Michigan–Bills to Legalize Raw Milk Sales

In 1948, Michigan became the first state to require mandatory pasteurization laws for all raw milk sold to consumers. Since that time, as far as is known, the legislature has not come close to reversing that freedom-robbing mandate and legalizing raw milk sales in the state. That could be changing. A trio of bills to legalize the sale of raw milk and raw milk products has been introduced in the legislature. It looks like the bills—House Bill 5217 (HB 5217), House Bill 5218 (HB 5218), and House Bill 5219 (HB 5219)— have some traction. Each of the
bills has thirty-seven cosponsors. All three bills have been referred to the House Committee on Government Operations.

Currently, raw milk distributed through herdshare operations is legal by written policy in the state; the Michigan Department of Agriculture and Rural Development (MDARD) has stated that it won’t enforce the mandatory pasteurization law for the distribution of fluid raw milk through a written herdshare agreement. In issuing the written policy in 2013, MDARD adopted the recommendations in Report of the Michigan Fresh Unprocessed Whole Milk Workgroup (for sale at WAPF), a report worked on by people from MDARD, the dairy industry, academia, shareholder dairies and raw milk consumers. MDARD limited the policy to fluid raw milk and maintained the ban on other raw dairy products, except for raw cheese aged sixty days (which, unlike the herdshare operation, required licensing and inspection). In spite of a subsequent court ruling holding that a herdshare dairy’s distribution of raw butter, raw cream and other dairy products to shareholders did not violate either the state dairy laws or Food Code, the department has still maintained that distribution is limited to raw milk despite the legal precedent against MDARD’s stance.

The three bills amend the Grade A Milk Law of 2001, the Manufacturing Milk Law of 2001, and the Food Law of 2000. Michigan legislative rules require a separate bill for amendment of each law. All three bills must pass for raw milk sales to be legal in the state.

The bills collectively legalize unlicensed sales by “direct farm-to-consumer producers,” or the producer’s “designated agent,” if the producer is in compliance with labeling and testing requirements for the raw milk or raw milk product sold. Sales under the bills must be direct-to-consumer only and can take place at farmers markets, farm stands, private food clubs, buyers clubs or cooperative distribution hubs; sales at retail stores are prohibited. Producers selling raw milk and raw milk products must file a notice with MDARD not less than ninety days before starting sales.

So far, Arkansas is the only state with a statute waiving liability for raw milk producers. HB 5219 creates a partial waiver of liability. That bill provides, “A member of the private food club shall sign a waiver that states the member understands and assumes the health risks of acquiring food outside the traditional commercial framework.” For other transactions, HB 5219 requires that the producer or designated agent provide the final consumer with a waiver stating, among other things, that “the raw dairy product is not regulated ; a statement that the consumer accepts the risk of consuming the raw dairy product; [and] an affirmation that the final consumer is making an informed, voluntary purchase.” The consumer is not required to sign any waiver. In foodborne illness lawsuits, courts do not favor waivers of liability (if they are not codified in statute); with the strong language favoring waiver in HB 5219, it will be interesting to see what happens if the bill becomes law.

A challenge for the bills’ proponents is that the Michigan legislature has little or no history of passing any kind of food freedom legislation. The legislature, unlike most legislatures, meets year-round; for alternate-year-meeting legislatures in states like Massachusetts, New Jersey and New York, there is also little track record of passing local food legislation. Traditionally, in Michigan, there has been a strong alliance between leadership in the legislature and agribusiness, which does what it can to stop any local food initiative from getting traction. Still, with a slowdown to the booming demand for raw milk nowhere in sight, now is a good time to end the prohibition on raw milk sales in Michigan.

Ohio–House Bill 406

A bill that has received considerable media attention is Ohio House Bill 406 (HB 406), the Farm-to-Consumer Access to Raw Milk Act, a bill that would legalize the licensed sale of raw milk from producers direct to consumers on the farm and at registered farmers markets. Currently, the distribution of raw milk only through herdshare agreements is allowed in Ohio via a state policy that has been in place since 2007.

HB 406 calls for heavy regulation of raw milk producers. It mandates that the Secretary of Agriculture “adopt regulations governing the sanitary production, storage, transportation, manufacturing, handling, sampling, testing, examination, and sale of raw milk to the ultimate consumer and for animal feed.” The rules must include a requirement that a raw milk producer “enroll in a quality milk production service program.”

The bill prohibits any sales unless the customer signs a liability waiver developed by the Ohio Department of Agriculture (ODA). HB 406 calls for the waiver to contain language acknowledging the risks of consuming raw milk.

Under Ohio’s current herdshare policy, raw milk dairies have been pretty much left alone; there have been few, if any, enforcement actions against herdshare operations. The question is why would any herdshare farmer want to get a license to sell raw milk, with all the requirements ODA will be mandating under its broad rule-making power HB 406 and with the high cost of compliance with HB 406 regulations.

HB 406 has received considerable media attention, but any favorable publicity the bill receives means nothing in the face of the regulatory obstacles before raw milk producers. In recent years, the raw milk bills that have passed in states like Arkansas, Iowa, Louisiana, North Dakota and West Virginia have all called for little or no regulation of raw milk producers with no license requirement. If Ohio were to legalize raw milk sales, the legislature there should pass something similar; otherwise, the herdshare dairies will continue on with their same operations.

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ARKANSAS – Liability Waiver for Raw Dairy Products

One of the biggest obstacles to meeting the explosive demand for raw milk is the lack of affordable product liability insurance. A Colorado dairy farmer who recently tried to obtain a policy said that the cheapest premium she found was six thousand dollars per year, an amount that is not cost-effective for the many micro-dairies with under ten cows that are seeking insurance. A California insurance broker who provides product liability policies remarked that the minimum payment for product liability from his company would be about nine thousand dollars, which would cover the premium and other costs. Many companies who write policies for raw milk producers write policies for only licensed and inspected producers; there currently are over twenty states where, by statute, an unregulated producer can legally sell or distribute raw milk.

Insurers, such as Farm Bureau, won’t write a policy for a farm that produces and distributes raw milk, not even issuing a policy that has an exclusion for that activity. Raw milk has a good track record for safety. In 2020, a year when demand for raw milk went up substantially, there were five foodborne illness outbreaks attributed to consumption of the product totaling twenty-eight illnesses, one hospitalization and no deaths. According to CDC data for 2005-2020, leafy greens accounted for nearly fifteen times the number of illnesses that raw milk consumption did, yet leafy green growers haven’t been reported to have had anywhere near the problems that raw milk producers have had in obtaining product liability insurance. The lack of affordable insurance, or lack of insurance—period—has deterred potential high-quality raw milk producers from getting into the business; it has also moved high-quality producers to leave the business.

Insurance industry practices are a major barrier to health for Americans; it’s way past time for Congress to revoke that industry’s antitrust exemption. The insurance problem raw milk producers have raises the question of whether state legislatures should immunize them from liability to provide the protection that insurance companies refuse to offer, as well as to facilitate bringing enough product into the market to meet the booming demand. State bar associations have usually been able to stop liability waivers for producers from passing into law, but there is one state that has adopted a liability waiver for raw milk products. Arkansas statute requires that a sign at the point of sale and a label on the milk container include the following statement, “The consumer assumes all liability for health issues that may result from the consumption of this product.”

Before 2025, the Arkansas law (Arkansas code 20-59-248) allowed the unregulated on-farm sale of an average of five hundred gallons a month of raw milk. This year the state legislature amended the law substantially, taking the cap off sales and expanding venues to include farmers markets, “natural food stores” and delivery from the farm where the milk was produced.

The new law also allows sales of any raw milk product. Producers selling a raw dairy product at farmers markets, natural food stores, or through delivery must include the following statement on the label, “Warning: This product, sold for personal use and not for resale, is a product that has not been pasteurized and may contain harmful bacteria that can cause serious illness. The consumer assumes all liability for health issues that may result from the consumption of this product.” In addition, a consumer obtaining raw dairy at any of the venues added by the new law must sign “an acknowledgment of risk that the consumer assumes all liability for health issues that may result from the consumption of the raw milk product.”

With the new law, Arkansas joins Wyoming as the only states to allow the sale of raw dairy products from unregulated producers in retail stores. The Arkansas legislature would not have undertaken this significant expansion of the law if it didn’t think the statutory liability waiver was working effectively. If raw milk producers can’t get a fair shake from the insurance companies, liability waivers could be the needed step to meet the unprecedented demand that currently exists for raw dairy products.

States could try to set up their own insurance pools for raw milk producers, but that’s a long shot. If the consumer as a clear warning that there is no legal recourse for illness, the liability waiver should be an option for state legislatures to consider.

FLORIDA – Keely Farms Dairy

Raw pet milk, as far as is known, has never been implicated in any foodborne illness outbreaks in Florida before, but that changed this past August when, in a series of press releases, the Florida Department of Health (FDH) accused Keely Farms in new Smyrna Beach of sickening twenty-one people with Campylobacter and Shiga toxin-producing E. coli (STEC). According to FDH, there have been twenty-one cases since January 24, 2025, including six children under the age of ten, and seven hospitalizations linked to consumption of raw milk from Keely Farms; severe complications have been reported in at least two cases.¹

While there were complaints from customers claiming that their milk had made them sick, the FDH press releases provided no evidence linking Keely Farms to the illnesses. If a government agency alleges that a dairy has made people sick, the usual procedure is for the agency to issue or obtain an order shutting down the farm until it shows it has rectified the conditions that led to the outbreak. FDH did not serve Keely Farms with an order or a notice of violation, never conducted a farm site visit, nor notified Keely directly that it was under investigation²; the dairy continued to produce raw milk. There was no indication that FDH had taken any milk samples for testing; the dairy sent milk samples to a lab to test for Campylobacter, STEC and mastitis, all of which came back negative.³

The Keely Farms milk was all labeled with a warning, stating “not for human consumption.” The farm website warned customers: “Since federal law prohibits the use of raw milk for human consumption, please DO NOT discuss this issue with us.” Despite the label and website warnings, on August 14, Rachel Maddox filed suit against Keely Farms and a store where she purchased the milk, seeking compensation for illness suffered by Maddox and her two-year-old son; the lawsuit alleges that Maddox lost her pregnancy due to consuming the milk.

If a jury were to find that Keely Farms milk was responsible for the illnesses, the “not for human consumption” warning on the label would not likely exempt the dairy from liability. Under tort law, a producer can be found liable not only if the illness was caused by an intended use of the product but also by a “reasonably foreseeable” use (such as the use of pet milk for human consumption).

References

1. Florida Department of Health. (2025, August 4). Florida Department of Health Provides Update on Raw Milk. https://www.floridahealth.gov/newsroom/2025/08/20250806-florida-department-health-provides-update-rawmilk.pr.html 
2. Farm-to-Consumer Legal Defense Fund. (2025, August 27). Floridaʼs Department of Health Is Destroying a Family Farm Without Due Process. https://www.farmtoconsumer.org/blog/2025/08/27/floridas-department-of-healthis-destroying-a-family-farm-without-due-process/ 
3. Farm-to-Consumer Legal Defense Fund. (2025, August 15). Why Is A Family-Owned Livestock Feed Provider Being Persecuted? https://www.farmtoconsumer.org/blog/2025/08/15/why-is-a-family-owned-livestock-feedprovider-being-persecuted/
4. Keely Oxum. (2025, August). Raw Milk Producer and Family Farm in Crisis. https://www.gofundme.com/f/rawmilk-and-farm-sanctuary-in-crisis

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On May 8, 2025, the North Carolina Department of Agriculture and Consumer Services issued a press release entitled, “With raw milk in the news, here is background information and studies on raw milk.” The document provides invalid conclusions, half-truths and distortions of scientific evidence that may misinform and intentionally deceive the public.

