First, a very brief overview. For decades raw milk sales were allowable in Illinois. There were no rules only "unenforceable policy." That is a direct quote from Molly Lamb of IDPH. She was given the task by her higher ups, of revising these policies so that could be enforced. A committee was formed ( Fall 2012) without raw milk farmer or consumer input but with representatives from the FDA, Illinois Farm Bureau and Large Dairy Co-ops like Prairie Farms and two pages of rules were drafted. After that draft evolved, I was asked to join the committee by Steve Diviencenzo of IDPH and when I discovered there were no other raw milk farmers or consumers on the committee I made noise. Ms. Lamb agreed to invite those others. The Dairy work group evolved into one equally divided between those supportive of raw milk production and consumption in Illinois and those against.
The group met monthly for 10 months and raw milk farmers were very clear that additional rules were not needed in light of the facts there were no reports of increasing raw milk related illnesses in our state. We very clearly put our objections into writing. IDPH pretended to listen but just as we thought we were making meaningful progress, he group was disbanded by Molly Lamb via an email in Nov. 2013. without warning.
IDPH released in February 2014, NINE PAGES of proposed rules specific to raw milk production in Illinois. Yes, your math is correct. They started with no rules, drafted two pages of proposed rules without consumer or raw milk farmer input and then AFTER we gave them the benefit of our time and expertise they fired us and then expanded their rules from two to nine pages.
Next month, July 2014, these proposed rules will become part of Illinois's Federal Register. From there YOU and I, the public, will have a 45 day comment period. If you care about the availability of raw milk in Illinois, if you are concerned about the inevitable closure of many small farms, if you feel strongly that YOU should be the one who decides what you and your family should consume then you must get ready to comment. The day is approaching with terrible speed. Please watch this blog and Illinois Alliance For Raw Milk Facebook Page. We will notify you when the official comment period begins and tell you how to make your opinion heard.
To help you prepare here are just a few of the most insane proposed rules concerning farmers who wish to sell raw milk directly from their farm premises.
Any farmer with just one cow, sheep or goat who sells their raw milk must possess a permit
from IDPH to do so. The permit would then require the farmer to submit to regular inspections
and milk testing.
Donating, bartering, distributing or even gifting of raw milk will be prohibited.
Distribution agreements, herd shares or other contractual agreements will be prohibited.
The farmer must maintain a log of all sales including the consumers name address and phone.
The Farmer must report the annual amount of raw milk sold whenever IDPH requests such
Warning signs about the dangers of raw milk must be posted and IDPH even states the font type
(Arial) ink color (black) and letter size (at least two inches)
No swine or poultry can be housed with lactating dairy cows.
The flanks, udders, bellies and tails of cows must be free from all visible dirt.
For every day that raw milk is sold the farmer must keep a sample a minimum of five days in
a sanitary container at 32-40 degrees.
The proposed rules go on and on to include requirements for the milking parlor, the equipment used, extensive milk testing requirements and further mandatory reporting to IDPH. If you would like to see the entire listing please email me at firstname.lastname@example.org and I will be happy to send them to you.
I predict the consequences of such rules, if passed will be this...
For those small farmers who might be able to meet these rules, (and my opinion based on the numerous farmers I've spoken to, is that less than 1/3 of current raw milk farmers in Illinois will even be able to come close) the expense in upgrading milk parlors alone will cause raw milk prices to raise dramatically and raw milk supply to just as dramatically plummet.
Consumers will become frustrated with the hoops they have to jump through (giving their names, addresses and phone numbers for tracking purposes) that they will either buy raw milk from farmers not permitted by IDPH or lie about their contact info or cross state lines to get their raw milk with less hassle.
Decent hard working farmers who have healthy herds and clean enough environments (I mean come on, any farmer who keeps his herd on pasture as they should be, will never have cows that are "free of all visible dirt") will close their dairy doors, or sell their raw milk illegally risking the chance of what? Jail time? Expensive fines? Public flogging? IDPH has yet to announce any consequences for farmers who choose not to follow the rules if passed.
Individuals who will recognize an opportunity to make big bucks from one or two cows will come out of the woodwork. Folks who have no business raising cows will buy a couple, sell the milk for exorbitant amounts without any regard for consumer safety or animal welfare. Think I am being dramatic? Think prohibition.
Or those who would rather make big bucks while touring the Midwest will start up black market raw milk transporting it in from other states. IDPH says they are worried about public health? Wait until desperate consumers start swallowing raw milk that has been on the back of a truck for the last 8 hours, has not been properly chilled, or poured into clean containers, or obtained from a suspicious source.
My bottom line is this. Illinois raw milk farmers have been selling large amounts of raw milk to thousands and thousands of raw milk consumers for many decades WITHOUT any significant raw milk related illnesses being reported.( In fact IDPH does not even consider a raw milk illness REPORTABLE, the risk being so minute.) Most of these farms are small and the majority are managed by experienced farmers with healthy pasture raised herds who are frequented by well educated consumers. These consumers have held us, the farmer, accountable without any prior help from IDPH. Granted no food is 100% safe and life is never risk free but the last thing we need in this state of great budget deficits and red-nose-wearing-bureaucratical- clowns...is more rules.
The level of nutritional risk I choose to take for myself and my family should be my choice and mine alone.