Saturday, 30 April 2016

Signing Off


Take Back Your Power

With this article, I sign off from this blog. I will not be posting any more articles here, but I will keep the blog alive for reference purposes. I have started a new blog for my new business called Jennifer Wilson, Life Coach.. My strap line for this business is "Take Back Your Power". Please follow the link for further details.

I thank you, all my readers and followers. I hope you have enjoyed my articles and found something of interest in them. I welcome you to my new blog where I have a gadget to sign up for emails when I post new articles. The new blog will cover similar topics to this one, but the focus of it will be to explain and expand upon what I do in my life coaching business.

So far, I have two articles, WYSIWYG, and Visually Oriented which as the titles imply are about our vision.

In May, I will be posting a series of 20 short articles which explain and set out the Tai Chi Qigong Shibashi movements that I teach. These movements are used in martial arts training, but are also beneficial to health and easy to do.

Thank you again and I hope to see you on my new blog, Jennifer Wilson, Life CoachMaybe I'll even see you in person!

My new blog address: http://jenniferwilsonlifecoach.blogspot.co.uk/ 

Wednesday, 6 August 2014

UK Law on Raw Milk


In relation to raw milk that is sold directly to the consumer, The Food Standards Agency (FSA) in the UK advises on their website that FSA Inspectors enforce parts of European Commission Regulations 852/2004, 853/2004, 854/2004 and the Food Hygiene (England) Regulations 2006.
 
I pointed out in my letter to Defra (Department of the Environment, Food and Rural Affairs in the UK) that Regulation (EC) No 853/2004 has a clause stating that small local enterprises such as those that sell raw milk directly to consumers should be regulated at national level.  Raw milk and raw cream intended for human consumption need appropriate national health measures.”  Defra replied that in the UK, these rules are provided in Domestic legislation (The Food Safety and Hygiene (England) Regulations 2013, Schedule 6) which in England, Wales and Northern Ireland permits the restricted sale of raw cows’ drinking milk.  But this is only part of the story as one can easily see by looking at this law.
 
Schedule 6 of The Food Safety and Hygiene (England) Regulations 2013 says that raw milk shall meet the following standards:
Plate count at 30°C (cfu per ml) _ 20,000, Coliforms (cfu per ml) < 100.
 
This Domestic legislation actually covers the European hygiene requirements under Regulation (EC) No 853/2004 Annex III, Section IX, Chapter I,
Part III which sets out that
3. (a) Food business operators must initiate procedures to ensure that raw milk meets the following criteria:
(i) for raw cows’ milk:
Plate count at 30 °C (per ml) ≤ 100 000 (*)
Somatic cell count (per ml) ≤ 400 000 (**)
 
Whether this national legislation is appropriate for small dairy farms producing raw milk for sale to consumers may be debatable, but it is not why I wrote to Defra.  What I am more concerned with is the regime for tuberculosis in milk producing cows.  I wrote to Defra to complain that a small dairy farm across the road from me cannot presently supply my raw milk because of the TB testing and licensing regime enforced in this country.  Where is the national legislation to give authority for this regime?  There isn’t any.  It stems from European law and both Defra and the Food Standards Agency admit this.
 
Defra claims that “The restrictions on sale were introduced to control outbreaks from RDM (raw drinking milk) consumption.”  The restrictions may have been introduced for this purpose, although I would argue that this was merely an afterthought and excuse for upping restrictions with a view to developing the milk choices most people have today, but they were not and have not been introduced by the English Parliament.  What was the regime before 2004?  I am relatively new to being a raw milk consumer and cannot shed light on this at the moment, but surely some readers will know.  Remember?  For now, I can only highlight that the current situation is inadequate.
 
The current regime that is being implemented with TB testing, isolating cows that react to a skin injection, slaughtering reactors, autopsy, further scientific testing and removal of licence to sell raw milk for human consumption all stem from European legislation.  For instance:
 
 
SECTION IX: RAW MILK AND DAIRY PRODUCTS
CHAPTER I: RAW MILK — PRIMARY PRODUCTION
Food business operators producing or, as appropriate, collecting raw milk must ensure compliance with the requirements laid down in this Chapter.
 
I. HEALTH REQUIREMENTS FOR RAW MILK PRODUCTION
...
2 (b) (i) cows or buffaloes belonging to a herd which, within the meaning of Directive 64/432/EEC, is officially free of tuberculosis;
 
I won’t go into the European Commission TB legislation any further here because it would not add to the discussion much and could be quite lengthy.  Any control plan put in place by the UK government on the basis of Regulations 852/2004, 853/2004, 854/2004 is stemming from authority based in EC law.  I believe this is an example of the European Community overstepping its boundaries and the UK government not acting in our best interests by following EC law verbatim. 
 
Similar complaints about the EC have been raised before.  I wrote about one in relation to social welfare and provision of food for deprived persons (which historically included milk powder).  The European Commission wanted to take control of this service.  At least in this instance they had some validity for their actions in that the food was to be traded in the open market.  However, Germany filed an action against the Commission for the European Communities with the submission that regulation in this instance had no basis in Community law because the plan created thereby was to deal with intervention stocks being used purely as a social policy instrument (principal of conferred powers).  Please note that the Defendant in this case was the Office for Harmonisation in the Internal Market (Trade Marks and Designs).  The EU is pushing to control social policy and makes many references to it in the Lisbon Treaty which I discuss further below.  However, the EU’s control over social policy is supposed to be limited still.  The EU’s status to control agriculture and health policy in the Member States is also supposed to be limited.
 