The claims made in the press release are not supported by the current body of scientific evidence on benefits and risks of raw and pasteurized milks. Study after study in the peer reviewed literature dispute the claims made in the press release. The press release offers North Carolina citizens entrenched beliefs masquerading as scientific facts that are not supported by scientific evidence. In reality, neither pasteurized nor raw milk is risk free.

Here are the facts that the NC press release left out, each with references that you are encouraged to review and fact-check.

1. The press release does not provide a valid scientific evidence base for claims that raw milk poses inherent public health threats from potential bacterial and viral hazards.

2. Pasteurized milk is a highly processed food that is linked to adverse health effects.

a. CDC reported two thousand one hundred eleven pasteurized milk illnesses and four deaths for 2005-2020.¹

b. Significantly higher outbreaks, hospitalizations and deaths were reported in pasteurized dairy from 2007-2020 of listeriosis compared to raw dairy.²

c. Stillbirth, miscarriage and premature delivery were reported for pasteurized dairy, not raw dairy.²

d. Heating milk (boiling and pasteurization) denatures milk proteins, increasing allergenicity and contributing to inflammatory disease.^3,4

3. Approximately fifteen million raw milk consumers benefit from access.

a. A recent government survey estimated that 4.4 percent of U.S. population consumes raw milk.⁵

b. Multiple sources report that consumption of raw milk is increasing, not decreasing (NielsenIQ figures^6,7 and California production data⁸).

c. CDC reported one thousand six hundred ninety-six raw milk illnesses for 2005-2020;¹ but not inflammatory disease.⁹

d. In one study, children with an allergy to pasteurized milk tolerated raw milk, whereas pasteurized milk induced adverse effects.³

e. Raw milk has a dense and diverse microbiota, similar to the breastmilk microbiota. Both benefit the gut microbiota and immune system function and suppress growth of pathogens.^8-11

4. CDC data indicate that illness associated with raw milk is not increasing in North Carolina or any state.

a. No significant increase was reported for illnesses linked to raw milk (see upper panel of Figure 1 in the referenced study).¹²

b. No significant increase was reported for state outbreaks or illnesses associated with raw milk, nor are rates by state increasing¹ (see Figures 11, 12, and 13 in the referenced study).¹

5. Consuming raw milk complete with intact natural microbes (microbiota) is beneficial to children’s health.

a. Just as children benefit from raw breastmilk and its protective microbiota, children (and adults) also benefit from raw cow or goat milk complete with their protective microbiota that strengthen gut, immune, nervous and respiratory systems.^9,13

b. CDC data for 2005-2020 indicate that no child died in the U.S. from consuming raw milk.¹

c. Children with allergies to pasteurized milk tolerate raw milk with no adverse effects.³

d. In multiple large cohort studies, children exposed to raw milk developed no diarrheal illness, had significantly fewer respiratory and ear infections and were more protected from inflammatory disease.^9,14,15

6. Emeritus Professor Rodney Dietart at Cornell University and colleagues have provided the only peer-reviewed systematic analyses to date of both benefits and risks for raw and pasteurized milks.⁹

a. Claims in the NC press release that raw milk is “inherently dangerous” and that “risks exceed benefits” are not supported by the body of scientific evidence.^9,13

b. These claims appear to be “risk perceptions,” that is, “a person’s subjective judgement or appraisal of risk”¹⁶ and “a blending of science and judgement with important psychological, social, cultural, and political factors”.¹⁷ Thus, risk perceptions are social constructs reflecting ideology, beliefs and economic interests, not estimations based on the accepted framework for evaluating and incorporating scientific evidence^18,19 and quality analysis^20-22 for robust risk analysis.

7. Scientific evidence fails to support the hypothesis that avian influenza H5N1 transmits to humans by ingestion.

a. Avian influenza H5N1 is not a foodborne pathogen that causes stomach flu in humans, but a respiratory infection and eye inflammation (conjunctivitis).^23-25

b. All lines of evidence for assessing influenza transmission²⁶ fail to support the hypothesis about oral transmission of avian influenza.

i. Avian influenza H5N1 is not highly pathogenic or highly virulent for exposed dairy workers.^25,27 Mild eye inflammation was reported for forty-one dairy workers in five states (thirty-one in CA, two in MI, one each in CO, NV and TX) exposed to reportedly infected cows.²⁸ No oral infections or pneumonia were documented in dairy workers or consumers.

ii. No disease transmission was observed for non-human primates inoculated with a high oral dose of H5N1,²⁹ while the same dose caused mild illness by the nasal route and severe illness with pneumonia by inoculation into the deep lung of non-human primates. This study was one of forty-four available inoculation studies recently reviewed.⁸

iii. No epidemiologic evidence documents oral transmission of H5N1 to raw milk consumers, even though more than two hundred sixty-three thousand gallons of H5N1- positive raw milk (~4.6 million servings) circulated in the CA retail market last November before a raw milk recall.⁸ No human influenza cases were reported.²⁸

iv. Validated models of transmission for respiratory and ocular exposure exist for influenza A23 but no mechanistic models exist for oral transmission of H5N1.

About the Author

Peg Coleman, MS, MS, is a medical microbiologist and risk analyst who consults on microbial benefits and risks via food and all potential transmission sources. She serves as a Fellow of the Society for Risk Analysis and a peer-reviewer for many scientific journals. Ms. Coleman provides expert testimony on evidence for microbial benefits and risks. For more information, visit Coleman Scientific Consulting (colemanscientific.org).

References

1. Stephenson MM, Coleman ME, Azzolina NA. Trends in burdens of disease by transmission source (USA, 2005-2020) and hazard identification for foods: focus on milkborne disease. J Epidemiol Glob Health. 2024 Sep;14(3):787-816.
2. Sebastianski M, Bridger NA, Featherstone RM, et al. Disease outbreaks linked to pasteurized and unpasteurized dairy products in Canada and the United States: a systematic review. Can J Public Health. 2022 Aug;113(4):569-578.
3. Abbring S, Kusche D, Roos TC, et al. Milk processing increases the allergenicity of cow’s milk-Preclinical evidence supported by a human proof-of-concept provocation pilot. Clin Exp Allergy. 2019 Jul;49(7):1013-1025.
4. Abbring S, Xiong L, Diks MAP, et al. Loss of allergy-protective capacity of raw cow’s milk after heat treatment coincides with loss of immunologically active whey proteins. Food Funct. 2020 Jun 24;11(6):4982-4993.
5. Lando AM, Bazaco MC, Parker CC, et al. Characteristics of U.S. consumers reporting past year intake of raw (unpasteurized) milk: results from the 2016 Food Safety Survey and 2019 Food Safety and Nutrition Survey. J Food Prot. 2022 Jul 1;85(7):1036-1043.
6. Aleccia J. Raw milk sales are up despite bird flu outbreak in dairy cows. Fast Company, May 14, 2024. https://www.fastcompany.com/91124899/raw-milksales-rise-bird-flu-outbreak-dairy-cows
7. Lyubomirova T. Bird flu latest: FDA raises raw milk risks awareness, studies pasteurization effectiveness. Dairy Reporter, Jun. 26, 2024 (updated Jun. 27, 2024). https://www.dairyreporter.com/Article/2024/06/26/FDA-tellsconsumers-to-know-the-risks-of-raw-milk/
8. Coleman ME. Deliberating the scientific evidence base for influenza transmission to raw milk consumers. Risk Anal. 2025 Jul 15.
9. Dietert RR, Coleman ME, North DW, et al. Nourishing the human holobiont to reduce the risk of non-communicable diseases: a cow’s milk evidence map example. Appl Microbiol. 2022;2(1):25-52.
10. Coleman ME, Oscar TP, Negley TL, et al. Suppression of pathogens in properly refrigerated raw milk. PLoS One. 2023 Dec 12;18(12):e0289249.
11. Butler MI, Bastiaanssen TFS, Long-Smith C, et al. Recipe for a healthy gut: intake of unpasteurized milk is associated with increased Lactobacillus abundance in the human gut microbiome. Nutrients. 2020 May 19;12(5):1468.
12. Koski L, Kisselburgh H, Landsman L, et al. Foodborne illness outbreaks linked to unpasteurised milk and relationship to changes in state laws – United States, 1998-2018. Epidemiol Infect. 2022 Oct 25;150:e183.
13. Coleman ME, North DW, Dietert RR, et al. Examining evidence of benefits and risks for pasteurizing donor breastmilk. Appl Microbiol. 2021;1(3):408-425.
14. Loss G, Depner M, Ulfman LH, et al. Consumption of unprocessed cow’s milk protects infants from common respiratory infections. J Allergy Clin Immunol. 2015 Jan;135(1):56-62.
15. von Mutius E. The microbial environment and its influence on asthma prevention in early life. J Allergy Clin Immunol. 2016 Mar;137(3):680-689.
16. Aven T, Ben-Haim Y, Andersen HB, et al. Society for Risk Analysis Glossary. Society for Risk Analysis, updated August 2018. https://www.sra.org/wp-content/uploads/2020/04/SRA-Glossary-FINAL.pdf
17. Slovic P. Trust, emotion, sex, politics, and science: surveying the risk-assessment battlefield. Risk Anal. 1999 Aug;19(4):689-701.
18. Marks HM, Coleman ME, Lin CT, et al. Topics in microbial risk assessment: dynamic flow tree process. Risk Anal. 1998 Jun;18(3):309-328.
19. Food and Agriculture Organization. Principles and Guidelines for the Conduct of Microbiological Risk Assessment. CAC/GL-30, 1999. https://www.fao.org/4/y1579e/y1579e05.htm
20. Lathrop J, Roed W, Ackerlund S, et al. SRA Risk Analysis Quality Test Release 1.0. Society for Risk Analysis, 2020. https://www.sra.org/wp-content/uploads/2020/08/SRA-Risk-Analysis-Quality-Test-R6.pdf
21. Waller R, Coleman M, Denard S, et al. Lessons identified from applications of the Risk Analysis Quality Test Release 1.0. Risk Anal. 2024 Aug;44(8):1886-1895.
22. Lathrop J, Dikmen I, Soane E, et al. Defining and assessing risk analysis quality: insights from applications of the SRA risk analysis quality test. J Risk Res. 2024;27(8):1028-1040.
23. Jones RM, Adida E. Influenza infection risk and predominate exposure route: uncertainty analysis. Risk Anal. 2011 Oct;31(10):1622-1631.
24. Lockhart A, Mucida D, Parsa R. Immunity to enteric viruses. Immunity. 2022 May 10;55(5):800-818.
25. Mostafa A, Naguib MM, Nogales A, et al. Avian influenza A (H5N1) virus in dairy cattle: origin, evolution, and cross-species transmission. mBio. 2024 Dec 11;15(12):e0254224.
26. Killingley B, Nguyen-Van-Tam J. Routes of influenza transmission. Influenza Other Respir Viruses. 2013 Sep;7 Suppl 2(Suppl 2):42-51.
27. AbuBakar U, Amrani L, Kamarulzaman FA, et al. Avian influenza virus tropism in humans. Viruses. 2023 Mar 24;15(4):833.
28. H5 bird flu: current situation. CDC, Sept. 16, 2025. https://www.cdc.gov/bird-flu/situation-summary/index.html
29. Feldmann H, Rosenke K, Griffin A, et al. Orogastric exposure of cynomolgus macaques to bovine HPAI H5N1 virus results in subclinical infection. Preprint from Research Square, 18 Oct 2024. https://europepmc.org/article/ppr/ppr927429

This article was published in the Fall 2025 issue of Wise Traditions in Food, Farming, and the Healing Arts, the quarterly journal of the Weston A. Price Foundation. Become a member today to begin receiving this valuable resource by mail.

