Saturday, December 5, 2009

My thoughts on milk regulations

I have received a couple emails in response to my brief post about the DEC cheese making proposal 18AAC32. I would like to share an excerpt of one of those emails here, as I am sure that many of you have had similar questions or thoughts:

What changes would help out and still assure a safe product? The regulations are intended to assure that the processing facility is sanitary. I am willing to write DEC in favor of smaller operators, but I would like to hear specifically what you want. Mark Andrews

Well first, I'd like to genuinely thank you for taking the time to comment Mark, otherwise I would not be writing this post. I've been wanting to write more about milk, milk laws, and the controversy that surrounds the raw milk movement. I've been wanting to do more research as I want to be as informative as possible. I will state here that I am a skeptic. I do not believe much of what I read, hear or am told by A. my government, B. FDA, C. mass media D. any other large corporations or businesses. With that in mind...

The short answer is that I think there should be an exemption in proposal 18AAC32, that acknowledges that there are families milking a few animals and wanting to sell their extra milk and cheese, who are not capable nor interested in meeting the requirements of a Grade A Dairy.

Just acknowledging that ordinary people can milk animals, process milk and make cheese in their own kitchens in a safe manner and end up with safe product would be a tremendous event for the DEC or the FDA. I doubt this will happen. However, I would hope that if there is enough public interest and demand that DEC could be compelled to write up a separate list of regulations for small scale home dairies. I'm talking about making a daily batch of cheese from two to ten gallons of milk, it really isn't feasible to do more than that without the big equipment.

Before I go on discussing what I find are reasonable requirements for a home dairy, let me first enlighten you with just a small portion of the current proposal:

Construction Standards:

There must be separate rooms for each of the following operations:
1. receiving, weighing milk, washing and sterilizing containers in which milk has been received.
2. pasteurization, processing, cooling, manufacturing
3. bacteriological and chemical analysis
4. storage or aging of products
5. boiler, compressor and other machinery
6. storing of cleaning supplies or other potentially hazardous materials
seven. (my seven key is broken) toilets, lavatories, lockers
8. business offices

There are many more requirements including the structure(s) be built out of concrete. Water lines must be supplied by a public water system. Discharge must exit into a public sewer.

Obviously these regulations have been written with a large dairy in mind. In Fairbanks about half of the population lives in the city and has access to public water and sewer. The other half lives in the surrounding hills and valleys. These homes have wells or in many cases water holding tanks and private septic tanks. The reason for the water holding tanks is that it is too deep and expensive to drill for wells which often result in poor water quality. People either have water delivered by businesses or they haul their own water in jugs or water tanks. My point would be that anyone with dairy animals would be already living outside the city limits and therefore would not be able to meet these requirements just by location, unless they purchased another piece of land just for the purpose of processing milk, cheese-making and distributing etc. Furthermore, thinking of the rest of the state, most farms are located out of main population centers, which means that they are not on public water / sewer systems. This proposal is making it almost impossible to keep animals on the same premise as turning milk into cheese.

I recently visited a small goat farm in Maine. The lady had a certified dairy Maine dairy and it was legal for her to sell pasteurized cheese. I don't remember if she sold raw or pasteurized milk or not (I'll ask). Her dairy was located in the basement of her house and was no larger than a ten by twelve room. She had concrete floors, three small sinks and a refrigerator. She was required to send samples of milk ( I'm not sure about cheese) in to have it evaluated for bacteria count. She also receives surprise visits from some sort of inspector who makes sure that her cheese making and milk processing room are sanitary. Her fridge has to be at a certain temperature and her screen door has to be closed. I think that those are fair requirements. If that is what it took for me to legally be able to sell fresh chevre at the local Farmers market I would do it in a heartbeat. Maybe more importantly, if another cheesemaker met those requirements, I would feel safe buying cheese from them. I don't think that making cheese on a small scale should require much more than making baked goods or jam. Other than possibly sending milk in for testing or having surprise inspectors stop to inspect the facility.

