in the Discussion on Health or Hazard |
Total diarrheal episodes annually USA |
217,973,045 |
Total foodborne illnesses annually USA |
48,000,000 |
Annual confirmed foodborne infections from the four "pathogens" (all foods) |
1,937,561 |
Average number of illnesses attributed to consuming raw milk (Dr. Beals, 19992011)2 |
42 |
Average number of illnesses attributed to consuming raw milk (Drs. Oliver and others, 20002008)3 |
27 |
From the perspective of a national public health professional looking at an estimated total of 48 million foodborne illnesses each year;6 or from the perspective of a healthcare professional looking at a total of 90,771 (data from Healthy People 20204) confirmed bacterial foodborne infections each year (about 0.2 percent), there is no rational justification to focus national attention on raw milk, which may be associated with an average of 42 illnesses maximum among the more than nine million people (about 0.0005 percent) who have chosen to drink milk in its fresh unprocessed form.
Using this average of 42 illnesses per year, we can show, using government figures, that you are about 35,000 times more likely to become ill from other foods than you are from raw milk.
Calculations on Relative Amounts of Illness from Foods for persons Drinking Raw Milk
It is irresponsible for a senior national government administrator to testify that because of those forty-two people, raw milk is inherently hazardous, parents should not be allowed to decide which foods they serve their children and milk should be banned across the nation unless it has been pasteurized.
SIDEBARS
Another of the critical myths perpetuated by those who promote fear is that bacteria grow remarkably fast. The most common example used is the statement that E. coli multiplies every 20 minutes; suggesting that this is how all bacteria behave. The implication is that even if there is only a single bacterium, it will rapidly multiply producing alarmingly high numbers to spread infection. Yes, in a laboratory you can get E. coli to multiply that quickly if you put it in its most favorable environment, with abundance of all the desired nutrients, at the optimal temperature for growth (99 degrees F) and the right mixtures of gases. But just for comparison, Listeria monocytogenes divides once every fifteen to thirty-four hours at refrigerator temperatures in packaged meat slices. For the purposes of this discussion, bacteria can multiply, or if conditions are not favorable, they will diminish in numbers. So experiments either show increasing or decreasing numbers over time. In publications they may say "growing" to mean multiplying, and "surviving" to mean diminishing in numbers.
And for the purposes of this discussion, a "source" is a location that has conditions under which the specific virulent bacteria significantly increase in numbers. A "reservoir" is a location in which a specific virulent bacteria is able to survive for some time or has conditions to enable very limited multiplication.
As a physician, I am dedicated to understanding, preventing and minimizing the impact of disease. Gastroenteritis has a real personal impact. Frequent trips to the bathroom, often with terrible abdominal pain, inability to go about your daily activities, lasting for days, is serious. The fortunately rare complications that can occur periodically with the forms of gastroenteritis mentioned here can be horrific and have a devastating impact on individuals and their families. In no way do I wish to trivialize the personal impact of these illnesses. However, all activities have risk. Consumption of any food has some risk of illness or adverse reaction. And the consequence of basing public policy on horrific personal experiences is that all foods will ultimately be banned, and we will not be able to participate in any activity.
REFERENCES
Ted Beals, MS, MD, is retired from the University of Michigan Medical School and Veterans Administration Health Administration. A pathologist with personal interest in dairy testing and safety of milk, he has been presenting testimony on dairy safety in North America for the last several years. He and his wife Peggy Beals are members of the Michigan Fresh Unprocessed Whole Milk Workgroup.
A Campaign for Real Milk is a project of The Weston A. Price Foundation
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AFFIDAVIT
I, Dr Theodore F. Beals, of Grass LaKe in the County of Jackson, in the State of Michigan, in the United States of America, MAKE OATH AND SAY AS FOLLOWS :
I am an expert in pathology including food safety and the biological health and health related aspects of dairy production, and as such I have personal knowledge of the facts and matters hereinafter deposed to, save and except for information imparted to me by other people, in which case I believe the source of information to be reliable and I believe the information to be true.
I earned my Bachelors of Science, Masters of Science and M. D from the University of Michigan in 1956, 1957, and 1966, respectively. I have been licenced to practice medicine in the State of Michigan since 1967. I completed 5 years of specialized residency training in pathology at the University of Michigan in 1971, and am specialty certified in Anatomic Pathology by the American Board of Pathology, which includes Canada. I am widely published, and have been a member or officer of more than 20 professional organizations.