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Throughout medical history, doctors have recognized occasions when there is a potential need for transfusions of blood or blood substitutes.¹ The West’s search for substitutes began in earnest in the 1600s, with substances such as “beer, urine, milk, plant resins, and sheep blood” taken into consideration as possible replacements.² Two centuries later, however, the concept of blood transfusion still remained both novel and experimental.

Alfred François Donné—a nineteenth century pioneer of microscopy, microbiology and the study of blood³—explored milk’s potential uses by injecting it into the veins of dogs and rabbits. Reports that this experiment had produced no negative effects got some clinicians interested in trying out intravenous (IV) milk transfusion on humans. They believed that there were similarities between blood, milk and a milky-white fluid called chyle. Although their view that blood was made out of chyle was erroneous (chyle, made of lymph fluid and fats, actually forms in the small intestine during digestion and travels from there to the blood), physicians wondered whether milk might be a safe blood substitute.

Importantly, these pioneers viewed blood as a living substance, something that “in obedience to laws which govern its origin and death…cannot be for any appreciable time removed from the circulatory condition without undergoing change.” This understanding led most to conclude that any milk used for transfusion had to be milk that likewise had “not parted with life”⁴—in other words, it needed to be perfectly fresh.

Nineteenth-century medical journals went on to publish numerous case reports describing the successful use of IV milk for a wide range of conditions, including anemia, cholera and severe diarrhea, pulmonary and other forms of hemorrhage, kidney disease, typhoid fever, ulcers, wasting diseases such as tuberculosis (TB) and conditions that we would now associate with cancer. However, the literature also documents failures and adverse reactions in both humans and animals, possibly related to poor-quality milk or the use of too much milk. When scientists began to perfect IV saline solutions in the 1880s,⁵ practitioners largely lost interest in IV milk.

“Fresh Living Milk” Saves the Day for a Cholera Patient

In the 1800s, cholera had become a frightening scourge of industrializing cities.⁶ Characterized by severe, rapid-onset diarrhea and sudden depletion of body fluids and salts,⁷ cholera could kill a person within a few hours of symptom onset. As Britannica explains, the “cellular pumping mechanism that controls the movement of water and electrolytes between the intestine and the circulatory system…effectively becomes locked in the ‘on’ position, causing the outflow of enormous quantities of fluid. . . into the intestinal tract.”⁷

Clinicians of the era observed that the blood of cholera patients had unique characteristics (later understood as the result of the severe dehydration and electrolyte imbalances), including being “thick” and lacking viscidity (stickiness or viscosity). They concluded that patients would benefit from new blood or a blood substitute, and fresh milk presented an intriguing option.

In Toronto, two prominent physicians had the opportunity to give IV milk a trial run in July 1854 during a local cholera epidemic. Dr. Edward Mulberry Hodder (1810–1878), born in England, had moved to Canada in 1838 to teach at Trinity College Medical School. Credited as the “father of obstetrics and gynecology” in Ontario, Hodder pioneered the use of carbolic acid as an antiseptic in surgery and childbirth⁸ (see the “From the Archives” article in this issue of Wise Traditions for Dr. Herbert Snow’s thoughts on carbolic acid). Dr. James Bovell, too, was a leading figure in Canadian medical circles, including as a researcher and mentor.⁹ Both doctors were unhappy with the failure of public health authorities to ensure a clean water supply and clean up the filth contributing to cholera.¹⁰

The 1854 epidemic prompted the improvised establishment of a “cholera shed,” which may have been part of a hospital or perhaps a building hastily given “hospital” status to isolate the overload of cholera patients from the healthy. Describing the situation, Bovell wrote, “Wards became overcrowded; the sick had neither utensils nor proper bedding, nor food for their accommodation; and much distress arose.”⁴

At about 10:00 pm on July 9 of that year, Thomas Harrison, a forty-year-old Irish farmer who had immigrated to Canada, developed sudden nausea, a “tendency to fainting” and diarrhea. After first being given medicines that provided no benefit, he was transferred to the cholera shed at 10:00 am the next morning, by which time he was in serious condition: “pale and cadaverous, sunken and cold,” with vomiting, cramps and a weak pulse.⁴ By 1:00 pm, it looked as though Mr. Harrison would soon die.

In the face of Harrison’s distress, Drs. Hodder and Bovell proposed the experimental procedure of transfusing “fresh living milk.” Because the two doctors’ colleagues were worried that the procedure might kill Harrison and stir up unwelcome public attention, Hodder and Bovell delayed their IV intervention “until there could scarcely be a doubt that death was imminent.” Here is how Bovell described that moment:

“At about 3 o’clock the prostration had greatly increased; the man lay on his back, with his eyes sunken, countenance of ashy hue, hands cold, tongue equally so, breath drawn in gasping sighs, and the pulse gone from the wrist. We now, therefore, commenced the operation.”⁴

The procedure involved bringing a cow that happened to be “grazing close at hand” (on lush green summertime grass, no less) to the cholera shed, for the doctors believed it essential to use milk that was full of life. Filling a four-ounce brass syringe, the two physicians slowly injected the milk into the patient’s veins, all the while monitoring his pulse. Hodder later described the dramatic events:

“I ordered a cow to be driven up to the shed, and while she was being milked into a bowl (the temperature of which was raised to about 100° Fahr.) through gauze, I opened a vein in the arm and inserted a tube, and then filled my syringe (also previously warmed), and injected slowly therewith. No perceptible change, either for better or for worse, took place; so after waiting two or three minutes, I again filled the syringe and injected seven ounces more. The effect was magical; in a few minutes the patient expressed himself as feeling better; the vomiting and purging ceased, the pulse returned at the wrist, the surface of the body became warm—in fact, the man rallied, and speedily recovered without a bad symptom.”¹¹

Bovell elaborated:

“[A]lmost simultaneously the eyes responded, the half-closed lids being raised, the lustreless orbs giving utterance to the relief which was being given, while deep and well-drawn inspirations told how readily the lungs responded to the vital tide which now flowed towards them. . . . [T]he voice, which was unearthly before, was clear, though not strong; and whereas, before the operation he was perfectly careless and, indeed, reckless as to his personal safety and the care of his family, almost his earliest thoughts were directed to the welfare of his children and wife.”⁴

Keeping their patient warm with hot water bottles and a turpentine rub, the two doctors gave him small amounts of “strong beef tea whenever he would take it,” along with two egg whites and an ounce of brandy. After getting a “tolerable” night’s sleep, Harrison woke with no further vomiting, diarrhea, pain or cramps. In fact, the diarrhea vanished so precipitously that one doctor gave him a laxative! Six months later, history tells us, Harrison was still alive.

Although the scientific understanding of blood in the 1850s might not have been perfect, the logic in favor of milk as a blood substitute held some truth. Milk is full of white blood cells—including neutrophils, lymphocytes, monocytes, immunoglobulin and epithelial cells—that perform a wide range of immune functions. In reversing Harrison’s diarrhea and contributing to his full recovery, the IV injections of raw milk appear to have strengthened his immune system while supplying the hydration and electrolytes that the depleted man so badly needed.

Other Toronto Transfusions

On July 13, Hodder and Bovell had the opportunity to repeat their success with a nursing mother of four, Irish immigrant Mary Hall. Admitted to the cholera shed with symptoms similar to Harrison’s, Hall initially was given silver nitrate¹² and, every half-hour, beef-tea, brandy and egg; when the next morning found her continuing to experience diarrhea, with an “extremely feeble and quick” pulse, a “countenance pinched and of ghastly hue,” a “cold and pointed” tongue and seeming restless and “careless about her fate,” the two doctors decided to repeat the procedure used to such good effect a few days earlier:

“Two syringes full, equal to 8 oz., of the fresh warm milk from the same cow which afforded the supply to Harrison, were injected into the vein. As soon as the operation was completed, she expressed the greatest relief, and seemed irresistibly impelled to draw deep and frequent inspirations.”⁴

By July 17, a fully recovered Hall was able to return home.

In his report describing these experiences, Bovell explains that he did two further milk transfusions, apparently without Hodder’s help, with patients who again were nearly at the point of death. In both cases, the patients initially seemed to benefit from the transfusion but died within a day. In one case, Bovell describes the woman in question as having “veins…so empty and small, that I was for some time foiled in my endeavours to find one.”⁴

Bovell subsequently fell ill himself and could not continue caring for cholera patients. Mr. John Mackenzie, a medical student credited by Bovell as being extremely competent and diligent, stepped up to help. Mackenzie administered IV milk transfusions to three more patients who arrived in extremis; unfortunately, despite seeming to “revive” posttransfusion, all three died. Bovell’s report mentions in passing that one of them, “a very athletic young man,” was first given calomel¹³ (a toxic mercury compound); it is possible that the others, too, were mercury poisoned before their transfusions.

Considering that all seven patients were in serious condition at the time of transfusion, it is noteworthy that fresh milk saved two out of seven and caused nearly all to experience some visible improvement. Is it possible that more might have survived if the milk had been injected sooner or if enough milk had been injected to provide sufficient rehydration? Notably, Hodder, with two out of three patients surviving, had the best track record, suggesting that he may have used precautions not followed by Bovell or Mackenzie.

Successes and Failures in America

According to the historical documents that I’ve found, no one attempted milk infusions again for about two decades. In 1873, Dr. Joseph Howe, a New York City physician who had read about Hodder’s successes, tried injecting raw goat’s milk into a TB patient who had been unable to eat and was literally dying of starvation.¹⁴ The liquid Howe used, which had been milked about three hours previously and transported by train,¹⁵ did not yield good results. After IV injection of just one and a half ounces, the patient reported vertigo and chest pain and displayed involuntary eye movements, with a renewal of those symptoms after being given three more ounces of milk (“retained at room temperature”) later that day. Although the pulse seemed improved and the man reported feeling better, he died (reports differ on whether he perished the next day or four days later). Howe’s next milk injection recipient (another terminal TB patient) died a mere four hours post-transfusion.

Before trying again with humans, Howe sought to repeat Donné’s experiment, injecting raw milk into dogs; when all seven dogs died, he wondered whether the “excessive volume of milk given to the dogs, rather than the milk itself…killed them.”¹⁴ Other physicians of the day speculated that the failures in humans and animals might be the result of not using fresh milk obtained mere minutes before, as Hodder had done when he conscripted a healthy nearby cow into service. Along those lines, Dr. Eugene Dupuy concluded around the same time that whereas “the intravenous injection of decomposed milk into dogs is uniformly fatal…the same experiment, if practised with perfectly pure and fresh milk, is entirely innocuous.”¹⁵

In 1878, Howe made a third attempt with goat’s milk, intravenously administering four ounces to a woman with advanced pulmonary TB (historically known as “phthisis”) who then reportedly experienced “marked improvement.”¹⁶ However, when Howe subsequently injected human breastmilk into a woman suffering from abscesses on her ribs and vertebrae as well as intestinal inflammation, the patient’s pulse spiked and then became intermittent; in addition, her breathing became “labored and irregular” and then stopped, forcing the team to revive her by artificial respiration.¹⁷ She died ten days later. An autopsy seemed to exonerate the IV milk, instead revealing long-standing intestinal ulcerations, bone necrosis and lung damage from pneumonia; nonetheless, the “unfavorable and alarming symptoms” observed in this case prompted Howe to give up on IV milk. He wrote, “Some have found [transfusion of milk] useful, while others, like myself, consider it a dangerous operation, and one which in no degree possesses the value of blood transfusion.”¹⁷

Another New York City doctor, T. Gaillard Thomas, was an “outspoken advocate of milk transfusion.”¹⁴ In 1875, Thomas adopted the Hodder approach for a thirty-year-old mother who had experienced a severe uterine hemorrhage following the surgical removal of a very large tumor four days prior. At the point when Thomas made the decision to try an IV of “pure, fresh milk,” the woman “appeared to be dying from sheer exhaustion.” He was able to find an Alderney cow (a now-extinct cross-breed of Guernseys and Jerseys) and reported:

“[The] young and healthy cow was driven into the yard, a pitcher with gauze tied over its top was placed in a bucket of warm water, the vein was exposed, and the cow milked at the moment the fluid was needed….The first effect which evidenced itself did so after about three ounces had been injected. Then the pulse became so rapid and weak that Dr. Mitchell…could scarcely detect it. The patient declared that she felt as if her head would burst, and seemed greatly overcome. I went on slowly, however, transfusing the fluid until [eight and a half ounces] had been reached; she was then left perfectly quiet….[T]oward midnight the patient fell into a quiet sleep….The patient steadily progressed to complete recovery.”¹⁸

Thomas’s second patient was a twenty-two-year-old woman with a very large and challenging ovarian tumor who experienced numerous complications and setbacks in the three weeks following its surgical removal. When Thomas observed her to be close to death, he decided to once again try IV milk, obtaining with “great difficulty…a cow from the stable of a gentleman living a mile and a half away,” which “was driven to the door of the pavilion in which the patient lay.” In this instance, five IV injections of milk over a six-day period were unable to vanquish the woman’s incurable “morbid state”; however, Thomas credited the milk with giving the patient—who he initially expected to die within a few hours—a nearly week-long “reprieve.”

