----- Original Message -----

From: "Paul Mayers" <Paul_Mayers@hc-sc.gc.ca>
To: <ca@magma.ca>
Sent: Sunday, October 17, 2004 10:32 AM
Subject: Raw Milk for Drinking

Dear Mr. McLaren:

Subject: Submission on Raw Milk for Drinking

This is in response to the submission you provided to Health Canada on March 19, 2003 requesting an amendment of the Food and Drug Regulations to allow for the sale of unpasteurized milk to consumers in Canada. The submitted information has been reviewed by a multi-disciplinary team. The following comments outline the results of this evaluation with specific reference to the two major issues you raised in the submission, i.e., i) safety and ii) nutritional quality of raw milk versus pasteurized milk.

i) Safety

Health Canada's mandate is to help Canadians to maintain and improve their health. Our role in this regard is to develop policies and standards regarding the safety and nutritional quality of food sold in Canada such as milk.

The availability of safe milk is important to maintaining a healthy diet, especially for children. Unfortunately, the practice of drinking raw milk presents risks of acquiring diseases including: campylobacteriosis, salmonellosis, yersiniosis, listeriosis, tuberculosis, etc. At present, the most serious threat may come from Listeria monocytogenes. This organism can cause septicemia, meningitis and may even result in death in immunocompromised persons and infants. It can also result in stillbirth, or miscarriage if pregnant women become infected. Listeria monocytogenes
may contaminate between 1 and 10% of the raw milk supply.

While raw milk is not available on the Canadian market, occasional exposures continue to result in illnesses. In 2000, Campylobacter in farm milk caused illness in 5 individuals in Edmonton. In August 2001, Escherichia coli O157:H7 in raw goat's milk was implicated in a central
Vancouver outbreak. In 2002, 5 members of a family became ill with Salmonella from raw goat's milk in Chilliwack. On Central Vancouver Island, 9 out of 13 kindergarten children became ill with Campylobacter after drinking raw milk while on a school visit to a local farm. On Vancouver Island, five children from different families were diagnosed with an infection of E. coli O157:H7 after drinking raw goat's milk. Two of the children had to be hospitalized. In Vernon, a number of cases of Campylobacter were traced to the consumption of raw milk. In the
Kootenays, a 35 year old woman needed surgery due to a Brucella infection which developed after she drank raw milk. On the Queen Charlotte Islands, two people developed toxoplasmosis after drinking raw goat's milk (2). In Quebec, illnesses linked to raw milk consumption have continued to occur each year since 1998 with Campylobacter, E. coli O157:H7, Listeria and Salmonella, all having been involved at various times in the outbreaks.

Prior to 1991, the sale of raw milk in Canada had traditionally been a provincially regulated matter. Health Canada, with the support of the National Federation of Milk Producers (the Dairy Farmers of Canada), recognizing the risks to human health, consulted with the provinces regarding prohibiting the sale of unpasteurized milk for human consumption. After consultation, a regulatory amendment was brought into force in 1991 to Division 8 of the Food and Drug Regulations, to prohibit the sale of raw or unpasteurized milk (cow's, goat's, etc.) to the consumer (B.08.002.2[1]). This regulation provides a regulatory safeguard against milk-borne illness by implementing a uniform control measure across Canada.

The dairy industry is well regulated and the Canadian Food Inspection Agency (CFIA) and the provinces have controls in place to ensure the safe production of pasteurized milk. Documents such as the National Dairy Code, the Dairy Plant Registration & Inspection System (DPRIS) guidelines and the Food Safety Enhancement Program (FSEP), outline the steps taken by these organizations to ensure that industry produces a safe product.

In summary, the microbiological and epidemiological evidence available continue to demonstrate a clear association between raw milk, disease-causing organisms and cases of human illness. The consumption of raw milk is considered to represent an unacceptable risk to human health.

ii) Nutritional quality

High-temperature short-time (HTST) pasteurization has a minimal and dietarily insignificant impact on the nutrient content of milk. Mineral nutrients, carbohydrates and fats are heat stable. While some milk protein is denatured by heat, this does not affect the quality of the protein and in fact makes it more digestible. Vitamins, including the fat soluble vitamins A, D and E, and water soluble vitamins such as riboflavin (Vitamin B2 ), niacin, pantothenic acid and biotin are relatively heat-stable. Other water soluble vitamins such as thiamine (vitamin B1), folic acid, vitamin B6, vitamin B12 , and vitamin C are less heat-stable but their losses due to HTST are less than 10 %, and would not be considered significant in the context of the Canadian diet.

There may also be effects resulting from handling, types of packaging, length of storage and storage temperatures, but these have not been systematically studied, particularly with modern analytical techniques.

