Not All Raw Milk is Produced Equally

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Written by Mark McAffee, Chairman of the Board, Raw Milk Institute
To: American Academy of Pediatrics

Re: Raw Milk policy position statement

December 20, 2013

Dear AAP Journal Editor,

I write to you in my capacity as chairman of the board of directors of the Raw Milk Institute ( RAWMI, rawmilkinstitute.org ).

RAWMI is a nonprofit, raw milk standards, food safety, produce- training-and-research organization. We find it our obligation to reach out to you to share data and research that perhaps you and the authors of the recent  American Academy of Pediatrics anti-raw milk policy position statement may not know or be aware of.

Your widely publicized position against any raw milk consumption is something we find oddly out of trend, out of sync,  and in near complete conflict with the most up-to-date research and the peer reviewed and internationally published research and  findings:

1. The UC Davis  IMGC “International Milk Genomics Consortium” research,
2. The widely distributed UC Davis “Splash News Letter,“ which distributes and publishes the most recent  findings on raw milk both here and internationally.
3. http://www.ncbi.nlm.nih.gov/pubmed/21875744,  known as the “GABRIELA study,” which onfirmed the dramatic decrease in allergies and asthma in 7000 children who drink raw milk.
4. http://www.ncbi.nlm.nih.gov/pubmed/17456213, known as the “PARSIFAL study,” which showed that 14900 kids who drank raw milk were then protected from allergies and asthma.
5. http://www.ncbi.nlm.nih.gov/pubmed/22846753, known as the “PASTURE cohort” study, which showed the beneficial immunoglobulin effects of drinking raw milk when pregnant and suggested that the raw whey protein may play an essential role in the immunologic protection.
6. http://www.greenmedinfo.com/blog/new-study-amish-prove-raw-milk-promotes-health-children, known as the AMISH study, which showed that Amish children had less asthma when they drank raw milk.
7. Multiple high quality QMRA risk assessment studies performed in the EU classify raw milk that is produced as intended for human consumption as a “low risk food.”
a.  Escherichia coli 0157 and Campylobacter jejuni related to consumption of raw milk in a province in Northern Italy. J Food Prot. 75:2031-2038. (Giacometti et al 2011)
b.  Quantitative risk assessment of listeriosis due to consumption of raw milk. J Food Prot. 74:1268-1281. (Latoree et al 2011) (This study replaced a previous, flawed US government assessment.)
c. Quantitative microbial risk assessment for S. aureus and Staphylococcus enterotoxin in raw milk. J Food Prot. 88:1219-1221. (Heidinger et al 2009)
d. As yet, no high-quality QMRAs for Salmonella spp. and raw milk

8. The CDC data, which reveals zero deaths from raw milk in their databases since 1972, when the databases were established. The two CDC raw milk cases associated with deaths were  illegally imported Mexican “bath tub” cheeses and not fluid raw milk from a US origin.
9. The CDC databases, which show at least 70 deaths from pasteurized dairy products, mostly from Listeria Monocytogenes. These include 49 deaths in 1985 and at least 9 deaths from pasteurized milk and cheeses between 2007 and 2013.
10. California Department of Food and Agriculture Grade A raw milk market standards and testing.
11. Raw Milk Institute standards and testing results as published at www.rawmilkinstitute.org, which show that raw milk produced under “grass-to-glass” food safety plans and testing is a very low-risk food.
12. All RAWMI LISTED raw milk producing dairies ( US & Internationally ) have a perfect food safety history with zero reported illnesses since being LISTED  by RAWMI. All food safety RAMP plans and testing data are published and available at www.rawmilkinstitute.org
13. In California, 625 stores carry state-inspected, intensively tested retail raw milk. It is a thriving market. Moms and families experience immune system recovery from all sorts of gut-based and immune illnesses.
14. We must all remember that breast milk is raw milk. We must all remember what UC Davis researcher and founder of the International Milk Genomics Consortium Dr. Bruce German said about pasteurization: “Pasteurization is an 18th century solution to an 18th century problem. . . we must and can do better.” Breast milk is not sterile and has at least 700 kinds of bacteria that help with the babies’ immunity!
15. Remember that pasteurized milk is the single MOST allergenic food in America as listed at the FDA website. Pediatricians tell patients not to consume (processed) dairy products because of this serious and known threat of allergic reaction. Eight children have died because of anaphylactic reactions since 1998 secondary to pasteurized dairy products. Why would any mother give her child with the most allergenic food in America when tested, non allergenic, safe raw milk helps children recover from asthma with its consumption?
16. According to the CDC, nine people per day die from asthma, many of them children, when treated by western medicine. . . no children have died since 1972 on raw fluid milk.
17. There have been zero incidences of TB in any raw milk because legal raw milk requires that the cows are tested annually to be TB free.  This concern is 100 years old and unfounded.
18. By design and evolution, raw milks contain a low level population of bio-diverse bacteria, active enzymes, active proteins, amino-acids, special purpose oligosaccharide sugars, and other whole intact vital living elements. The UC Davis IMGC research says that breast milk contains at least 700 kinds of bacteria including on occasion some human pathogens.  The NIH Human Genome and Human Biome studies explain why this is such an essential part of the immune system and health of normal healthy mammals and humans. Without the resident colonies of bacteria that reside in the gut, the health of the human is in serious jeopardy. At least 80 percent of the human immune system is based on the biodiversity of bacteria that thrive in the gut. Modern medicine, antibiotics, sterilized long shelf-life, processed foods and other modern conveniences have reduced gut biodiversity and dramatically suppressed the immune status of Americans, and especially our children. Doctors must know this because doctors are committed to healing and health.
19. Many California-based pediatricians DO prescribe legal, state-inspected raw milk to children because it is so effective in building immune strength, and  controlling and preventing allergies and asthma.
20. Raw milk kefir has also been shown to rapidly heal Crohns. See www.crohnsbabe.com for a very compelling story of a young women who chose raw milk over a colostomy bag and now no longer suffers Crohns. Many other ex-Crohns raw milk consumers have made this easy choice as well. I would ask. . . what doctor would choose a colostomy surgery for their patient before suggesting consumption of raw milk kefir? “Do no harm” with the least invasive approaches would definitely apply here.  I cannot think of any logical, ethical, moral, or even cost effective medical argument that would prevail when comparing a colostomy bag over consumption of a raw milk kefir?  This is the level of passion that drives this compelling discussion!