In a third case, Thomas injected milk into a woman who again had a large ovarian tumor, but because she was hemorrhaging severely, she died fourteen hours later. Thomas alluded to having performed four additional IV milk transfusions (for a total of seven) but did not provide details.

Based on his success with the first woman—about whom Thomas conservatively stated that while “he would not positively assert that the transfusion of milk saved the life of the patient,” it was “his firm conviction…that it did”¹⁹—and referencing the reported successes of other physicians, Thomas predicted a “brilliant and useful future” for IV milk (see sidebar for a summary of his observations).

In the late 1870s, Dr. Charles T. Hunter performed IV milk transfusions on four patients, two with severe anemia and two with typhoid fever; only one survived. That patient, a thirty-two-year-old woman with “extreme anemia” and “spinal irritability,” received three separate injections of “fresh-drawn” milk heated to 100F°. Although she experienced violent symptoms in response to the first injection (including labored breathing, a variable pulse, chills, hives, “capillary congestion of the face and surface of the body,” bulging eyes, “turgid” lips and “the whole expression wild and alarming”), the medical team administered two more infusions on Days Seven and Twenty. The side effects—the same ones plus some new ones such as headache, nausea, vomiting, cramping and pain—proved temporary, and the woman ended up making a full recovery.²⁰

Hunter’s second anemia patient—a thirty-two-year-old sailor who received three infusions over a two-week period—also experienced severe side effects and only temporary improvement before dying. In this instance, Hunter humbly concluded that the operation had probably “hastened the death of the patient,” but he remained favorably disposed toward IV milk as a last resort in “cases of hemorrhage and great debility.”²¹

Without full information about the entire set of interventions performed on these patients, it is difficult to draw conclusions about whether the milk influenced the fatal outcomes, and an 1879 report about Hunter’s first two cases makes precisely this point. That report ventures the opinion that the side effects might have been an adverse reaction to quinine (both patients received repeat doses of quinine as well as morphine) rather than to the milk.

Both an Art and a Science

Respected Irish surgeon Austin Meldon, based at the Jervis Street Hospital in Dublin, was by far the most successful physician to use IV milk transfusion, performing the procedure thirty-two times with mostly favorable results.¹⁶ When he tallied twenty of his cases, nine of twelve patients with phthisis recovered, as did all four with pernicious anemia, both patients with exhaustion from hemorrhage and one of two patients recovering from typhoid fever.²² As of 1881, Meldon was urging his fellow professionals to give IV milk transfusions a “fair trial,” stating that the procedure seemed “to have fallen into unmerited disrepute” both in the UK and America.¹⁶

In only one early case (a thirty-year-old man with typhoid fever) did Meldon’s intervention elicit immediate and dramatic symptoms similar to those seen in Hunter’s second case, while injecting a larger quantity of milk (ten ounces) than Meldon later came to believe was optimal: “During the injection the pulse increased in force, the patient complained of great cold, and his face became of a dusky hue. No sooner had the operation been finished than the respiration became very much obstructed, the patient gasping for breath, and the fingers, feet, and lips became cold and livid.” By that evening, the patient had significantly improved and continued to strengthen over the coming days. Two and a half weeks later, however, he showed signs of regressing; after the patient rather reluctantly acquiesced to a second transfusion, he died within a few hours.

Like Hodder and others, Meldon came to believe that the properties of the milk were important, and he seems to have mostly gotten it right. Most notable was his revelation that the milk, ideally, should have the same pH level as the blood. (A pH of 7.0 is neutral, values below 7.0 are more acidic, and values above 7.0 are more alkaline.) Normal blood pH is in the range of 7.35 to 7.45. Meldon said,

“Some deaths have occurred during or immediately after the operation, but in these cases the milk was either acid or kept for too long a time, or too large a quantity had been injected. The milk of any animal kept in confinement is slightly acid even when it leaves the udder, and as the blood will not tolerate the presence of an acid, it is not to be wondered at that very unpleasant symptoms often developed when milk in that state has been injected.”

Dr. Abraham Jacobi, known as the founder of pediatrics, shared Meldon’s perspective on the dangers of acidity and seems to have been one of the rare medical professionals to recognize that milk from grass-fed cows was “naturally alkaline.” On the topic of IV milk transfusion (which he did not practice himself), a report summarizing comments by Jacobi noted:

“One reason of the bad effect of milk injections, [Jacobi] thought, was that they might be acid; and he had found that cows were liable to have acid milk in their udders, due probably to their habits or food. It was important that the milk be tested with litmus before being used, as the injection must not only be not acid, but be alkaline.”²³

In one of Meldon’s successful cases, he brought a goat directly into the bedroom of a patient with wasting disease who was bleeding from the lungs and expected to die; he did not allow the goat to be milked until the tube had been inserted into the patient’s vein and he had tested the milk. When testing revealed the milk to be acidic, Meldon added ten grains of carbonate of ammonia to the ten ounces of milk before beginning transfusion. There were no side effects, and the patient “materially improved.” He began to recommend that carbonate of ammonia routinely be added to injected milk to ensure alkalinity.

In an analysis of twenty-two published cases of IV milk transfusion, Meldon grouped the cases into four categories, with the majority (82 percent) falling into the first two: (1) those in which the operation cured the disease; (2) those in which the operation prolonged life; (3) those in which the operation was productive of neither good nor evil; and (4) those in which the operation, in all probability, shortened life.

The Sooner, the Better

In an 1878 Philadelphia medical school lecture, a Dr. John H. Brinton compared blood transfusion and IV milk transfusion, recommending in either case that transfusion be “done early, and before the patient is in a moribund condition.”²⁴ Citing the “great percentage of deaths” that blood transfusions of the era were causing, the “advantages claimed for milk” (such as the elimination of coagulation risks) and the probability of “excellent” outcomes when undertaking IV milk transfusions in a timely manner, Brinton favorably concluded:

“As far as my own practice is concerned, I think that, in future, I shall try the intravenous injection of milk in preference to the transfusion of blood. I have transfused a great many patients. . . and my results have been very far from reassuring. I think the proposed intravenous injection of milk offers us much better results, judging from the cases published….The main obstacle to complete cure. . . thus far has been the very late period of the disease at which the injection has been attempted. Though the exact rationale of the action of milk, thus introduced, upon the system has not been satisfactorily shown, I think this new operation will, in a few years, have entirely superseded the transfusion of blood.”

Determinants of Success

In response to the adverse effects observed by American and British practitioners, Meldon initially proposed that the symptoms could be mitigated by injecting no more than four ounces of milk at one time; a couple of years later, he revised his recommendation upward to no more than six ounces. Other IV milk proponents such as Thomas thought that no more than eight ounces of milk should be injected at one time. A German doctor argued that injection of large quantities of milk into animals “invariably led to the formation of pulmonary emboli.”¹⁴ On the other hand, Hodder uneventfully administered larger doses of milk to his cholera shed patients—including Harrison, who after receiving twelve ounces experienced clear and immediate improvement and no negative side effects.

The generally positive results obtained by Hodder and Meldon, on the one hand, versus the more problematic results of doctors like Hunter and Howe raise interesting questions about the variables that most influenced IV milk transfusion outcomes. Based on my reading of various case reports, I believe the most significant factors probably included:

• The type of disease treated
• The baseline condition of the patient
• Other factors related to their care (such as the concurrent administration of substances like silver nitrate, calomel, quinine and morphine)
• The amount of milk injected
• The way the milk was handled
• The amount of time that elapsed between milking and injection
  Factors specific to the practice of injection (e.g., sterility and equipment)
• The quality of the milk

Both ancient wisdom and modern science solidly confirm that milk from grass-fed cows is nutritionally superior and has more “life” and “health” than milk from grain-fed cows. Milk from grass-fed ruminants also has a higher pH,²⁵ which makes it more compatible with blood. Although the historical documents provide almost no information about the animals that supplied IV milk, we know that the Toronto cow who helped Harrison recover was “grazing close at hand,” which means that the cow was eating grass at least on the day of the transfusion. Although this does not prove that the cow was 100 percent grass-fed in the prior weeks, considering Toronto’s climate, geography and culture, it seems likely that in general, the area’s cows were grass-fed, especially in the summer. At the time, Toronto had a population of just thirty thousand and was surrounded by forests and wilderness areas.

It is also worth mentioning that in the Toronto region, June and July are the rainiest months, and the first milk transfusion was on July 10. This would mean that the cow was probably eating fast-growing green grass, which has higher levels of chlorophyll, folate and other nutrients than grass during dry periods, making it ideal for the production of high quality milk. The nutrient profile of milk from cows grazing on grass growing in poor soil or eating dry grass, hay or alfalfa will be lower. As for the milk used by Meldon in his many successful cases, he wrote in 1881, “In any place, whether it be town or country, [milk] is easily procured within a few minutes, and with proper precautions the operation is devoid of danger.”²² In the context of the Dublin of that era (with a population of around six hundred fifty-three thousand), we don’t know what the quality of that “easily procured” milk might have been, especially because he also referred to “animals kept in confinement,” but we do know that he preferred and “invariably used” goat’s milk because it was “much more easy to bring that animal in close proximity to the patient, thus avoiding any unnecessary delay between milking and the injection.”²² We have all seen beautiful photos of Ireland’s rolling green hills, so perhaps the local goats and cows had access to at least some grass and hay.

In 1870, New York City’s population of nearly a million was almost four times larger than that of Dublin. How did a city of that size provision its residents with milk when there was not yet refrigeration and the only forms of transportation were horses, railroads and boats? There were two options. The first was to keep cows and goats inside the city, but without large fields of green grass, the animals had to be kept in barns and stables and given external feed. The second option was to transport milk from dairy farms outside the city. However, dairy farming had already begun shifting away from the small family farm to bigger farms that kept cows in confinement and fed them an unnatural diet. In The Raw Truth about Milk,²⁶ William Campbell Douglass II, MD, says about nineteenth-century New York City:

“Cows in the late 1800s were fed on garbage. The Commissioner of the New York State Health Department. . . reported that cows were milked in a mixture of manure and mud, dust, dirt, filth, and disease—germs were as much the total product that people drank as was the milk itself. On farms, pails that were used to carry slop to the pigs were also used to convey milk to human consumers.”

