Just to clarify, there are no rules in regards to raw milk production and sales in Illinois, there is only unenforceable POLICY.
How can that be, you query?
Well, originally, when all the milk rules were written years ago, the powers that were, assumed all milk sold was pasteurized. And being so sure about this fact and not bothering to do any real serious research, you know, like asking around, they plunged ahead and wrote the Grade A Pasteurized Milk and Milk Products Act. or PMO as we in the milk business often refer to it.
This act was fairly detailed and lengthy but it left out those of us who sold raw milk being as we are not Grade A since the Department of Public Health refused to allow us to KEEP our Grade A permits a few years ago when we wanted to do so. The funniest part, well I think it's hysterical but I am in a minority , is the way "dairy farm" is defined in the PMO. And I quote from page one of the act (Public Health 410 ILCS 635/3 section 3, part b.1)
"Dairy Farm" means any place or premise where one or more cows or goats are kept, and from which a part or all of the milk or milk products are provided, sold, or offered for sale to a milk plant, transfer station, or receiving station.
Now, the reason this gives me the giggles is because none of the raw milk farmers on the Dairy Work Group sell their milk or any part of their milk to a "milk plant, transfer station, or receiving station" We all sell our milk direct to the consumer, no middle man in the form of a milk plant, transfer station, or receiving station, EVER. Thus, in my opinion and based on the definition above, we do not meet the definition of "Dairy Farm"
See why this is so hysterical? Every day my husband milks 10 or so cows, complete with udders, sending that fresh healthy milk through a very clean glass pipeline into a very clean stainless steel tank where it is quickly cooled and where customers then pour it into their milk bottles and feed it to their children.
But according to the IDPH's definition, we are NOT a dairy farm.
So if we are not a dairy farm does it not also follow (your honor) that we cannot be held responsible for the rules written in the PMO? Seems logical enough to me. But when we asked this same question of IDPH, several times in several meetings, we are told that yes, we are still considered a dairy and must follow the rules. (Except they are not rules only "policy" )
So we asked that the legal department of IDPH to meet with us obviously ignorant, uninformed farmers and explain to us how we meet the definition of dairy when we don't meet the requirements of a dairy as they have written in the PMO, and we are told at the September 10 th meeting that the legal department can't be bothered to meet with us directly.
So to recap, there are no rules (only "policy") regarding raw milk in Illinois, thus IDPH had to form the Dairy Work Group in order to write the rules. But in the rules written for pasteurized milk where raw milk farmers have been excluded based on IDPH's definition of dairy, we are being told that IDPH's legal department says we do meet the definition of dairy yet none of them can be bothered to tell us WHY in a face to face meeting. Thus if indeed we do meet the definition of dairy in the already preesnt rules of the PMO, then why did IDPH feel the need to form the Dairy Work Group to write NEW rules in the first place?
And they wonder why we have trust issues.
Just four more weeks until our next Dairy Work Group Meeting. It should be very interesting