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Where Sale of Natural Milk Is Allowed Methods of Production

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 residues.

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 here) and (click here).

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.