Author: Theresa Sweeney
Regulatory Register – Winter 2024
Raw Milk Doesn’t Define Dairy
The activist claims are unfounded. The proposed laws endanger public health. And raw milk does not define dairy.
Much like the anti-vaccination movement (with whom it shares many advocates), raw milk proponents make various claims that may seem at least somewhat plausible but fall apart on closer scrutiny. The arguments, and the suspect reasoning behind them, have popped up in state legislatures for years, and for the most part they may not seem to require that much scrutiny – until someone gets sick, which happens all too often.
But with new laws being considered in more states, the tiny niche of raw milk has the potential to disrupt the dairy industry far beyond its actual market. Long touted by its devotees as superior to pasteurized milk and the key to saving dairy farms, in practice it undoes generations of public health success that has won consumer trust and made commercially sold milk one of the safest products available.
To cite the science: Raw milk does not contain more or superior nutrition to pasteurized milk. Raw milk’s record on gut health shows how greater harm works against any perceived benefits. Raw milk does not “cure” lactose intolerance. And so on, and so on.
What raw milk does do is contain pathogens that make people sick. The current patchwork of local regulations has proven why raw milk is a public health threat: Places where raw milk sales are available to the public see much greater milk-related illness outbreaks than places where such sales are prohibited. That’s why pasteurization was invented in the first place – not as a conspiracy against consumers or farmers, but as a public health measure that has saved thousands of lives over generations.
Those are just a few of the reasons why the Centers for Disease Control and Prevention and the Food and Drug Administration support raw milk restrictions. As with routine vaccinations, in which a decline has led to deadly, and absolutely unnecessary, illness outbreaks, pasteurization has been so effective, for so long, that many people no longer remember how this technology improved lives in the first place.
Another popular raw-milk argument is that what consenting adults choose to buy and sell is their own business. With all due respect to absolutist libertarians, the world doesn’t work that way, as every consumer-safety regulation in the universe attests. The world especially doesn’t work that way when a product bought by consenting adults is then given to children. The vaccination comparison holds: Even though personal-conscience and religious belief exemptions exist, good luck enrolling children in a public school without a polio vaccine. There’s a reason for that. Ask your grandparents.
Another argument in raw milk’s favor is that it will “save the farm.” It’s certainly possible that revenues from small-scale sales may help a dairy farm here and there. But it’s even more certain that foodborne outbreaks that weaken consumer confidence in milk (and unfortunately, many consumers won’t distinguish between raw and pasteurized milk when hearing a radio news report on a highway) harm the tens of thousands of dairy farmers who sell in the commercial marketplace.
Dairy farmers have spent generations building a reputation for safety and quality. No “alternative” testing protocol will ensure the same level of safety as decades of experience with pasteurization, and no assurance that raw milk sellers will do the right thing and ensure safety on their own will take the place of a surefire technology that is universally applied.
So, to any state legislator who is contemplating loosening restrictions on raw milk sales: The National Milk Producers Federation, the largest organization of dairy farmers in the United States, representing small, medium and large farms, more than 95 percent of them family-owned and operated, in every region of the country, stands opposed to the legislation you are considering. It’s bad for families, it’s bad for farmers, and it’s based on bad science.
The suspect evidence and faulty reasoning has gone on long enough. It needs to stop.
NMPF Urges DMC Signup as USDA Announces Enrollment
Statement from NMPF President & CEO Gregg Doud:
“Dairy farmers are pleased to finally have the certainty of knowing when the Dairy Margin Coverage (DMC) program signup is beginning, and NMPF urges every dairy farmer to strongly consider signing up. DMC itself is improved from the previous farm bill, thanks to the permanent incorporation of updated production histories in the program, and recent low producer margins underscore just how critical DMC is for dairy farms of all sizes. We thank Congress for making this important change and are grateful for USDA’s work in rolling out this updated program for farmers.
“NMPF is eager to assist producers in any way they can with this program. We also look forward to working to ensure that farmers receive what they need even more – a new farm bill that provides certainty for the next several years, and not just 2024.”