When cows are grain- and soy-fed (sometimes supplemented by human food waste such as overripe fruit), deprived of access to clean water and sunshine, and milked and handled in unsanitary conditions, it stands to reason that the nutritional profile of the milk will be much lower. Although we don’t have proof that the cows that supplied milk to Drs. Howe, Thomas and Hunter were not grass-fed, it seems unlikely. If we assume that the cows in 1850s Toronto provided the best milk, the goats and cows in 1870s Ireland offered the second-best milk and the cows in 1870s New York produced the worst milk, this fact matches up to the presence and severity of side effects and the success rate of the IV milk transfusions.

In the vast majority of milk injections, doctors in Canada, America and the UK seem to have preferred to use raw milk (then called “fresh milk”). This is evident in the case reports that describe cows and goats being milked on the spot. Boiled and strained milk appears to have been the exception rather than the rule, as in two of Meldon’s successful cases when fresh milk was unavailable. A London surgeon wrote in 1885 that IV injections of both “fresh milk in small quantities, or of milk boiled after standing” were “harmless” but warned, “it is most dangerous to employ ordinary milk not so boiled, and the ordinary London milk is especially deleterious.”¹⁵ In an 1899 paper objecting to the practice of boiling milk, the author noted that boiled milk had significant nutritional disadvantages: “The continuous use of milk sterilized by heat by infants leads to a large number of cases of impaired digestion and nutrition, anemia, rhachitis and scurvy, and in any case a predisposition to any and all infections.”²⁷

The Decline of IV Milk Transfusions

Interest in IV milk transfusions seems to have declined in the 1880s, with the last major article published in 1885. My research suggests that physicians abandoned the practice prematurely, never allowing it to reach its full potential. Any new procedure needs an adequate trial-and-error phase before it is perfected, and IV milk injections do not appear to have received a fair trial. That is too bad, because IV milk transfusions may have offered unique benefits not provided by saline solutions or blood transfusions, including immune system support and the ability to cure severe diarrhea.

The rising popularity of isotonic saline solutions was probably the main reason that physicians lost interest in IV milk (and they likely assumed that saline solutions offered benefits equivalent to IV milk injections), but there were also other reasons:

• Dr. Thomas described “violent prejudice and opposition in the mind of the hearer,” and Dr. Meldon noted that some objected that milk was “unphysiological”; apparently, the idea of injecting milk into the blood just didn’t sound right to some doctors.
• When poor-quality milk was used, the serious side effects and failures that resulted gave the procedure a bad name.
• Physicians considered milk to be a blood substitute, but it wasn’t.
• IV milk was less convenient.
• As the medical community became more aware of the dangers of contaminated milk (due to unsavory industrial dairy practices), doctors became less willing to consider IV milk injections.
• Toward the end of the nineteenth century, scientists discovered that fresh milk was not sterile but contained live bacteria. This, too, would have make doctors less open to injecting milk.

On the other hand, the physicians who witnessed successful outcomes remained IV milk proponents. Meldon frankly stated, for example, “I have made up my mind that I will not allow any patients under my care to die of exhaustion without an attempt to save them by the intravenous injection of milk.”²⁸

Final Words

Dr. Hodder may have been wrong in some of his assumptions about the similarities between blood and milk, but he was correct to assume that milk, like blood, had “life.” As Dr. Weston A. Price once documented, the isolated residents of the Swiss Alps knew all about the “life” in milk and had rituals to honor and celebrate the life in milk and butter when cows were eating fast-growing summer grass. The Maasai, too, knew about the life in milk and insisted that would-be parents (both mothers and fathers-to-be) drink the milk of cows eating the fast-growing green grass of springtime. Dr. Price transformed the lives of some poor and malnourished students in America with nutrition that included “high vitamin butter.”

When modern man began to ignore this wisdom and started embracing “modern” farming techniques, he encountered “death” in the milk. Uncaring industrial dairies and greedy businessmen took advantage of the desire for cheap milk and produced contaminated products that, sadly, often killed babies. When pasteurization became the norm, it may have solved these overt problems of contamination, but it also ensured that there would no longer be any “life” or “health” in the milk. Even if we no longer inject milk, we need good, healthy raw milk, butter and cheese from pastured cows and goats eating healthy, species-appropriate food. This allows milk to remain one of nature’s most perfect foods, with superior nutrition and amazing healing and health-giving properties.

About the Author

Joe Anstett was born in the USA, but a trip to Peru in 2003 changed his life. He now lives in Peru with his Peruvian wife (Ruth) and a 15-year-old son (David). In his early life, Joe would experience severe fatigue and brain fog except after eating a really good meal. This led him on a lifelong quest to find answers, many of which came from the works of Dr. Weston A. Price. Joe currently writes a blog on the health benefits of strontium (a mineral similar to calcium) and its potential benefits to inflammation, mitochondria problems and chronic pain. joeanstett.substack.com.

References

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4. Bovell J. On the transfusion of milk: as practised in cholera, at the cholera sheds, Toronto, July, 1854. Read before the Canadian Institute, January 27th, 1855. https://wellcomecollection.org/works/gukwptjy
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SIDEBAR:

Dr. T. Gaillard Thomas: A Fan of IV Milk

In 1878, New York doctor T. Gaillard Thomas summed up his opinions18 about the merits and how-to’s of IV milk (which he referred to as “intra-venous lacteal injection”) as follows [slightly edited for brevity]:

1. The injection of milk…in place of blood is a perfectly feasible, safe, and legitimate procedure.

2. [N]one but milk removed from a healthy cow within a few minutes of the injection should be employed. Decomposed milk is poisonous.

3. A glass funnel, with a rubber tube attached to it, ending in a very small canula, is better, safe, and more attainable than a more elaborate apparatus, which is apt, in spite of all precautions, to admit air to the circulation.

4. The intra-venous injection of milk is infinitely easier than the transfusion of blood.

5. The injection of milk, like that of blood, is commonly followed by a chill, and rapid and marked rise of temperature; then all subsides, and great improvement shows itself in the patient’s condition.

6. I would not limit lacteal injections to cases prostrated by haemorrhage, but would employ it in disorders which greatly depreciate the blood, as Asiatic cholera, pernicious anaemia, typhoid fever, etc., and as a substitute for diseased blood in certain affections.

7. Not more than eight ounces of milk should be injected at one operation.

8. [I]f milk answers, not as good, but nearly as good, a purpose as blood…its use will create a new era in this most interesting department of medicine.

This article was published in the Summer 2025 issue of Wise Traditions in Food, Farming, and the Healing Arts, the quarterly journal of the Weston A. Price Foundation. Become a member today to begin receiving this valuable resource by mail.

The post Life in the Milk: A History of Intravenous Milk Injections appeared first on Real Milk.

Federal: Should the Interstate Raw Milk Ban be Overturned?

With President Trumpʼs nomination of Robert F. Kennedy, Jr. to be Secretary of Health and Human Services (HHS) and his subsequent confirmation, raw milk has been in the news. RFK Jr. has stated that there should be increased access for Americans to raw milk. Since 1987, there has been a federal prohibition on shipping raw milk across state lines for human consumption and interstate commerce; the U.S. Food and Drug Administration (FDA), the agency within HHS that has jurisdiction over raw milk, issued a regulation establishing the ban.

A question that has come up is: with RFK Jr. in power, is now the time for Congress to pass a law repealing the ban? The FDA established the ban in response to an order from a D.C. federal district court in the 1986 case of Heckler v. Public Citizen. The only raw dairy product currently legal in interstate commerce is cheese aged sixty days; FDA treatment of raw cheesemakers shows the risks involved with lifting the ban and giving FDA complete jurisdiction over any raw dairy product crossing state lines—whereas the FDA does not exercise jurisdiction over dairy products in intrastate commerce.

In 2019, University of Vermont Professor Catherine Donnelly wrote Ending the War on Artisan Cheese, a book detailing the FDAʼs harassment of raw cheese producers. One of the examples she provides is related to harassment of cheesemakers who attended an October 2013 workshop in Georgia titled “Food Safety and Hygiene in Artisan/ Farmstead Cheese-Making,” which was cosponsored by the Georgia Department of Agriculture, the Innovation Center for U.S. Dairy and Whole Foods. The workshop was designed for small-scale cheesemakers and also included invitations to federal and state inspectors—the thought being that many of the inspectors were “not always knowledgeable about artisan cheesemaking.” However, just one day after the workshop, the FDA inspected every single artisan cheesemaker (as well as the two Whole Foods stores that attended the workshop), resulting in detention of some products. As Donnelly states, “The notion that attendance at, or sponsorship of, an education workshop could subject an artisan cheesemaker or cheesemonger to regulatory enforcement defeated the very purpose for which those workshops were intended.”

The American Cheese Society (ACS) is the leading organization in the U.S. supporting the promotion of artisan, farmstead and family cheeses. As Donnelly explains it, “Attendees at the American Cheese Society began to notice some interesting connections between the dates when the annual ACS meetings were occurring and the timing of FDA recall announcements and unannounced visits to their establishments. Cheesemakers would lament that they were unable to bring the quality assurance members of the organization to the ACS annual meetings because it became a matter of routine that unannounced inspections from the FDA occurred during the ACS meetings.

FDA officers would take cheese from producers for “microbiological compliance sampling” which then requires cheesemakers to “withhold the production lots being tested from distribution into commerce until results of the FDAʼs analysis were returned.” Affected companies noticed a pattern: many times results were released only after the products had reached the end of their sell-by dates. And in most cases, the tested products met compliance criteria. They were salable products that fully complied with regulations, but they could not be sold because of regulatory targeting and testing of these goods.

In 2009-2010, FDA changed the tolerance level of generic E. coli in raw milk cheese from ten thousand colony forming units per gram of cheese (cfu/g) to ten Most Probable Number (MPN) per gram in two or more subsamples or greater than one hundred MPN in one or more subsamples. The European Union has established a generic E. coli tolerance level only for pasteurized cheese. The new tolerance levels effectively prohibited artisans from being able to release significant amounts of product into commerce. Extensive sampling by FDA from 2004 to 2006 before the new requirements went into effect showed that about 70 percent of the cheese tested then would not have met the new standard. There is no scientific evidence that these standards lead to safe cheese. Thanks to political pressure, FDA finally halted using the 100/10 MPN standards in 2016.

There is little evidence that FDA has changed its position on raw dairy since the publication of Donnellyʼs book. RFK Jr. and FDA Commissioner Marty Makary are going to have a big challenge changing the FDA culture on raw dairy. Any law Congress passes to overturn the ban should limit FDA discretion in interpreting the law and FDAʼs rule-making power as much as possible.

There are currently forty-seven states that—by statute, regulation or policy—have either legalized milk sales for human consumption, raw milk sales for pet consumption or the distribution of raw milk through herdshare agreements. State legislatures and agencies have eroded the effect of the ban one state at a time.

That said, with greater consumer demand for raw milk than ever before, there are not enough producers or cows to meet that demand. There is a need for many states where sales or distribution are legal to pass more favorable laws bringing more producers on line. Overturning the interstate ban can help make this happen, depending on how tightly Congress controls FDA with the legislation and how much the anti-raw milk bias at the agency changes.

Two sources of additional farmers to meet the unprecedented demand for raw milk are Grade A dairies and homesteaders. Grade A dairies have been the drivers in recent legislation in Delaware and Georgia legalizing the sale of raw milk for human consumption; however, considering the decline in the number of conventional dairy farms in the U.S., not that many Grade A dairies have transitioned to selling raw milk for direct consumption. More farms will start selling raw milk commercially in the homestead community; many homesteaders with a family cow often have excess milk beyond their own familyʼs needs, leading them to sell raw milk to others in their community. The number of homesteaders in the dairy business increases if they can sell raw milk and other raw dairy products direct to the consumer without regulation. Small-scale dairies generally have a good track record for safety whether or not they are regulated; if there is a problem, raw milk is typically an easily traceable food.

