Call the Governor and Attend IDPH Hearing Nov. 6 Stop Illinois Department of Health from Adopting Any Raw Milk Regulations November 6, 2014
The Illinois Department of Public Health (IDPH) has falsely claimed that it must issue raw milk regulations to be in compliance with federal requirements. There is no federal requirement that any state issue regulations on raw milk for human consumption. A big turn out for the hearing on November 6 is important in the effort to defeat the regulations. Shortly after the hearing on November 6, the Joint Committee on Administrative Regulations (JCAR) will begin its review of the proposed regulations; this legislative committee has the power to reject them. A transcript of the hearing will be sent to JCAR; so, the more people on record at the hearing opposing the rules means a better chance JCAR will vote them down.
The proposed rules undermine the Governor Quinn's efforts to promote local food and small farms. Within in the past ten years, 20% of the state's conventional dairy farms have gone out of business. Imposing burdensome regulations on Illinois raw milk producers will cause even more dairies to shut down. The governor has the power to order IDPH to withdraw the proposed rules. For over 30 years, the unlicensed on-farm sale of raw milk has been legal by policy in Illinois. It's a policy that has worked well with no reports of foodborne illness attributed to Illinois raw milk producers going at least as far back as 1998, if not further back. The proposed rules even prohibit unlicensed dairy farmers from giving raw milk to guests at their homes. An official with IDPH has admitted that the regulations the department wants to become law would not be passed by the Illinois Legislature if submitted as a bill. If it won't pass through the people's branch of government, why should the agency adopt it as law?
See Talking Points and More Information below. Please pass this alert on and ask others to do the same.
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Action #1 - Call the Governor's OfficesAsk Gov. Quinn to Order IDPH to Withdraw the Proposed Raw Milk Regulations
Call the Governor's offices in Springfield (217-782-0244) and Chicago (312-814-2121). Gov. Patrick "Pat" Quinn needs to hear from Illinois residents.
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Action #2 - Attend the IDPH Hearing on November 6Whatever You Can Do - Show up, Speak up, Write up
A transcript of the hearing will be sent to JCAR [Joint Committee on Administrative Regulations] as it begins to review the proposed rules. Thursday 9 a.m. to 4 p.m.
Illinois State Fairgrounds - Illinois Building 801 Sangamon Ave. (near Gates 1 & 12) Springfield, IL 62702 [directions] You may use the Talking Points below in crafting your statement. See More Information to better understand the issues. |
Talking PointsTell IDPH why raw milk matters in Illiois
Let officials know how consuming raw milk obtained from raw milk producers has benefited your health and the health of your family. Talk about the public health impacts: - If it's not broken, don't fix it. The proposed regulations are a solution in search of a problem. There have been no cases of foodborne illness outbreaks attributed to Illinois raw milk producers going at least as far back as 1998 if not further back. The state policy of allowing unlicensed on-farm sales of raw milk has been in existence for over thirty years and has worked well.
- Clear lines of traceability are inherent in direct sales of raw milk from the farm to consumers--a component of any sound public health system.
- Raw milk producers typically are small farms having only a few animals or small herds and are able to provide the kind of attention that is needed to make sure every animal is healthy and the milk is produced and sold in a sanitary manner compared to larger pasteurized dairy operations that have hundreds and hundreds of cows' milk combined together creating a situation where the same care and attention is not possible.
- There is no federal requirement that any state issue regulations on raw milk for human consumption. IDPH has falsely claimed that it must issue regulations to be in compliance with federal requirements; instead, IDPH should be directed to focus on real public health issues in the industrial food system.
- This is a freedom of choice issue. If consumers want to buy raw milk from an unlicensed producer, that should be their prerogative. IDPH doesn't need to be protecting consumers from themselves, especially with the Illinois producers' strong track record for safety.
Talk about the economic impacts: - The regulations will hurt the local economy. A number of Illinois raw milk producers have indicated that if the regulations go into effect, they will either quit the dairy business or go underground and continue to sell without the license required by the regulations. The net effect will be that access to locally produced raw milk will not be as great, causing consumers to spend more of their food dollars on out-of-state sources.
- Rules meant for large-scale, multi-farm dairy operations are being proposed for small family farms that sell small quantities direct to the final consumers, while also prohibiting those farms from selling raw milk anywhere but the farm. Complying with the requirements will be cost prohibitive for many.
