw goat’s milk. His family owned and operated PA permitted raw goat dairy and cheese facility.
All of these agencies are supposed to work together for the health and wellbeing of Americans. Yet there are obvious major conflicts of interest, goals and agendas. We (and other raw milk farmers) as law abiding, tax paying citizens, doing-our-honest-best-to-comply-with-the-regs, often feel we personally have become the battle ground where each of these powerful, wealthy agencies try to exercise their will, display their strength and defend their ego.
It would be really nice if they would take their fight somewhere else.
All we want to do is to be left alone to grow and deliver food of integrity for our friends exactly like we feed our own family!
Note to the News Media. I know you are on this list and that is perfectly fine. But this is an explanation and discussion intended for Family Cow families only. So please understand that you are not permitted to print or report in any way from the content of this personal letter to our friends.
Thank you. – Edwin Shank
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