USDA announced today that the 2024 Dairy Margin Coverage sign-up will open Feb. 28 and run through April 29. For more NMPF resources related to the DMC program and other federally backed risk management programs, visit here.
Dairy Products Stocks Fall As Milk Production Growth Remains Weak
FMMO’s Next Steps Begin
Its Federal Milk Marketing Order (FMMO) hearing now concluded, USDA is now considering more than 12,000 pages of testimony as it formulates its plan for FMMO modernization. NMPF is still doing what it can to ensure that proposal best reflects the interest of dairy farmers and their cooperatives, two NMPF economists said in a Dairy Defined podcast.
The key to successful modernization is a comprehensive approach that addresses the complexity of federal orders in a way that respects the entire dairy industry while keeping in mind that orders most fundamentally must work for farmers, Dr. Peter Vitaliano, Vice President for Economic Policy and Market Research, and Stephen Cain, Senior Director for Economic Research and Analysis at NMPF. That’s always been the bedrock principle behind NMPF proposals on areas ranging from returning to the “higher-of” Class I mover to updating milk composition factors.
“What separates National Milk’s proposals from processor groups is more of our holistic approach,” Cain said. “You can’t look at the federal order system having not been updated in 20 years and not address all facets of the industry, right? You can’t say in good faith that Class I differentials need to be updated because costs have gone up without also conceding the fact that make allowances need to go up for the same reason. So we took that holistic approach. That is going to help move the industry forward together.”
Cain and Vitaliano also discuss USDA’s decision-making timeline, and why July could be the key moment for FMMO modernization. The full podcast is here. You can also find the podcast on Apple Podcasts, Spotify and Google Podcasts. Broadcast outlets may use the MP3 file below. Please attribute information to NMPF.
NICMA Elects New Officers, Concludes Successful 79th Annual Meeting
The National Ice Cream Mix Association (NICMA), a dairy industry trade organization managed by NMPF and led by its chief science officer, Dr. Jamie Jonker, held its 79th Annual Meeting Jan. 14-17 in Fort Lauderdale.
More than 60 attendees, speakers, and guests enjoyed three days of technical sessions covering topics from food safety, product trends and innovation, employee retention, socially responsible sourcing, regulatory issues, and industry economics. NICMA welcomed Boxes of St. Louis, Inc., and General Films as new Associate Members.
NMPF Accepting Applications for 2024 Scholarship Program
NMPF is now accepting applications for its National Dairy Leadership Scholarship Program for the academic year 2024-2025.
NMPF awards scholarships annually to outstanding students enrolled in master’s or doctoral programs actively pursuing dairy-related fields of research of immediate interest to NMPF member cooperatives and the U.S. dairy industry at large.
Graduate students pursuing research that directly benefits milk marketing cooperatives and dairy producers are encouraged to apply. Applicants do not need to be members of NMPF to qualify. Scholarship recipients will be invited to present their research via webinar during the summer of 2024. Top applicants are eligible to be awarded the Hintz Memorial Scholarship, created in 2005 in honor of the late Cass-Clay Creamery Board Chairman Murray Hintz, who was instrumental in establishing NMPF’s scholarship program.
Recommended fields of study include but are not limited to Agriculture Communications and Journalism, Animal Health, Animal and/or Human Nutrition, Bovine Genetics, Dairy Products Processing, Dairy Science, Economics, Environmental Science, Food Science, Food Safety, Herd Management, and Marketing and Price Analysis.
Applications must be received no later than Friday, April 12, 2024. For an application or more information, please visit the NMPF website or email scholarship@nmpf.org.
Scholarships are funded through the National Dairy Leadership Scholarship Fund. If you would like to support the scholarship fund, please consider a donation here: https://donate.stripe.com/eVa7th6v18VcaT6144
NMPF Comments on FDA Veterinary Priorities and Antimicrobial Use Duration
NMPF submitted comments Jan. 19 to the FDA Center for Veterinary Medicine on their Environmental Scan.
