Open Letter to FDA’s Dairy Head, John Sheehan
By Steve Bemis, Esq.
I have to give you credit, Mr. Sheehan, for playing your cards close to your chest as the chief FDA enforcer out to ban raw milk. You’ve carefully directed that FDA avoid any semblance of dialogue on the topic of raw milk consumption, and now I think I know why: FDA knows too much, and doesn’t want to risk having to answer a simple question: How Many Americans Drink Raw Milk?
The answer to this question is hugely significant to an intelligent evaluation of the supposed risks in drinking fresh, unprocessed raw milk. This evaluation, this dialogue with the American public, has had nothing but deus ex cathedra pronouncements from FDA and CDC since the earliest crack-downs on raw milk farmers and distributors beginning in the 2006 time-frame. The number who drink raw milk is the denominator that is missing to give perspective to the several dramatized cases of illness and the drumbeat of CDC reports of total numbers of illness. Being sick is no fun, and not to be minimized. But neither should such cases be maximized without a frame of reference – particularly when the “data” are being used to drive public policy and restrict freedom of choice.
Come to find out, FDA has probably known the answer to this question since at least 2008, and probably since CDC got the data from their own Population Survey Atlas of Exposures, conducted in 2006-2007 (a similarly-titled Survey dates to 2004, although I have not reviewed it). In fact, it now seems more likely than not that FDA knowledge of the number of raw milk drinkers was the stimulus for the sudden escalation of crackdowns in 2006-2007 in Ohio, Michigan, New York, California and elsewhere. The cow was escaping from the CAFO! Quick, close the gate behind her!
I was made aware of the 2008 survey when Dr. Ted Beals distributed the above link to the detailed CDC source. The survey was conducted under the auspices of FoodNet, a collaborative network established in cooperation with a program (EIP, Emerging Infections Program) of the CDC; state health departments in CA, CO, CT, GA, MD, MN, NM, NY, OR and TN; FDA’s own CFSAN; and the USDA’s FSIS. It was huge, conducting telephone interviews with 17,372 interviewees representing a population of 45,883,553 people in the listed ten states, from May 2006 to April 2007. It was undoubtedly expensive, paid for by taxpayers, conducted by an independent contractor (Clearwater Research, Inc.), and it created statistically-valid state-by-state and total percentages for scores of foods of all types, from potato chips to hamburgers, from lettuce to brussels sprouts, and from tomatoes to raw milk. There is little doubt that this survey is sufficiently representative to extrapolate to the entire country.
Based on the CDC’s own survey, the average number of people drinking raw milk in this 2006-2007 sampling was 3.0% of the population, ranging from 2.3% in Minnesota to 3.8% in Georgia.
The population in the United States in late 2007 was about 302,000,000 people. Thus, if someone drank raw milk 3 years ago, he or she was among NINE MILLION RAW MILK DRINKERS. If the rate has increased today to, say, 4.0%, a raw milk drinker (the survey sampled all ages, including children under 12) is among OVER 12 MILLION. With increases in raw milk consumption in recent years, there is no doubt the number of people consuming raw milk exceeds 10 million.
Raw milk illness data are a constantly moving target. From what I have read, the number of reported illnesses from raw milk, excluding queso fresco and similar raw milk soft cheeses, could vary anywhere from approximately 50 to 150 per year over the last 15 years. There were no deaths reported from consuming fluid raw milk over this entire period. Using the 9 million raw milk drinker universe and 50-150 annual illnesses, this suggests an annual raw milk illness rate in the range of 0.001% to 0.002% of raw milk drinkers. It may be more, since not all cases get reported (which usually means they are minor, raising questions about the real cause of a stomach-ache). But, it’s probably significantly less since the number of raw milk drinkers (there’s that pesky denominator again!) has certainly been increasing sharply in recent years. So, FDA and CDC, what is the current number of raw milk drinkers? I’ll bet you know, or have a pretty good guess.
On the other hand, who cares what you know? I’ll bet I know at least 10 million answers to that question.