Rather than lifting the ban immediately, there are a number of smaller steps that could be taken at the federal and state levels to improve the regulatory climate to the point where it would be more feasible to end the interstate prohibition with less risk of a backlash against raw milk by FDA. Among such steps could be:

1. Repeal Section 9 of PMO / Amend the Pasteurized Milk Ordinance (PMO); this is a document governing the production and distribution of raw milk for pasteurization. Every state has adopted either part or all of the PMO; Section 9 states that only pasteurized milk should be sold to the final consumer, restaurants, grocery stores, etc. The PMO is revised every two years; the revision starts at the biannual National Conference on Interstate Milk Shipments (NCIMS, most recently in April 2025). FDA works on the revisions with other stakeholders; my understanding is that the FDA has final say on any revisions. If a state passes a law on raw milk sales for human consumption, that law controls over the stateʼs adoption of Section 9 in the PMO. Removing Section 9 from the PMO would help change the culture of anti-raw milk bias that exists at FDA and state agencies; it would increase the chances of expanding raw milk access in the forty states currently allowing raw milk sales or distribution through law or policy. Also, it would improve the prospects for legalizing the sales of raw milk for human consumption in the remaining ten states that otherwise ban it.

2. Amend FDA Food Code—The FDA Food Code governs food establishments, defined as any operation that “stores, prepares, packages, serves, vends food directly to the CONSUMER, or otherwise provides FOOD for human consumption” including restaurants and markets. Just about all states have adopted all or part of the Food Code. States can adopt regulations that are either more or less strict than the Food Code provisions. FDA works with USDA, among other stakeholders, in drafting revisions of the Food Code; itʼs usually revised every three or four years (the last update was 2022, fda.gov/food/hfp-constituent-updates/fda-releases-supplement-2022-foodcode). The current revision states that “Fluid and dry milk and milk products shall be obtained pasteurized and… comply with GRADE A STANDARDS as specified by LAW.” The next revision of the Code should remove these provisions. Only about a quarter of the states allow sales of raw milk in restaurants. Removing these provisions would reduce bias by regulators against raw milk and should increase raw milk access.

3. Redirect Dairy Checkoff Program funding—Have funding from the dairy checkoff program which the National Dairy Council receives (USDA-AMS has oversight) go toward promoting raw dairy—starting with raw cheese would be good since its sale is legal in all fifty states.

4. U.S. Dairy Innovation Centers—Have the four U.S. dairy innovation centers which receive funding from USDAAMS award grants to dairy businesses that produce raw dairy; remove the current prohibition. Awards have been used for technical assistance, health and safety training, marketing strategies, etc.

5. Testifying on State Raw Milk Bills—Have RFK Jr or FDA Dairy Chief testify in favor of state bills legalizing raw milk sales, distribution or expanding raw milk access. John Sheehan used to submit testimony opposing raw milk bills.

6. Standard of Identity—Issue standard of identity regulation for specific types of raw cheese with less than sixty-day aging requirements.

7. Reducing Federal Pressure Against Raw Milk Law and Policy—Find areas where a stateʼs raw milk laws or policy affect its funding or rating with the federal government (such as, possibly, NCIMS state rating for compliance with PMO) and change policy so there is no longer any effect.

8. Dairy Co-op Prohibitions—Make dairy co-op prohibitions on co-op members distributing raw milk for direct human consumption illegal.

9. FDA Interstate Raw Milk Ban—Adopt policy that FDA will only take enforcement action against those transporting raw dairy directly to consumers for human consumption if there is evidence that the product is either adulterated or misbranded. Cease from interpreting the Public Health Service Act to regard raw dairy as a “communicable disease” per se. Current policy leaves enforcement open against food buyers clubs and farmers; FDA does not enforce the ban against individual consumers crossing state lines to obtain raw dairy for their own consumption.

10. FDAʼs “For Consumers” Webpage—Publish information on the FDA website about raw milk safe handling. Excerpts can be taken from Peg Bealsʼ book, Caring for Fresh Milk, and FDA can publicize this booklet on its website homepage. A statement could read: “FDA recognizes the consumer demand that exists for raw milk; consumers who drink it should follow these guidelines.” See fda.gov/food/resources-you-food/raw-milk

RFK Jr. faces the challenge of changing the culture on raw milk in FDA and ending the fearmongering about the product, but there will never be a better time to do so than now, with him in charge of HHS. This factor combined with the current demand for raw milk and the insufficient supply point toward an attempt to relax or overturn the ban during the Trump administration.

2025 State Legislation

Three states passed raw milk bills this session; two expanded raw dairy access and the third gave more due process protections to dairy farmers in the event of a government investigation. The states with the new laws are:

ARKANSAS – Current law limits sales to on-farm with a cap on volume of five hundred gallons per month. Senate Bill 464 (SB 464) represents a major breakthrough for producers and consumers in the state. There is no longer a cap on sales, and producers can now sell any other raw dairy product as well; sales of raw dairy, in addition to on-farm, are now legal at a farmers market, at a “natural food store” or via delivery from the farm where the milk is produced. There are refrigeration, signage and labeling requirements; both signs and labels are required to contain the following statement: “This product sold for personal use and not for resale, is fresh whole milk that has not been pasteurized. Neither this farm nor the milk sold by this farm has been inspected by the state of Arkansas. The consumer assumes all liability for health issues that may result from the consumption of this product.”

NORTH DAKOTA – In its last session the legislature legalized the sale of raw milk direct to the consumer. Effective August 1, House Bill 1131 (HB 1131) expands on that to include the direct-to-consumer sale of any raw dairy product. The only requirement in the bill is that a farm selling raw milk or raw milk products shall label the products as “raw milk” or “made with raw milk.”

UTAH – In 2023 an investigation by the Utah Department of Agriculture and Food (UDAF) into a suspected foodborne illness outbreak resulted in a suspension that nearly put the largest raw milk producer in Utah out of business. The investigation was characterized by the producer being in the dark as to what his rights were in getting his permit reinstated, and what the legal authority of UDAF actually was. In response, the legislature passed House Bill 414 (HB 414), legislation that provides greater due process protections on matters such as testing, reissuing a suspended permit and the issuance of a cease-and-desist order. The legislation marks the fifth raw milk bill that the mother-daughter team of Symbria and Sara Patterson has been responsible for passing; the Pattersons are the founders of Red Acre Center, a nonprofit that has been the driving force behind the development of one of the most favorable regulatory climates for local food in the country.

NORTH CAROLINA – N.C. FARM BILL

It has been a long time since a state has tried to roll back the clock and ban or restrict raw milk access, but that is now happening in North Carolina, primarily due to one individual, Agriculture Commissioner Steve Troxler. Through his allies in the legislature, Troxler was able to get a section in Senate Bill 639 (SB 639), also known as the North Carolina Farm Bill, that would have banned the distribution of raw milk through herdshare agreements; under current law, both herdshares and raw pet milk sales are legal.

In pushing for the ban, Troxler tried to scare the public about the dangers of bird flu by saying, “We’ve been playing Russian Roulette with one bullet in the chamber, with these other pathogens. But when you add [bird flu] into the mix, we put two more bullets into that chamber.”1 Bird flu is a respiratory, not gastrointestinal, illness (that is, the mode of transmission is the respiratory tract, not the digestive tract); there is no evidence that bird flu in raw milk or any other type of flu in raw milk has ever made anyone sick.

The outcry against the herdshare ban was so great that the Senate Agriculture, Energy, and Environment Committee took it out of the bill but, with pressure from Troxler, then substituted an amendment with a ban on pet milk sales. A number of micro dairies in the state rely on income from selling pet milk. The pushback against banning pet milk was great as well; as of the beginning of June, the full Senate had not voted on SB 639. The NC Farm Bill is one of the worst pieces of legislation in memory. SB 639 also contained sections establishing a liability shield for pesticide manufacturers and giving the North Carolina Department of Agriculture and Consumer Services law enforcement powers that extended far beyond its current jurisdiction.

There was also a provision for a study on “the advisability of allowing the dispensing of raw milk via herd arrangements, and the retail sale of raw milk and raw milk products”—a possible lever to reintroducing legislation restricting or banning raw milk next year if nothing passes in 2025.

Thanks to effective opposition from farmers, consumers and advocacy groups, there was growing hope that the NC Farm Bill would not pass out of the legislature this session.¹

1. The Regenaissance. (2025, May 15). North Carolinaʼs Raw Milk Rebellion: Consumer Demand Forces a Legislative U-Turn. https://theregenaissance.news/p/north-carolinas-raw-milk-rebellion.

This update was published in the Summer 2025 issue of Wise Traditions in Food, Farming, and the Healing Arts, the quarterly journal of the Weston A. Price Foundation. Become a member today to begin receiving this valuable resource by mail.

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Delaware–Raw Milk Bill Passes Legislature

On June 27 the Delaware House of Representatives passed Senate Bill 273 (SB 273), sending the legislation on to the governor for signature. SB 273 allows the direct-to-consumer sale of raw milk and raw milk products by licensed dairies; the bill calls for inspection and testing requirements as well as for the dairy to prepare “a risk management plan that covers sanitation, handling and testing methods.”

The legislation called for the Department of Agriculture to write and adopt regulations to administer and enforce SB 273. The path of the bill and its passage out of the legislature was another sign of how opposition to raw milk has declined. The drivers for the bill were Grade A dairy farmers, Stephanie and Greg Knutson; in the past decade, Delaware has lost three-fourths of its Grade A dairies. Delaware Secretary of Agriculture Michael Scuse testified in favor of the bill at Senate and House committee hearings and on the Senate floor. A Delaware Farm Bureau representative testified in favor of SB 273 as well; the Department of Health was neutral on the legislation—something that rarely happens in any state.

As of September 10, Governor John Carney still had not signed the bill. Secretary Scuse had said he wanted to write regulations for SB 273 before his own term expired in January.

Louisiana–Raw Pet Milk Sales Now Legal

On June 19, Louisiana became the forty-seventh state to legalize the sale or distribution of raw milk when Governor Jeff Landry signed House Bill 467 (HB 467). The new law legalizing sales of raw pet milk in the state went into effect on August 1.

Raw pet milk producers received good news from the Louisiana Department of Agriculture and Forestry (LDAF) when the department moved to exempt them from all regulatory requirements except a labeling requirement and testing for Salmonella. LDAF’s decision saved producers hundreds of dollars in registration and other fees. LDAF indicated that if raw milk dairies wanted to produce other dairy products or mix any other ingredients into raw milk, they would be subject to registration and other applicable regulations in the state’s commercial feed code.

Massachusetts–First State to Test Raw Milk Dairies for Bird Flu

In the five months since bird flu was purportedly discovered in dairy workers, constant fearmongering from government agencies and the media has yet to provide a shred of evidence that bird flu is a threat to human health. Nevertheless, in August, possibly due to pressure from the federal government, Massachusetts became the first state to require raw milk dairies to submit a sample to the Massachusetts Department of Agricultural Resources to test for H5N1. As of the end of August, none of the dairies submitting samples had received a positive test result. Unfortunately, several raw milk dairies in the state have already been hurt by the climate of fear the government and media have tried to create over bird flu. On July 19, Agri-Mark dairy cooperative sent a letter to its members and informed them that they would no longer be allowed to sell raw fluid milk for human consumption; the new policy went into effect on September 1.

Nevada–How the De Factor Raw Dair Ban Works

There are currently forty-seven states that allow (through statute, regulation or policy) either the sale of raw milk for human consumption, the sale of raw milk for animal consumption or the distribution of raw milk through herdshare agreements. The outliers are Hawaii, Nevada and Rhode Island; sales of raw milk are legal by statute in Nevada, but reality couldn’t be more different. Nevada has established a de facto ban through its laws that make it impossible for producers to legally sell raw milk.

