Friday, May 6, 2011

FDA Overreach: Blocking Raw Milk Sales

I have not posted since December 2009; I'm delighted to see hundreds of readers have visited the blog in the interim, and I promise to post on a more regular basis.

I have a separate libertarian-conservative political blog which I've been posting on a nearly daily basis; the reason I'm mentioning this is not to promote the blog but to provide a context. I believe I'm responsible, not the government, for maintaining my health, including my diet and exercise lifestyle choices. I think there's a cost and benefit analysis relevant to government intervention in the marketplace. These regulations often have the effect of restricting consumer choice, and regulatory costs must be passed along to the consumer.

Clearly we have safety concerns (e.g., Salmonella, Escherichia coli, and Bovine spongiform encephalopathy); these dangers are not transparent to the unsuspecting consumer. There are a number of potential issues from farm operations to food or feed processing, e.g., unhygienic food preparation (unwashed produce, unclean hands, pest problems, improperly thawed foods, overexposed cooked foods, etc.), inadequately maintained/cleaned equipment, infected manure fertilization, contaminated water irrigation, insufficiently heated foods or feed processing, and meat, eggs or milk from ill animals. We have typical audit standards: the extent to which farmers, food processors or restaurants can document ongoing compliance with industry safety standards and/or relevant regulations (for example, we heat feed to a temperature guaranteeing any harmful bacteria are killed) enables federal or industry inspectors/auditors to devise an audit plan (such as checking and validating the purported temperature measurement). If, on the other hand, there is no documentation of standard procedures or ongoing record keeping at sufficient detail, we may need to expand the nature of the audit plan. And obviously if there are no verifiable effective controls in place--whether it's inadequate separation of diseased animals from production processes or produce or manifestly unkempt kitchens or facilities--we may need to suspend operations until compliance can be verified.                                  

I also believe that regulators should attest to certain marketing claims made by businesses, e.g., this fish is wild-caught (versus farm-raised), younger (versus older) or was caught in Alaska, this produce is organic, or this chicken was processed air-chilled (versus standard water-immersion). [As an aside: younger and/or wild-caught fish are thought to have lower metabolized exposure to mercury or other contaminants. I don't have any business relationship with SmartChicken (see above link); my Columbia, MD Safeway once had their whole chickens on special, and I tried one and was blown away by the difference in taste versus, say, your 88 cents/lb. roaster on sale at Sam's Club. It's pricier (roughly $8 per 3 lb. bird); if you are interested, they have a store locator or you can order directly.]

Several years ago my middle sister married a high school sweetheart. My brother-in-law's father operates a small ranch in east Texas raising a few livestock. I went to visit them in married student housing at a nearby university, and while I was there, my sister prepared this roast, which she informed me came from "Blue Eyes", one of her father-in-law's grass-fed livestock. The meat was perhaps a little tougher and tasted somewhat different from the supermarket beef I was used to buying, but I liked it.

So flash forward several years to around 2003 when I started paying more attention to my diet and started looking into nutrition more seriously. I never had glaring deficiencies in the sense I was never a big purchaser of snack foods or or sugary items or desserts (about the only time I eat them is on social occasions, e.g., refreshments at breaks during a training class); I almost never eat out unless I'm traveling on business. But it was clear I didn't really have an appreciation for the value of dietary balance and  nutritional diversity of various fruits, nuts, and vegetables, the effects of refining various foods (e.g., the fact that regular white bread has been stripped of various nutrients available in whole grains) and the suboptimal effects of a starch-heavy, lower-fiber diet, particularly on those of us with a propensity towards weight gain.

One of the things I blackboxed was the effect of the product life cycle. I, of course, had heard the old saw that "you are what you eat". But, for instance, I knew about dietary concerns over excess consumption of saturated fat, but I didn't realize that most supermarket beef was conventionally finished to make cattle fatter (i.e., to improve the taste of the beef, with the satiety effect of fat). In order to do that, they feed foods not metabolized well by cattle (such as corn). Corn and other foods are rich sources of omega-6 fatty acids, and we have seen the optimal omega-6 to omega-3 fatty acid ratio explode in the American diet over the past few decades--which I personally believe correlates with the higher incidence of obesity in Americans.

One alternative is to get back to a more healthy essential fatty acid ratio is through more traditional diets:




I have purchased some grass-fed meats locally, but I remembered my sister's roast and felt (given the premium pricing) if my brother-in-law or his father ever decided to competitively market their beef, I was willing to throw my business their way. In fact, over the past year or so, it looked like my brother-in-law was considering a second career raising beef. My sister gathered a number of grass-fed beef recipes, and my niece, a graphics designer, had put together a website extolling the ranch and a business logo. But suddenly his business model changed, aimed more at marketing conventionally finished and processed premium cuts of beef at very competitive prices from other suppliers.

I was confused by the change in his business model; he explained that to sell meat across state lines, he had to go through a USDA inspection process and given his smaller operation, that wasn't feasible.



Now the observant reader may be wondering, what does grass-fed beef have to do with my post heading dealing with raw milk? The same type of  "you are what you eat" considerations apply to the milk you drink. For example, the rancher in the above video references CLA; CLA is proportionally available in raw milk produced by grass-fed cattle, e.g., by the Amish.



The FDA has decided to protect residents of Maryland and Washington DC from the health benefits of raw milk produced by an Amish farm, Rainbow Acres, in Pennsylvania by blocking its sale. For your convenience, I'm embedding the guest editorial below:

Guest Editorial: IBD, "Raw Deal"



My personal opinion? The editorial is spot on. Instead of the federal government pushing on a string to prevent giving consumers a healthier alternative to Big Milk, they should stick to their core competencies of regulating Big Agriculture instead of targeting the industrious small business Amish farmer, whom drinks his own milk and knows his sales are dependent on maintaining the quality of his product.