A copy of my curriculum vitae is attached to this Affidavit as Exhibit A
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I have prepared a report dated January 4, 2011, which sets out my opinion on the relative risks to human health posed by fresh unprocessed whole fluid milk ( subsequently referred to as raw milk intended for human consumption) , and on the existence of viable alternative methods of regulating raw milk so as to protect the public wellbeing short of outright prohibition
In the context of milk for human consumption, my experience in pathology deals with microbiology, testing and cellular aspects of disease. I have been qualified to give expert opinion evidence in Court dealing with pathological, biological and health related aspects of dairy, including Court cases in California and Ontario. A copy of the transcript of my testimony in the California case is attached as Exhibit B and a copy of the transcript of my testimony in the Ontario case is attached as Exhibit C to this affidavit. I adopt my testimony as set out in those transcripts as true and accurate.
Throughout history fresh milk from animals has been consumed by huge populations of people in many cultures around the world. If milk had been inherently dangerous, it would have been eliminated from the general diet in the time long before pasteurization was discovered. In fact fresh and fermented milk have been the staple of many of the highly successful cultures over the history of civilization.
In regard to public health there is no science-based necessity for pasteurizing fresh raw milk intended for human consumption. Non-pasteurized milk produced with the intention of human consumption fresh in the fresh state is legally available in 28 States in the United States of America, is widely and lawfully available throughout the European Union and its members countries, and is available in the United Kingdom with the exception of Scotland. With the exception of Canada, every member of the G8 group of counties has made provision for the lawful production, distribution and consumption of unpasteurized milk. In these countries, unpasteurized milk is often referred to as fresh milk rather than raw milk.
Generally speaking countries and states that allow sale of both unpasteurized and pasteurized milk create two separate regulatory streams. The first stream for fresh unpasteurized milk imposes standards for lactating health and hygiene and for sanitation at milking and bottling facilities. Testing for herd health is required as well as regimens for routine testing of milk samples to monitor the quality of the milk and for the presence of possible pathogens.
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9. The intent within the first regulatory stream is to optimize the nutritional and microbiological value of the fresh milk while minimizing the risks to consumers. These regulations are intended to balance benefits with acceptable risks to the general public. The risks for properly regulated fresh raw milk and milk products fall within the acceptable range of risks for other food products and are considered minimal or trivial throughout most of the world. In my opinion, properly regulated raw milk produced specifically for human consumption in the fresh unprocessed form does not impose substantial health risks to the general public.
The second stream of milk production is a separate regulatory stream for pasteurized milk, which is widely referred-to within the dairy industry as industrial milk. In this affidavit, I use the term industrial milk to include milk that is intended for pasteurization ( pre-Pasteurized industrial milk) as well as milk that has already been pasteurized ( pasteurized industrial milk).
Pasteurization is an industrial process that involves complex processing of milk by controlled heating for a period of time. Two of the commonly used temperature/ time standards expose the milk to 145 degrees F. ( 62.8 degrees C) for half an hour or 163 degrees F ( 72.8 degrees C) for 15 seconds. Industrial milk pasteurization was introduced and continues to be used to prolong the shelf-life of the milk for marketing purposes. It is also necessary if the milk is homogenized, since milk that has been homogenized quickly becomes unmarketable. Regulation in the second stream is tailored to the pasturization process. The pasteurization process is designed to significantly reduce the bacterial content of the milk, ( including any pathogens) that enter the milk through the cow or after the cow is milked through the factory farming and transportation processses. Pasteurization also significantly reduces the number of the beneficial organisms and alters the organic substances that are contained in milk, including enzymes, immunologically-active components and vitamins. Pasteurized milk contains the non-living biomass of thousands of micro-organisms, including dead pathogens and altered proteins, enzymes, vitamins and other biologically important components.