- As environmentally-conscious stewards of the land, family farmers that produce raw milk are predominantly diversified farms focused on sustainability and providing local food for their communities. Many depend on the income from raw milk to supplement their other farming income streams.
- The proposed rules are a job killer at a time when Illinois, especially rural Illinois, and family farmers are already struggling economically.
- The proposed rules undermine the governor's efforts to promote local food and small farms. Within in the past ten years, 20% of the state's conventional dairy farms have gone out of business. Imposing burdensome regulations on Illinois raw milk producers will cause even more dairies to shut down.
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More Information
The Illinois Department of Health (IDPH) issued proposed regulations on September 5th that a number of raw milk producers believe would put them out of business. The proposed regulations contain sanitary standards that can be arbitrarily applied against producers, provide requirements intruding on the farmer-consumer relationship, and prohibit distribution of raw milk through herdshares and CSAs unless the dairies are in compliance with all requirements for Grade A dairies - a financially impossible standard for small family farms to meet. The proposed rules even prohibit unlicensed dairy farmers from giving raw milk to guests at their homes. The Dairy Group Committee, a subcommittee of the Food Safety Advisory Committee (FSAC), drafted the proposed rules. FSAC, which provides advice on food safety matters to IDPH, is not mandated by statute but is supported through a grant by FDA, the most anti-raw milk government agency in the U.S. For a time, raw milk producers and consumers were on the subcommittee but raw milk proponents were only on the committee to give the appearance that there was a consensus on the drafted rules. IDPH officials and people from the dairy industry controlled the subcommittee and ignored all recommendations for the rules submitted by the raw milk producers and consumers.
The proposed rules actually contain a statement by IDPH denigrating the product it is supposed to be objectively regulating, a statement that has nothing to do with any actual requirements in the proposed regulations.
IDPH's propaganda missive reads: The consumption of raw milk increases the risk of foodborne illness because the milk may contain harmful organisms (bacteria, parasites, etc.). Clinical and epidemiological studies have established a direct association between gastrointestinal illness and the consumption of raw milk. Proper pasteurization of raw milk is the only proven, reliable method to decrease the amount of harmful organisms to levels safe for human consumption. [p. 13] Outside of this gratuitous shot that has no place in any law, the proposed rules include unreasonable provisions: - A producer with even just one cow or goat would be required to have a permit and would be subject to regular inspections and testing.
- Sanitary standards that can be arbitrarily applied against producers to shut them down even when there is no threat to the public health. For example: "the flanks, udders, bellies and tail of all lactating dairy animals shall be free from visible dirt." and "all milking equipment shall be stored in a dust-tight room..."
- Prohibition on giving away milk to guests at the farm of unlicensed producers.
- Prohibition on herdshares and the distribution of raw milk through community supported agriculture (CSAs) unless the producer is in compliance with all requirements for Grade A dairies which produce raw milk for pasteurization - a financially impossible standard to meet for just about all shareholder and CSA dairies.
Zoning restrictions imposed on farms that distribute raw milk to shareholders and CSA members at a farm; that is, such a farm may not be located "within an incorporated area of a municipality, within 1.5 miles of an incorporated municipality, or within an unincorporated urban area." What this has to do with protecting the public health is anyone's guess. Intrusion into the farmer-consumer relationship by requiring farmers to maintain records of each transaction with the customer name and address, to issue IDPH-approved "consumer awareness information with each sale or transaction", and to provide "instructions for the consumer to notify the local health department for the area in which the consumer resides of a consumer complaint or suspected foodborne illness." Are producers of any other foods required to do this?
Stay tuned for future alerts. For updates, please check the Illinois Alliance for Raw Milk facebook page and this webpage.
Read FDA Driving Illinois Raw Milk Regulations |
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Farm-to-Consumer Legal Defense Fund, a 501(c)(4) nonprofit [EIN 20-8605130], defends the rights and broadens the freedoms of family farms and artisan food producers while protecting consumer access to raw milk and nutrient-dense foods. Learn more About Us or read the FTCLDF 2013 Summary.
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Please forward this alert to others who are concerned about protecting locally-sourced nutrient-dense foods and preserving sustainable small family farms and artisan food producers as well as defending the rights to sell and to access the foods of one's choice from the source of one's choice. |
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