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Health Canada Meeting of April 4, 2005

Attendees for Health Canada:
Paul Mayers
Jeff Farber
Ron Burke
Hélène Couture
Nora Lee
Karen McIntyre

Attendees for Natural Milk Coalition of Canada:
Sally Fallon (president, Weston Price Foundation)
Marcus Koenig (organic farmer, Weston Price local chapter leader)
John Sorchen (consumer who home pasteurizes raw milk)
James McLaren (president, Natural Milk Coalition of Canada)

Location – Building 7, Tunney’s Pasture, Ottawa from 2:30p to 4:45p

Introductions were made by all in attendance.

Sally Fallon presented her PowerPoint presentation on a projected screen. She covered the following topics:
- Health benefits of raw versus pasteurized milk
- Safety of raw versus pasteurized milk and milk products
- Legal issues
- Trends in various US states and overseas
- Comments on Paul Mayers letter of Feb 23/05 to Dr. Gould

Marcus Koenig then described the ready availability of raw milk in Switzerland and Austria. He was a Swiss national before immigrating to Canada. He presented a picture of a consumer raw milk vending machine, which are in common use there and described its operation.

John Sorchen grew up in Austria where he pasteurized raw milk for family consumption. He firmly believes in pasteurization but wants to do it himself rather than commercially because the milk tastes much better. He finds it difficult to buy raw milk in Canada, unlike in his native Austria because of farmers fear of the present law. He presented a $30 double-walled aluminum pot that he uses for home pasteurization. It is designed specifically for home pasteurization and heats to the correct temperature without risk of boiling over.

James McLaren presented a 1-page summary of the major aspects of raw milk distribution that would need to be addressed for thorough regulation in a Canadian context. He then restated his earlier proposal for Health Canada to study a Canadian dairy farm that distributes 70.000 litres annually of raw milk and dairy products.

Mr. Mayers advised that if he knew of such an operation he would be obliged to notify the Canadian Food Inspection Agency for enforcement action. Mr. McLaren advised that this raw milk distribution was done legally under a cow sharing program. Mr. Mayers asked if the consumers under this program actually owned a cow or a share of a cow because Health Canada’s interpretation was that the former was legal but not the latter. Mr. McLaren said he was not sure.

Health Canada inquired about the sources for the Canadian epidemiological data that was presented.

The prevalence and trends of consumer raw milk consumption was discussed.

At one point, Ms. Fallon inquired how Health Canada ensured the public safety of raw oysters. Mr. Mayers responded that it was through public education. Mr. McLaren inquired how effective that was and Mr. Mayers said that public education was an effective risk management tool.

Mr. Mayers assured that Health Canada’s regulatory policies and procedures were based on science and that any changes would be so based.

Through discussion and inquiry, Health Canada indicated that the Coalition could use Health Canada's Guidelines for the Safety Assessment of Novel Foods Derived from Plants and Microorganisms as a guide for the development of a data package for Health Canada's assessment of the safety of the introduction of raw milk for consumer sale and have to follow their standard procedures for the introduction of a "novel food" into the marketplace. The framework for this application could be developed in one of two ways – either wait for Health Canada to develop it, which might take some time given their priorities, or the Coalition could propose a framework for Health Canada’s review and comment which would be an iterative process until satisfactory to both sides.

It was suggested that the framework could be developed first before any money was spent on the study itself. A primary concern for Health Canada was microbial hazards and tests would have to be submitted to prove safety. Health Canada made it clear that they would not base a decision on epidemiological data, but wanted analyses of raw milk for pathogens.

Mr. Mayers then left the meeting at 20 minutes beyond its original conclusion time.

Discussion continued around further details of the framework elements. The Coalition suggested comparative tests with pasteurized milk and soy and juice products, as well as challenge test with raw and pasteurized milk. Based on the discussions, Ms. Fallon also suggested that the direct sales model contained in the Pennsylvania regulations might serve as a favorable regulatory model. Health Canada felt that the inclusion of both of these suggestions in a proposed framework or study would not be viewed unfavorably.