I think it should be legal to sell raw milk and raw milk cheeses. That being said, I'm not going to go into the issues surrounding them yet. I will say that raw milk is consumed world wide on a daily basis with very few related illnesses. We drink raw milk and have been making raw milk cheeses for two years. My children are thriving. How can one even begin to compare a couple gallons of milk being turned into cheese in a home kitchen to milk in a cheesemaking factory. Personally I can see why the standards are so strict for the factory. In a home kitchen quality control is much easier enforced.

The state of Alaska and those of us who live here are going to be in big trouble if for any reason our chain of supply is cut off. Almost all of our food including milk is shipped in to the state. A very very small amount is actually grown and produced here (seriously scary). Our state should be doing all it can to foster the growth of small farms and dairies. Really all I want is for myself and others is to be able to sell milk and cheese from our own land, without having to go into debt building a factory. This is not an unreasonable request. I think that there is growing interest among the public for local food, raw and unprocessed foods, organic and natural foods. It is time to be heard, we just need the higher-ups to listen and the only way that is going to happen is if enough of us yell.



4 comments:

Bob Hayles said...

I'm glad to see another raw milk/raw cheese proponent being interested and INVOLVED in reforming the law.

I'm a bit of a mavrick. I look at milk laws from a rights perspective rather than a food safety one. Where in the constitution is the government given permission to tell us what we can and cannot consume? Where is it written that they can make our nutritional choices for us?

Read about the Raw Milk Wars at www.juicymaters.com. It's in the political section.

Bob Hayles
http://www.JuicyMaters.com

kuskolady said...

Let me start by saying that I am not against making changes and there are changes that need to be made to milk sales in the State of Alaska. Now let me go to the other side for a bit. As we have conversed, my husband and I just built a Grade A Goat Dairy in Palmer. We are not licensed and our cheese is about ready for market.

I am sorry that more information is not out there about the cheese regulations. They are not cut and dry as they seem. Take for instance the many rooms to the building. You can have your office in your home, if you don't have employees other than yourselves, you don't need a bathroom, and the rooms don't need to be big. Our building is rather on the large side because we have made it with room to expand and grow and look at it as what it could become if we ever sold our place.

One must remember that DEC is regulated by a lot of Federal Law and not State Law.

There are lots of options in equipment that are not super expensive. It is all in the amount of product you want to deal with. I encourage people to go out there and search for different equipment that has been created to meet PMO (Pasteurized Milk Ordiance). You will be surprised. The next step is to see if it is approved in Alaska, and if not, get all the information on the equipment and go to DEC with it.

Another option is to create a co-op group where you go together and build the building and purchase the equipment then work together to make the product to sell.

To make changes in the raw milk laws, you need to go to the State Politicians. There was a bill out there last year that didn't make it all the way through before the end of session; but doesn't mean it can't be put out there again.

The regulations are not necessarily set up to aid the big boys, really. To know how the regs work for the smaller guy, meet with DEC representatives and ask your questions.

The water system and waste system doesn't have to be from the "town" system. We live way out of town and our water works just fine. Because we did put in a larger building we also put in a new septic system.

The real options for the building are that it has a cement floor with drains and that the walls and ceiling are coated with moisture proof substance. You can make your building from a basic wooden structure then just make sure that the walls and ceiling are covered good with FRP.

We also have a shares program that allows us to give people that own a share the raw milk they desire.

Thanks for listening and if anyone has questions that I might be able to answer due to experience with getting into the business, I would be more than happy to do so.

Margie and Edward
Healing Acres Goat Dairy

kuskolady said...

Emily:

I've been trying to post and it's not coming through. I'm going to write you an e-mail about what I see as good and bad about the regs. As you remember, we just built a Grade A Goat Dairy.

Thanks
Margie Buchwalter
Healing Acres Goat Dairy, LLC

kuskolady said...

I meant to say that we are NOW licensed.