It is a truly an American experience that “official professional policy lags demonstrated pioneering efforts” by many years. It is clear that the AAP policy position is in this “lagging policy” category.  In California, 625 stores carry raw milk, which has been demonstrated to be low risk. It is consumed by about 80,000 delighted people and children every week. Other markets in the US have demonstrated this same growth and relative safety. It would be disingenuous and misleading to characterize this “low risk raw milk” as the same raw milk that is produced as intended to be pasteurized, or raw milk that existed in certain dairies 100 years ago, or even raw milk that comes from questionable or illegal untested sources today. It is absolutely imperative that AAP differentiate between the types and qualities of raw milks. Not all raw milk is produced equally.

A blanket policy statement that all raw milk is the same is a policy error and completely unfounded and untrue.  Different standards, inspections, conditions and testing result in different levels of risk.

Breast milk is raw milk and doctors know that “breast is best!” for many compelling reasons.  Children thrive on raw milk because it is complete as intended for the immature digestive tract. Pasteurized milk is very difficult to digest and for this reason cannot be given to infants.

The FDA website identifies processed milk as the most allergenic food in America. Pasteurized milk is a product made from milk. . . it is no longer milk. It is designed for Shelf Life and not Gut Life.  In fact, properly informed pediatricians counsel their patients away from pasteurized dairy products if allergies are suspected. Yet the Academy strongly recommends pasteurized milk and claims that there is no difference between raw milk and pasteurized milk nutritionally. The research says otherwise. According to Dr. Bruce German at UC Davis, the foremost researcher on raw milk in the world, store bought processed milk does not provide the same digestibility or benefits for asthma and allergies as raw milk does. He also has said “Pasteurization is an 18th century solution to an 18th century problem and we have the technology and standards to  do much better.” Researcher Dr. Von Mutius confirms Dr. German’s findings with her own EU-based raw milk research and confirms that raw milk is effective for treating asthma and allergies.

We no longer have the problems associated with TB, filth, Typhoid fever and or poor water quality that was suffered in the late 1800’s and early 1900’s. We also no longer have the problems with raw milk that were experienced during that same time when that raw milk is produced under rigorous standards and testing.  This is the 21st century and we need pediatricians to operate with a full tool box and training in all available methods to address the needs of their children and their immune systems.

We ask that the American Academy of Pediatrics take the lead and consider adopting a  scientifically grounded  and  appropriate raw milk policy. An example might be:

Not all raw milk is produced equally.  Raw milk is a low risk food for human consumption where it is produced and inspected  under rigorous, transparent standards and testing. Raw milk has been shown to be easily digested and provide immune benefits to patients with asthma and allergies. However, raw milk that is produced as intended for pasteurization can be a high risk food if consumed raw and should be pasteurized prior to consumption.

We all know that pioneering new practices and use of new technologies mean that official policies will lag behind. If you can publish this commentary in your Journal, it would go far to bridge some very wide ideological gaps that divide the last hundred years of raw milk history and medical experience.

More and more families go to their pediatricians to report excellent growth, fewer colds and flu, freedom from cavities, few or no ear infections, relief of eczema  and thriving children, only to add “with trepidation” that the family drinks raw milk. The pediatricians then reprimand families for their neglect and the dangerous choices being made for their beloved children. It is time that families and their doctors “become one with their children’s welfare” with immune and nutritional health status as their highest priority. A change in this blanket ban on raw milk AAP policy position would go far to help both children and their doctors.

Nine people die each day from asthma, many of them children. None have died from raw milk since the CDC started their databases in 1972. We do not claim that raw milk or any food is perfect and yes there have been some illnesses, but in balance, the benefits far outweigh the risks, especially when considering the very high standards that legal retail inspected and tested raw milk must pass. Please publish this statement in your Journal. Our country’s caring pediatricians need this additional information to more fully inform their opinions and effectively and more appropriately treat their precious little growing patients.

Most kind regards,

Mark McAfee, Chairman of the Board
Raw Milk Institute
7221 South Jameson
Fresno, California  93706
559-970-5581

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