A Nevada dairy cannot produce raw milk to be sold unless there is a county milk commission to regulate production and distribution; even if there is a county commission, the sale of raw milk and raw milk products the farm produces is legal only in that county, nowhere else in the state.¹ Currently, only one of the sixteen counties in the state, Nye County, has a milk commission. A bill allowing statewide sales of raw milk, certified by a county milk commission, was vetoed by Governor Brian Sandoval in 2013.

The Nye County Raw Dairy Commission (NCRDC) formed in 2012.² Under state law, the commission must “adopt written regulations, which must be approved by the Director [of the Nevada Department of Agriculture] governing the production, distribution and sale in the county of certified raw milk and products made from it. . .”³ It is the commission that certifies the raw milk and raw milk products so they can be sold. The director, as far as is known, never approved the regulations the Raw Dairy Commission drafted and adopted in November 2015⁴ (per agenda and minutes for 11/18/2016).^5,6 If the director had approved, a Nye County dairy would have had to comply with not only the commission’s regulations but also dozens of regulatory requirements issued by the Nevada Department of Agriculture that are found in the state administrative code, including extensive physical facility requirements—all this to sell milk in a county of around 56,000 people.⁷ Nevada’s population is 3.2 million.⁸

Herdshare agreements aren’t an option for raw milk producers in Nevada. Anyone selling or dispensing raw milk must have a permit issued by the state and be in compliance with all county and state regulations. Nevada law defines “sold or dispense” to mean “any transaction involving the transfer or dispensing of raw milk by barter or contractual agreement or in exchange for any form of compensation, including, but not limited to, the sale of shares or interest in a cow, goat or other lactating mammal or herd.”⁹

Sales of raw milk for animal consumption are legal but only if there is an “approved denaturant”¹⁰ added to the milk; all the approved denaturants are toxic. There isn’t much opportunity for dairy farmers in Nevada these days, especially small-scale operators. There are around twenty Grade A dairies left in the state, ranging in size from 500 to 25,000 cows.¹¹ Nevada dairy farmers have lost millions of dollars in raw milk sales to neighboring California; 2025 should be the year when the booming demand for raw milk moves the legislature to pass a law that actually gives raw milk producers a chance to make a living.

1. Nev. Rev. Stat. Ann. 584.207 (NRS 584.207), https://www.leg.state.nv.us/nrs/nrs-584.html#NRS584Sec207

2. Commission created in 2012 by “Nye Ordinances Chapter 8.40 Raw Milk Commission”. See archived Notice of Public Hearing on Nye County Bill 2012-15, originally posted July 17, 2012. https://www.nyecountynv.gov/CivicAlerts.aspx?AID=212&ARC=485

3. Nevada statute NRS 584.207, clause 3(b) https://www.leg.state.nv.us/division/legal/lawlibrary/NRS/NRS-584.html#NRS584Sec207

4. Regulations of the Nye County Raw Milk Commission. Adopted November 11, 2015 per agenda and minutes for Nov. 18, 2015. https://nvnyecounty.civicplus.com/DocumentCenter/View/29055/Item8?bidId=

5. Raw Milk Commission Agenda November 18, 2016. (2016, Nov 14) https://www.nyecountynv.gov/AgendaCenter/ViewFile/Agenda/_11182016-2101

6. Draft Meeting Minutes for Nye County Raw Dairy Commission. (2016, Nov 18). https://www.nyecountynv.gov/AgendaCenter/ViewFile/Minutes/_11182016-2101

7. worldpopulationreview.com/states/nevada/counties

8. worldpopulationreview.com/states/nevada-population

9. Nev. Rev. Stat. Ann. 584.207 (NRS 584.209), https://www.leg.state.nv.us/nrs/nrs-584.html#NRS584Sec209]

10. Ibid.

11. nevadamilk.com/on-the-farm/nevada-farms

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National–Bird Flu Propaganda against Raw Milk Not Working

Since March 25 when avian influenza was “confirmed” in U.S. cattle for the first time, government agencies and the media have unleashed a nonstop barrage of propaganda against raw milk, warning people not to drink raw milk because it may contain bird flu which may make them sick. The media have engaged in round-the-clock fearmongering to scare people into stopping their consumption of raw milk. So far, their campaign is not working.

A May 14th story on the Public Broadcasting System (PBS) website reported on just how big a failure the campaign has been. The article, titled “Raw Milk Sales Spike Despite CDCʼs Warnings of Risk Associated with Bird Flu,” reported—according to market research firm NielsenIQ—that since March 25th, weekly sales of raw cowʼs milk had gone up anywhere from 21 percent to as much as 65 percent compared with the same period a year ago.1

Mark McAfee—the owner of Raw Farm, the largest raw milk dairy in the U.S.—told PBS, “People are seeking raw milk like crazy. Anything that the FDA tells our customers to do, they do the opposite.”1

Sally Fallon Morell, president of the Weston A. Price Foundation (WAPF), estimates there are now around twenty million raw milk drinkers in the U.S. The warnings from FDA, CDC and other government agencies about the dangers of bird flu in raw milk have considerably increased what was already a booming demand for the product.

1. Alessio, JoNel. (2024, May 14). Raw Milk Sales Spike Despite CDCʼs Warnings of Risk Associated with Bird Flu. PBS News Hour. https://www.pbs.org/newshour/health/raw-milk-sales-spike-despite-cdcs-warnings-of-risk-associated-with-bird-flu

West Virginia–Raw Milk Retail Sales Now Legal

On March 9, House Bill 4911 (HB 4911) became law; the bill provides, in part, that “raw milk may be sold by a seller in West Virginia to a consumer in West Virginia.” The new law went into effect June 7th.

The bill legalizes the sale of raw milk in retail stores; there is a labeling requirement that includes the warning statement, “Consuming unpasteurized raw milk may increase your risk of foodborne illness, especially for children, elderly, immunocompromise individuals, and persons with certain medical conditions.”

Under HB 4911, the Commissioner of Agriculture may issue regulations “in compliance with raw milk dairy industry standards.” HB 4911 initially had a clause providing that producers werenʼt liable for illness attributed to milk consumption unless they intentionally contaminated the milk, but a Senate amendment to the bill cut out that provision. Courts donʼt favor liability waivers for foodborne illness.

A decade ago, West Virginia had the most strict raw milk laws in the country, banning sales both for human consumption and for pet consumption as well as prohibiting herdshare agreements. In 2016, the state legislature passed a bill legalizing herdshares, but that new law never took hold with raw milk producers; the law had costly testing requirements and also required farmers to file copies of each herdshare contract they had with the Commissioner of Agriculture.

HB 4911 passed through the House and Senate by big margins and became law when Governor Jim Justice did not take action on the bill (state law requires the governor to veto the bill within fifteen days from the time it reaches his desk).

Congratulations to the billʼs lead sponsor, Delegate Michael Hornby (R) and West Virginia raw milk producers and consumers. Soon the Real Milk Legal Map will reflect this change for West Virginia.

Pennsylvania–Proposed Regulations to Legalize Raw Butter Sales

On June 15, the Pennsylvania Department of Agriculture (PDA) issued proposed regulations amending the state dairy code, including legalizing sales of raw butter by permitted dairies. Under current law, the only raw dairy products permitted farmers can sell are milk and cheese (aged 60 days).

For the permitted raw dairies, the proposed regulations are a mixed bag. They contain a clause that would mandate dairy producers to comply with the FDA Food Safety Modernization Actʼs (FSMAʼs) onerous food safety plan requirements for food processing plants. Under federal law, there is no food safety plan requirement if either a producerʼs sales are under one million dollars or more than half of the producerʼs gross revenue is from sales that are direct-to-consumer.

For the stateʼs unpermitted raw milk farmers, there is an amendment in the proposed regulations that was intended to strengthen PDAʼs claim of jurisdiction over their dairy operations. Current regulation prohibits the sale of raw milk by unpermitted dairy farms; an amendment in the proposed regulation expands on the current definition of the term “sale,” stating that term “includes selling, exchanging, and delivering to a consumer who is a member of a ʻbuyers club,ʼ cow herdshare agreement or other type of membership purchasing group.”

Itʼs estimated that the proposed rules will go into effect in June 2025. The public will have an opportunity to comment on and attempt to amend the rules this summer.

Oregon–CAFO Requirements for Micro Dairies

One of the more original ways to shut down raw milk dairies ended on March 21st when the Oregon Department of Agriculture (ODA) withdrew its policy to require a small dairy to obtain a Confined Animal Feeding Operation (CAFO) permit. In Oregon on-farm sales of raw milk are legal as long as the dairy does not have more than two lactating cows, nine lactating goats or nine lactating sheep;¹ the application of the CAFO permit rule would have required these dairies “to install expensive drainage systems, put in wastewater holding tanks, keep daily records and pay annual fees starting at $125, on top of a $100 application fee—or face fines up to $10,000 if they didnʼt comply.”²

Oregon regulation defines CAFOs “as the concentrated feeding or holding of animals or poultry, including. . .dairy confinement areas. . . where the surface has been prepared with concrete, rock or fibrous material to support animals in wet weather.”³ In 2023 ODA changed its interpretation of that definition to apply it to small dairies. The drivers for the new interpretation were dairy industry lobbyists who complained that the small dairies had “an unfair competitive advantage over bigger dairy farms that had to follow state regulations and pay annual fees.”²

As raw milk farmer Christine Anderson explained, even if a couple cows were on pasture for most of the day and only brought indoors to a barn for milking for fifteen minutes, once the cows walk on the concrete floor the farm meets the definition of a CAFO.²

On January 24, the Institute for Justice (IJ) on behalf of Anderson and three other raw milk farmers filed a complaint in federal court arguing that the CAFO permit requirement should not apply to small farms since they conduct a completely different business than those operations the definition has traditionally applied to.⁴

Despite ODAʼs withdrawal of its policy, IJʼs lawsuit against the department will continue in federal court. Bobbi Taylor, an attorney for IJ, said that in ODAʼs press release on the withdrawal, “Theyʼve [ODA] stopped short of saying that they would never enforce this policy against small farms. . . or disclaiming that they had the authority to do so in the first place, which is what we’re challenging in the lawsuit. . . . So thereʼs a fight still to be had and weʼre gonna continue to have that fight.”²

1. Oregon revised statute 621.012(2). https://oregon.public.law/statutes/ors_621.012

2. Figueroa, Alejandro. (2024, March 25). Oregon agriculture department reverses burdensome requirement on small dairy farms. OPB News. https://www.opb.org/article/2024/03/25/oregon-department-of-agriculturewithdraws-requirements/

3. Oregon Department of Agriculture. CAFOs in Oregon – Frequently Asked Questions. https://www.oregon.gov/oda/shared/Documents/Publications/NaturalResources/CAFOFAQs.pdf

4. Wilk, Nathan. (2024, January 31). A group of small dairy farmers sues Oregon over new regulations they see as too burdensome. KLCC. https://www.klcc.org/economy-business/2024-01-31/small-dairy-farmers-sue-oregon-government-over-new-regulations

Louisiana–Raw Pet Milk Bill Passed

On June 4, House Bill 467 (HB 467) went to Governor Jeff Landryʼs desk; if he takes no action by June 24, the bill would become law, allowing the sale of raw pet milk by dairies that register with the state Department of Agriculture and Forestry (DAF) and making Louisiana the 47th state to legalize the sale or distribution of raw milk.

The sponsor for the bill was Representative Kimberly Landry Coates from the stateʼs 73rd District, Coates skillfully navigated opposition from DAF and the Louisiana Department of Health and Hospitals (DHH) in getting the bill to the governorʼs desk. The original version of the bill provided that licensed dairies could sell up to five hundred gallons of raw milk a month for human consumption; wanting a fallback, Coates proposed amendments on raw pet milk sales to HB 467 in a House committee hearing, which were adopted. Shortly after a Senate committee hearing on HB 467 (the bill passed out of both the House committee and House floor unanimously), DHH tried to kill the legislation by attaching a fiscal note of $900,000 to the bill. A fiscal note is an estimate of what additional expenses the government will incur if a bill passes into law; DHHʼs inflated figure was designed to convince legislators that the bill was not worth passing with the expenses that the department would have incurred by investigating all the foodborne illnesses raw milk consumption supposedly would cause.