The scan’s purpose is to identify major trends, including emerging issues and ongoing challenges, in the veterinary center’s internal and external environments to support, inform, and improve short-term and long-term strategic planning. The center asked six wide ranging questions about priorities, legal authority, communications, and One Health, an effort to improve health outcomes among all species.
NMPF’s comments reviewed the nearly 40-year U.S. dairy industry commitment to One Health through residue avoidance and the FARM animal care program. Comments to specific questions included support for broader FDA authority through the FEED Act to regulate feed additives with non-nutritive benefits, including environmental benefit claims, production claims, and claims about effects on the animal well-being and pre-harvest food safety. The comments also supported FDA’s efforts to streamline development and approval of other novel technologies to address animal health, antimicrobial use, and environmental issues.
The veterinary medicine comments followed joint comments NMPF submitted Jan. 5 with the American Association of Bovine Practitioners (AABP), the Academy of Veterinary Consultants (AVC), and the National Cattlemen’s Beef Association (NCBA) on the draft FDA Guidance for Industry (GFI) #273 Defining Durations of Use for Approved Medically Important Antimicrobial Drugs Fed to Food-Producing Animals. In reviewing GFI #273, the groups identified several substantive concerns.
The group also referenced the agency back to extensive evidence-based comments previously submitted to earlier requests by the agency for public comments on this topic — specifically, the joint comments from AABP, AVC, NMPF and NCBA in 2017 and 2021, to include a request for information document with more than 80 scientific references.
US-EU Trade Discussion Features NMPF’s Morris Representing Dairy
Shawna Morris, Executive Vice President for Trade Policy and Global Affairs, attended U.S. Trade and Technology Council (TTC) events on Jan. 30-31 representing U.S. dairy in discussions via the Transatlantic Initiative on Sustainable Trade (TIST) work program.
The European Commission launched the initiative last May to boost bilateral engagement with the United States and accelerate the transition to a climate-neutral economy. Morris participated in a high-level plenary session, a smaller breakout session, and a Jan. 30 welcome reception. While there she focused on the need to ensure EU agricultural policymaking is not wielded as a barrier to trade, encouraging the European Union to focus on collaboration on shared objectives rather than prescriptive dictates that would deepen U.S.-EU agricultural trade tensions.
NMPF Advocates for Common Names Protections in USTR Comments
NMPF, in partnership with the U.S. Dairy Export Council (USDEC), submitted comments to the U.S. Trade Representative Jan. 24 that emphasized the U.S. government’s need. to secure commitments from trading partners to assure the future use of certain generic cheese terms. The comments, part of NMPF’s ongoing mission to protect the rights of U.S. cheesemakers to use common names like “parmesan” and “feta” worldwide, were submitted in response to the agency’s request for input on its annual Special 301 review of intellectual property trade issues.
NMPF and USDEC’s submission supported more comprehensive comments from the Consortium for Common Food Names (CCFN), which NMPF’s trade policy team staffs. CCFN reiterated how producers on-the-ground are negatively affected when the European Union confiscates common names, and detailed the specific markets that the administration should prioritize work in to preserve export opportunities.
Ag Trade Caucus Launches as NMPF Pushes Export Opportunities
NMPF Trade Policy Director Tony Rice joined Farmers for Free Trade for Jan. 31 and Feb. 1 meetings with key lawmakers and staff to promote a more proactive U.S. trade agenda. The meetings coincided with the Jan. 31 launch of the new Congressional Ag Trade Caucus, inspired by the farmer group to elevate the importance of trade policy that levels the global playing field for America’s dairy and ag producers.
Rice spoke with congressional staff about the need for new market access for American dairy exports, relaying the industry’s concern that U.S. exporters are seeing growing disadvantages versus America’s competitors. The discussions also offered the opportunity for NMPF and Farmers for Free Trade to educate newer congressional staffers from agricultural districts about the value of exports to their districts and constituents.