All human activity has risk. It is easy to voice the opinion that something is unacceptable unless it is completely safe. However, nothing can be totally safe. From a scientific and risk analysis perspective the question becomes 'are the various risks acceptable?'. This must balance the value/benefits of the activity with the risks. In the present context we are focused on the general public and on food. Consumption of any food has some public risk. But consumption of food is not some interesting pastime, it is an absolute necessity. And consumption of high quality food is directly related to maintaining the public health and wellbeing. Families must consider food choice in the context of their personal health as well as maximizing the development of their children. Therefore acceptable risk when looking at the health consumption of milk must be balanced against the benefits to the public and our families. It is possible to make some calculations based on public statistics and the history of risks from consuming milk. Using myself as an adult male in the general public and the knowledge that I have been consistently drinking fresh unprocessed whole milk that for many years I have obtained directly from farmers that I know personally ( I consume about 182 US gallons / 689 L. per year) I have a greater risk of being injured in an automobile accident on the way to pick up my milk at the farm, than I do from drinking the milk every day,
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Both industrial and fresh unprocessed whole milk being produced for human consumption have been associated with illness in the general public. These illnesses usually make consumers mildly but occasionally seriously ill. The possible risks are very small and do not rise to the level of a threat to the public health particularly when weighed against the benefits.
23. In my professional opinion, fresh raw milk offers significantly greater health and nutritional benefits than industrial milk currently available in the public market. The comparative health advantage of raw milk consumption is most pronounced for the millions of people who have lactose intolerance, but the advantages are also significant for the many people who do not have this condition.
Dr. THEODORE F. BEALS
SWORN BEFORE ME this 4th day of January 2011
in the State of Michigan, in the county of Washington
Deedra G Davin ) _______(signature ) ______________a Notary Public in and for the State of Michigan
Families that drive long distances to obtain farm fresh, unprocessed whole milk want the nutritional and health values they know are present in this milk. They know how important it is for their growing children. There is no controversy over the values of milk in our regular diet. All across the country people are allowed to consume raw milk.
However, families have been faced with the threat that the Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) would shut down the dairies supplying this nutrient dense food. They say fresh milk is inherently dangerous and poses a threat to the public health.
The truth is that fresh milk has been part of the diets of cultures around the world for as long as recorded history. If it was dangerous, people would have quit drinking it long ago. Those obsessed with banning raw milk repeat over and over that people who drink it get sick. What they do not say is how often this happens compared to the risks we face in everyday life.
Millions of Americans are drinking raw milk regularly. Outbreaks attributed to raw milk are extremely rare. Using national data, the risk from injury driving to pick up my fresh unprocessed whole milk is higher than the reported risk of becoming ill from drinking that milk.
The experts agree, many ready-to-eat foods are far more risky than raw milk, but DATCP is not closing down grocery stores and delis.
Those obsessed with banning the sale of raw milk claim that milk is obviously dangerous because bacteria grow rapidly and even traces of contamination will result in illness. Many bacteria, including some that are necessary for our own digestive processes, do grow well in milk. Beneficial bacteria are present in fresh milk and act like probiotics. Pasteurization kills those beneficial bacteria. However, the rare virulent pathogens that can cause disease in some people do not grow well in milk.
All of the textbooks on dairy science describe all of the various components of milk that are altered by heating and they detail the proven destructive effects of homogenization. So why do the industrial dairies pasteurize, some even ultra-pasteurizing? Because the milk takes a long time to move through the system from the farm to the grocery store. It can spoil before it reaches the home.
When you obtain your raw milk fresh directly from your own personal dairy farmer, you know where it is produced. You personally know the farm family. Know they manage their dairy to provide clean milk from healthy cows fed to maximize the nutritional value of the milk. These dairies are proud to show you their pasture, how they care for their cows and produce milk that is intended to be consumed unprocessed.
There is no plan to make everyone drink raw milk. Some families want the law to allow them to choose to buy milk for their growing families that is not pasteurized. They want the choice to find a dairy family that produces the milk that they know is good, pay them fully for the effort they put into providing a safe quality product. And they acknowledge that like everything in life, nothing can be guaranteed totally safe.
Ted Beals is a pathologist who retired from the faculty of the University of Michigan Medical School and the Senior Executive Service of the Department of Veterans Affairs in Washington, D.C. He is an international consultant on milk safety. He and his wife, Peggy, a registered nurse, live in Grass Lake, Mich. They have consumed fresh, unprocessed whole milk from several Michigan dairies for many years. Ted Beals is a pathologist who retired from the faculty of the University of Michigan Medical School and the Senior Executive Service of the Department of Veterans Affairs in Washington, D.C. He is an international consultant on milk safety.