Rep. Kim Coates countered DHH by submitting another amendment removing raw milk sales for human consumption from HB 467; this took DHH and the fiscal note out of the picture since DHH does not have jurisdiction over pet food. When Agriculture Commissioner Mike Strain indicated DAF no longer opposed the bill, HB 467 passed out of the legislature easily.

Coates had seen the devastation the dairy industry had suffered in her own district and knew legal raw milk sales were the way to stop the loss of dairies. She testified at the House committee hearing on the bill that in 1940, Louisiana had 105,000 dairies and as late as 1987 there were still 1,500 dairies in operation; today that number stands around fifty. Passage of HB 467 gives the state a chance to reverse the decline in dairies.

Coates had widespread support for HB 467. There was an overflow crowd at the Senate hearing before the committee on Agriculture, Forestry, Aquaculture, and Rural Development; committee chair Stewart Cathey received over five hundred emails on the bill.

Congratulations to Rep. Coates for getting the bill into law and to others helping with its passage, including veterinarian/dairy farmer Dr. Hue Karreman, microbiologist Peg Coleman, (both supported by the Weston A. Price Foundation and dairy farmer Miles Sinagra, who all provided testimony before the committees.

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It has been about a year since H5N1 virus (bird flu) was “discovered” in dairy cattle; during that time, there hasn’t been a shred of evidence linking any human illness to the consumption of raw milk contaminated with bird flu. Nevertheless, several states are testing raw milk produced for direct consumption for bird flu. The testing has been described as “a solution in search of a problem”; it looks like an attempt to reduce the supply of raw milk—this, at a time when the demand for the product has never been greater. The test that federal and state regulatory agencies use to detect bird flu in a sample of milk is the polymerase chain reaction (PCR) test. PCR detects the presence of RNA from virus cells that have been fragmented in the process so no intact cells remain; therefore, the test itself cannot be used to determine whether the original so-called viral cells were dead and inert or “live” and infective. The detectible presence of viral RNA in a test sample depends on the amount of virus cells (that is, the viral load); the PCR cycle threshold (Ct) indicates the degree of amplification applied to the sample in order to get a result. In order to detect the presence of any viral RNA when the viral load is low, the Ct value will be set higher to run more cycles of amplification; if only a trace amount of viral RNA is present, then more than 35 cycles (Ct 35) might be needed to obtain a positive test result. Even if the result is positive for bird flu, PCR cannot determine whether the viral RNA represents a complete “live” virus capable of infection and replication or merely an inactive fragment of viral RNA that cannot infect. To determine whether there is a supposed intact, infective virus in the sample, a follow-up validation test such as an egg inoculation test is needed to see whether the so-called viral material can be cultured.

There is no consensus on what Ct value is valid for the PCR test. Researchers choose a Ct to distinguish between “presumptive positives” for viral RNA and “negatives” for test samples, but rarely do they provide cultured validation of results (such as, by embryonated egg or tissue inoculations). A Massachusetts Department of Agriculture official stated, “PCR tests are only valuable up to about 30 cycles”—meaning that results from PCR tests run at Ct greater than 30 (Ct>30) are unreliable and may detect only traces of inactive viral fragments. According to reports, the California Department of Food and Agriculture (CDFA) chose to run its PCR tests at Ct set no lower than 35 cycles (Ct>35). The
Maryland Department of Agriculture runs PCR tests set no lower than 40 Ct (Ct>40), as does the USDA National Veterinary Services Laboratory (NVSL) in Ames, Iowa; NVSL is the lab that runs confirmation tests for positive test results from state labs. Finally, the FDA has published a guidance document on testing for bird flu with PCR set at Ct>45.

As far as is known, three states—California, Massachusetts and New York—have required farmers producing raw milk for human consumption to test for bird flu; a fourth state, Maryland, has required farmers producing milk for pet consumption to test for bird flu. California has done the most testing for bird flu so far, and the testing has found H5N1 in well over half the state’s Grade A dairies producing milk for pasteurization that have tested positive for bird flu. If a Grade A dairy cow or milk tests positive for bird flu, then the dairy can continue selling milk and not have to pull the positive cows from the milk line. The position of federal and state governments is that pasteurization inactivates any bird flu virus present in the milk, while known antiviral activity in raw milk is ignored.

So far in California, two dairies producing raw milk for direct consumption (including Raw Farm, the world’s largest raw milk dairy) and a raw milk distributor have had their sales suspended for bird flu due to presumptive positive PCR results of their milk samples. During the suspension, the dairies could still sell raw milk for pasteurization, but the price they received was a fraction of what they get for selling raw milk for human consumption. Raw Farm had its sales suspended for six weeks, costing over one million dollars in sales and causing massive shortages of raw milk in California. Raw Farm accounts for an overwhelming majority of raw milk sales in the state. The CDFA suspended Raw Farm sales solely on the basis of a positive PCR test without running any validation test for infectivity—as mentioned earlier, the PCR test cannot determine whether the virus particles present are live, intact and infective.

There has been tremendous pressure from the federal government on the states to test retail raw milk for bird flu, especially from USDA’s Animal Health Inspection Service (APHIS). A Public Records Act Request from the Weston A. Price Foundation (WAPF) for communications on bird flu between the CDFA and the FDA/USDA was denied by CDFA on the grounds that “. . . based on the facts of this case. . . the public interest served by not disclosing records related to an active investigation and outbreak response clearly outweighs the public interest served by disclosure.”

The bird flu “pandemic” has led to the culling of over 160 million poultry in the U.S. It has led to the shutdown of the country’s largest raw milk producer. The public health threat so far doesn’t come close to justifying the upheaval it has caused with the egg shortages throughout the country and the raw milk shortage in California. The consumer demand for raw milk continues to grow to levels never seen before despite the nonstop fearmongering by the government and media over bird flu. The campaign against bird flu is about reducing the supply of animal protein for the American people, not about public safety.

This update was published in the Spring 2025 edition of Wise Traditions in Food, Farming, and the Healing Arts, the quarterly journal of the Weston A. Price Foundation.

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Photo credit: Tanya Barrow (Unsplash.com)

RFK Jr. could issue a standard of identity regulation with an aging requirement for a specific raw cheese of less than 60 days. There is no law that needs to change for the HHS Secretary to be able to do this. 
The regulation establishing the interstate ban (21 CFR 1240.61 – raw milk and milk products) provides that there is an exception to the ban “where alternative procedures to pasteurization are provided for by regulation, such as in Part 133 of this chapter for curing of certain cheese varieties.” The term “curing” is another word for aging.  The definition of “milk product”s in 21 CFR 1240.3 provides that the ban extends to cheese “where not specifically exempted by regulation.” 

Titled “Requirements for Specific Standardized Cheese and Related Products”, 
21 CFR 133 Subpart B, among other regulations, establishes standards of identity for specific cheeses and for the general categories of hard cheeses, soft-ripened cheeses and semisoft cheeses. 

Statute 21 USC 341 (Definitions and standards for food) provides, in part, that “whenever in the judgment of the Secretary such action will promote honesty and fair dealing in the interest of consumers, he shall promulgate regulations fixing and establishing, for any food under its common or usual name so far as practicable, a reasonable definition and standard of identity, a reasonable standard of quality, or reasonable standards of fill of container.” 

In FDA’s words standards of identity “have been established to ensure that the characteristics, ingredients and production processes of specific foods are consistent with what consumers expect.” 


There a number of cheeses listed in Part 133 regulations that can be sold pasteurized or raw, but the aging requirement for all raw cheeses in the current regulations is 60 days. There is no basis in fact or science for a uniform aging requirement. Different kinds of cheese don’t have the same water content, salt content, period of growth for harmful bacteria or type of culture used. For instance, in the European Union which does take these factors into account in its regulations, the shelf-life for camembert is only 57 days. The uniformity in the aging requirement hurts cheese producers who could be getting paid earlier than 60 days for some of the cheeses they produce and who are prohibited, in effect, from producing raw soft ripened and raw semi-soft cheeses.


The regulations for hard cheeses (21 CFR 133.150), soft ripened cheeses (21 CFR 133.182) and semisoft cheeses (21 CFR 133.187) all begin with the following statement:
      “The cheeses for which definitions and standards of identity are prescribed by this section are….cheeses for which specifically applicable definitions and standards of identity are not prescribed by other definitions of this part . . . .”

The cheeses in these three regulations all have a 60-day aging requirement if they are raw, but there is nothing preventing the HHS Secretary from issuing a regulation for a soft cheese like feta that has less than a 60-day aging requirement; there is nothing legally precluding an aging requirement as little as a one-day period. Feta has a good safety profile because it is very acidic with a high salt content and a relatively low moisture content. 
It would be a good cheese to start with in lowering the aging requirement for cheeses where the science supports that action. 

Photo credit: Monika Borys (Unsplash.com)

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New York–Government Inaction Hurting Raw Milk Producers and Consumers

While only a few states have yet to legalize some form of raw milk distribution, there are many among the legal states that need to change their laws to improve access for consumers and give farmers a more viable market for their milk. New York is one state that badly needs to amend its laws.

Under current law in the state, only on-farm sales by permitted producers are legal. The prohibition on the delivery of raw milk by permitted dairies has resulted in millions of dollars in sales every year lost to raw milk farmers in neighboring states such as Pennsylvania, Massachusetts and Connecticut. The only other raw dairy product New York farmers can produce and sell is cheese aged 60 days, a further limitation costing producers substantial income.

In 2004 the New York State Department of Agriculture and Markets (NYDAM) had plans to legalize the sale of other dairy products but never followed through. Until 1994, the unregulated sale and delivery of raw milk was legal in New York State; that year, NYDAM issued regulations limiting transactions to permitted sales on the farm. NYDAM has the power to issue new regulations, allowing both delivery of raw milk and the sale of any raw dairy product without needing further authorization from the legislature. Farmers and consumers have been contacting NYDAM for years about changing the law, but NYDAM has done nothing, ignoring the massive loss of revenue that instead flows to producers in neighboring states.

A veteran dairy farmer with decades of experience in producing raw milk for both pasteurization and direct consumption has set up an online petition asking signers to contact New York State Agriculture Commissioner Richard Ball and NYDAM Division Chief Casey McCue requesting that the department issue regulations to allow deliveries of raw milk and sales of raw dairy products other than milk and cheese. The petition can be accessed online at: bit.ly/3HjsLmM.

NYDAM’s intentional inaction is not only hurting raw milk farmers and consumers; it’s ensuring that the consolidation of the state’s dairy farms continues. The family dairy farm in New York is rapidly disappearing. A recent USDA Census of Agriculture report shows how far the dairy industry has fallen off in the state. According to the census from 2017 to 2022, the number of dairies declined by one-third in the state; New York lost almost two thousand dairies during that period. Big increases in input prices over the last few years, along with
a federal pricing system that continually shortchanges farmers, have accelerated the number of farms producing commodity milk that have gone out of business. There was already a steep drop in dairy farms before 2017; over the past twenty-five years, the number of dairies in the state has decreased from nine thousand to around three thousand today.

Dairy farmers trying to get out of the commodity system have three options: (1) bottling and pasteurizing their own milk; (2) processing their own milk into value-added products, such as butter and cheese; and (3) selling their own milk for direct human consumption. By far, the last option is the easiest and least expensive way for the dairy producer to escape the commodity system and remain in business. A change in the raw milk laws by NYDAM would enable many more Grade A dairies to successfully make this conversion.

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