From: James McLaren
To: Philippe Laroche
Sent: Monday, September 22, 2008 10:10 PM
Subject: Quebec's new raw milk cheese regulations and Raw Drinking Milk
Thank you for our telephone conversation about my inquiry with Andre
Jean regarding the new Quebec raw milk cheese regulations and Raw Drinking
I am a consumer with a mission to see Raw Drinking Milk re-introduced
into either the Canadian or the Ontario marketplace. I have been working
on this since 2000 and the full history of our activities is documented
There are two approaches to achieving this goal. One approach is called
"cow-sharing" whereby consumers buy a share of a cow and pay
someone else to look after it for them. Cow owners may then consume
their own raw milk. The legality of this method is now before the courts
with the trial of Michael Schmidt in New Market, Ontario.
However, I am arguing for a second method, "official recognition
and regulation" because outbreaks will then be attributed to the
failure of dairy farmers to follow prescribed procedures rather than
sanctioning the whole idea of drinking raw milk, as is the case now.
The recent Maple Leaf listeria outbreak closed the Maple Leaf plant
but did not shut down the sale of all cold cuts.
We filed a proposal for Raw Drinking Milk with Health Canada in 2003
but it was rejected. We then met with Health Canada to find out why
and it was explained to us that Health Canada would only change the
law if we filed an application in a particular manner, i.e. with lab
tests and production procedures defined in a prescribed manner that
would permit Health Canada to assess the safety of a specific method
of producing Raw Drinking Milk. This was outlined more fully in another
meeting on September 13, 2005, a summary of which is attached (click
On July 30, 2008, Quebec introduced new regulations to permit the sale
of all raw milk cheeses, not just those that were aged for at least
60 days. The 60-day rule ensured a kill-off of all harmful bacteria.
On August 2, 2008, an article in The Gazette explained that a new category
of safe raw milk was created for the new raw milk cheeses. I thought
that this milk would also have to be safe enough to drink raw and I
wanted to find out if this was true. From my earlier discussions with
Health Canada, I assumed that Health Canada had signed-off on the new
Quebec regulations, so I called Blossom Leung in your group to find
out who to speak with. She told me that Andre had been closely involved.
In my first conversation with Andre he explained that Quebec went ahead
on its own with the new regulations with the proviso that sales would
be limited to Quebec only. He said that he was in touch with Quebec
on their initiative and that Health Canada was now working to amend
the Food and Drugs Act to include the Quebec initiative and thus make
it available for the rest of Canada.
I then asked Andre about the new category of safe raw milk required
by the new regulations and whether or not it was safe to drink raw.
He said no because in cheese making, lactic acid is introduced which
competes with any harmful bacteria and kills them off.
I decided to research his statement and found out that it is wrong,
which thereby proves that this new category of safe raw milk is safe
enough to consume raw.
I first spoke to Margaret Morris, a well known cheese maker who also
teaches it in Eastern Ontario. She said that you introduce lactic bacteria
which make lactic acid which does compete with any harmful bacteria.
But she also said that her target ph is 5. I then spoke to a dairy goat
farmer who acidifies cows' milk to feed the baby goats. His veterinarian
cautioned him on this procedure because harmful bacteria can survive
to ph 3.
What this means is that the process of acidification in cheese making
is insufficient to ensure a kill-off of all harmful bacteria. Therefore
the raw milk which goes into making the cheese in the first place has
to be safe enough on its own for direct human consumption, i.e. it is
also Raw Drinking Milk.
I called Andre back to discuss this and when I challenged his original
statement he directed me to speak with your group.
At this point I would draw your attention to the attachment (click
and the thorough testing that Health Canada said I would
have to go through to begin the process for legalizing Raw Drinking
Milk. I therefore ask if Health Canada is going to go through these
same detailed procedures itself in its approval of the new Quebec
regulations for inclusion in the Food and Drugs Act? And if not, why
not. And if it does, then will it also declare that this new category
of safe raw milk is safe enough for direct human consumption, i.e.
Raw Drinking Milk? And if not, why not.
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