Health Canada Meeting of September 13, 2005
I met with Dr. Farber at Health Canada on September 13, 2005 for an
hour and in attendance were also Helene Couture and Dr. William Yan.
We discussed the format of the lab tests that would be acceptable
in our resubmission.
They said they were interested in 3 specific pathogens and out lab
tests would have to cover salmonella, listeria monocytogenes and e-coli
O-157. They also said that the number of samples per batch would have
to conform to current sampling principles which under the circumstances
would be 60 per batch and all 60 would have to test positive. They
gave me the reference and a photocopy from Micro-Organisms in Foods
2 by A.N. Sharpe.
They would like to see 4 seasons testing because pathogen levels
vary by season. And they would prefer Canadian samples to assure the
results in a Canadian context. They said they would not rule out US
sources but Canadian would be preferred.
We would also have to address in our resubmission how the herd is
free of tuberculosis and brucellosis and any other disease. But since
these are covered by other existing procedures, we need only make
reference to these procedures. The same would be true for anti-biotic
The accepted lab test methodology is on their website and they would
forward me the URL.
I mentioned that we initially wanted direct sales only but that I
had spoken to the DFO (Dairy Farmers of Ontario) and that they might
consider joining in our reapplication. I asked how much more difficult
would the lab testing be if we also included retail sales. They said
that once the milk was tested safe by a producer they did not think
it would add much complexity whether the raw milk was then sold directly
to consumers or went through the existing dairy processing and retail
distribution system. This was provided that again the safety issues
are already known and addressed by the existing retail processing
procedures which could be referred to and discussed in our resubmission.
They emphasized that our resubmission has to demonstrate that raw
milk is safe and that that is their primary concern. They also said
that whatever procedures we put down will have to be followed 100%.
If we want to deviate in any way whatsoever, we would have to refile.
They also mentioned some consideration should be given to shelf life
both in terms of safety and quality. They said pasteurized milk has
a shelf life of six weeks. I said I have kept raw milk for up to three
weeks but that shelf life doesn’t matter to consumers who want
raw milk, even if its only 2 days, like on the carton I brought from
England and presented at our last meeting, (click
I asked if we couldn’t simply adopt the English system since
they never banned the sale of raw milk. They said the English environment
is different and raw milk safety must be evaluated in a Canadian context.
I also mentioned that we eventually would want a small producer exemption.
They said that if I included it now, it would likely complicate the
filing and take more time to have it approved.
They also mentioned that there is transparency for any filing such
as ours and that our resubmission would be reviewed by a number of
interested stakeholders who would be free to comment and whose comments
would be considered from a standpoint of science and safety.
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