Other effects on the nutritional quality of milk resulting from pasteurization are not supported in your submission. For example, while lipase and lysozyme are enzymes that can remain active at high pH and therefore may be active within the gastrointestinal system, the references to a positive effect of lipase on fat absorption and related health benefits are either very old (dating to 1926 and 1941) or their validity is questionable because they are not in the peer-reviewed, recognized scientific literature. Unfortunately, the reference to Renner is untraceable (German publication), and several other publications are not truly peer reviewed. In addition, your references to refereed journals all point out facts that do not relate back to a health influence.

In summary, from a nutritional point of view, the information provided in the submission and our further review of the literature does not support a conclusion that raw milk is better nutritionally than pasteurized milk.

Having reviewed the information presented in your submission and in further consideration of the scientific literature, Health Canada has concluded that this submission is not supportable. We are therefore not in a position to agree to your request to seek an amendment to the Food and Drug Regulations to permit the sale of unpasteurized milk to consumers in Canada.

Yours truly,

Paul Mayers
A/Director General
Food Directorate

REFERENCES

1. British Columbia Ministry of Health, Health File #03, January 2002.

2. Journal Canadian Medical Association. June, 1989.

• Renner E., Schaafsma G.,and Scott K.J. (1989). Micronutrients in Milk. In "Micronutrients in Milk and Milk-Based Products" (E. Renner, ed.), pp. 1-70.

 

----- Original Message -----

From: "James McLaren" <ca@magma.ca>
To: "Paul Mayers" <Paul_Mayers@hc-sc.gc.ca>
Cc: "Brian Klunder" <brian_klunder@hc-sc.gc.ca>
Sent: Tuesday, December 14, 2004 4:46 PM
Subject: Restoring raw drinking milk & consumer preparation of raw milk
Attach: Goats milk bottle scan cropped.jpg (39.5 KB) (CLICK HERE)
Goats milk label scan cropped.jpg (26.9 KB) (CLICK HERE)

We would like to thank you and your team for taking the time to study our proposal and to respond to our request. Curiously we received your email when I was in England, where anyone can buy raw drinking milk as a ready-to-eat food. Please see the attached jpeg’s.

As you know, we are interested in restoring raw milk as a ready-to-eat food here in Canada and it sounds like it would actually be pretty easy based on the conversation I had with the English goat milk producer. If this option doesn’t interest you, then we want the consumer preparation of raw milk restored instead, which does not appear to be discussed in your reply. Just because milk is sold raw doesn’t mean it will necessarily be consumed raw any more than raw hamburger will be eaten raw, except by the Lebanese in their kibbeh. Dairy farmers aside, consumers can now prepare any other raw food of animal origin except raw milk. This sort of discrimination is unacceptable to us and you have given us no compelling reasons in your response to think otherwise. All we want is what any dairy farmer and their family has and does - access to their own raw milk and the right to decide how to prepare it, or not, as we can now do with any other raw food of animal origin.

To encourage you to be part of the solution rather than part of the problem, I propose that we conduct a joint field study. Our website refers to a Canadian dairy farmer who annually distributes 70,000 litres of raw dairy products for raw consumption to over 100 customers and their families. To dispel the myths that have been falsely created about the hazards of certified raw milk production and consumption, he has kindly volunteered to have his operations studied. Since 2000 the farmer has done comparative testing through an independent consultant and an accredited lab. The tests have been randomly conducted with comparative testing of store-bought milk of any make (to study the claims made by health officials) and raw milk.

Another reason to conduct this particular study has to do with the raw milk infections you cite in your response. If someone becomes infected from drinking raw milk then that raw milk by definition needed to be pasteurized for safety. Therefore, all the infections you cite were caused by raw milk that was unsafe to begin with and unless the producers followed superior hygienic production practices designed specifically for raw drinking milk, I would say that your study procedure was unscientific and that your results and conclusions are therefore invalid. By conducting our proposed study, we can establish a level playing field by using raw milk produced specifically for raw drinking, rather than raw milk that was infectious to begin with.

We were also surprised by your comments on nutrition. For one thing, your own test for successful pasteurization, if we understand it correctly, is the complete cessation of enzyme activity as measured by one in particular, alkaline phosphatase. Firstly, a simple Google search shows that this particular enzyme is used in bone calcification, and we consider this a nutritional advantage. Secondly, why would the dairy industry produce a type of milk that is enzyme‑enhanced, if enzymes have no nutritional value? I am referring of course to the lactase-enhanced milk for consumers with lactose intolerance. For these reasons alone, and we have many more examples to offer, we cannot accept your conclusion that heat-treated milk is nutritionally equivalent to natural milk. Furthermore, consumers should be the ones to choose which form of milk is best for them, not you.

I would like to arrange a meeting with you to discuss these points and to see if we can reach a mutually agreeable course of action with respect to the above. I will be contacting your office to see if a date and time can be set.

James McLaren, B.Com. C.A.
President, Natural Milk Coalition of Canada

 

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