Even the individual States in the USA have jurisdiction over the legislation that covers the production and sale of raw milk to consumers, not the Federal government.  It seems to me that not only is the European Union progressing to act like a federal government for Member States, it is moving in the direction of completely replacing their governments.
 
Another reason I wrote to Defra is because the Food Standards Agency Consultation on raw milk was nonsense when one examines the law surrounding their actions.  For instance, what gives them the right to say that raw milk cannot be sold in supermarkets?  Both Defra and the FSA claim it is the European Commission that gives validity to their authority.  Is this appropriate?
 
European Communities
Perhaps the Treaty of Lisbon amending the Treaty on European Union and the Treaty establishing the European Community, signed at Lisbon, 13 December 2007 was our ultimate downfall?  However, surely sharing competence still leaves room for some Member State sovereignty?  Under TITLE I, CATEGORIES AND AREAS OF UNION COMPETENCE, Article 2C section 2 says that the Member States share competence (my emphasis) with the Union in (d) agriculture and (f) consumer protection, which naturally relate to the production and sale of raw milk within a Member State.
 
Has our domestic government come to the point of being nothing more than a puppet show, i.e., acting as decided in Europe with no sovereignty whatsoever?  By not creating its own legislation for some issues surrounding raw milk production and sales from small dairy farms even when European law encourages it, the UK is handing over its authority on a silver platter to the European cum global bureaucracy.
 
As the Europa website reminds us, democratic government must have legislation to authorise its actions.  This is the rule of law.  The British are proud of their rule of law.  The long arm of the law reaching over from Brussels is a bit heavy handed in my view and I would call for the UK government to remedy this gap to improve access to wholesome raw milk, and assist small dairy farms as called for in this International Year of Family Farming.
 
BUT, can any government in the world today really act outside the remit of agri-tech and the Global Harmonisation Initiative?  Our world is constructed by humans and law shapes this reality.  Our food has been constructed too.  We’ve been tinkering with it since farming began about 10,000 years ago.  We use nature, but alter it.  Many thoughtful people such as the Roman Emperor Marcus Aurelius (121-180 CE) and Masanobu Fukuoka (see The One Straw Revolution) have advocated living closer to nature.  Meanwhile, the present prevailing constructed reality is moving further and further away from nature at an ever increasing speed due to technology.
 
Photo credit with thanks to the Global Harmonization Initiative, a joint activity of the US-Based Institute of Food Technologists and the European Federation of Food Science and Technology founded in 2004 (the same year that the above EC legislation came into effect!) to promote harmonization of global food safety regulations and legislation which must, in reality, include harmonization and standardisation of the food itself.  This is one reason the food in supermarkets all looks the same as discussed by Joanna Blythman in her book Shopped, The Shocking Power of British Supermarkets.   And no wonder cloning is so popular with governments and global corporations.

Future of Raw Milk



Dear Blog Readers and Email Recipients
 
Thanks to Omrina Nawaz from the Defra Customer Contact Unit for replying to my letter to George Eustice MP.  Her letter is now published on this blog here.  Below are a few comments on her reply with further information on the issues raised.  I conclude from it all that due to the Global Harmonisation Initiative and the government's focus on agri-tech, the future of raw milk, at least as we know it today, is bleak.
 
I remember the words of a solicitor who often said, “I choose my words carefully.”  Language can sometimes seem like an inadequate tool for communicating, but in law, words are very important.  So it is with government as well.  By carefully looking at the words of Defra’s reply and with a little experience, one can see through the propagandist information supplied.  This exercise has reaffirmed my view that the government as an entity does not give a hoot about the health and happiness of its citizens, but is solely concerned with the pursuit of money.   After all, the government is working in partnership with global corporations that profit from people being ill, to improve the health to the nation.  Feeding Tubes and the food products used with them are an example of how engrained sickness is with profit.
 
First of all, I would like to clarify the product that is being discussed.  Many refer to the raw milk that is sold directly to consumers as raw drinking milk.  I don’t like this term because I actually drink very little of the raw milk I purchase.  I use most of my raw milk to make Viili yogurt and kefir.  So in this article I will simply refer to raw milk as raw milk even though it is also supplied to businesses for processing before sale to consumers.  I prefer cow’s milk, but goat’s milk and sheep’s milk are good too.
 
In her letter, Omrina on behalf of Defra states that:-
 
“The government wants to see a profitable, thriving and sustainable dairy sector and recognises the vital contribution small dairy farms make to the UK’s economy.”
 
I have emphasised the words profitable and economy because they refer to money.  In other words, the government wants to see more money being made in the dairy industry.  I also highlighted the word vital because this is nonsense as used here.  Raw milk consumers would notice if all small dairy farms shut down tomorrow, but it would be a blip on the screen for the UK economy.
 
The government wants to see profit.  That’s number one.  Big dairies are about maximising profit.  Number two, small dairy farms that produce raw milk for sale to consumers are a drop in the (milk) bucket.  The third point of importance is that business is to be in line with the New World Order.  For some, the mention of a New World Order conjures up thoughts of conspiracy theories, but it’s actually nothing more than what we see happening in the world today with everything taking on a global perspective and being ordered at global level.  But do not take my word for it; the government says it all the time.
 
“The Government is investing £160 million, to improve this country’s uptake of research into farming so that the UK can remain globally competitive.”
 
The UK government is investing £160 million in its agri-tech strategy, not so more of its citizens can access nutritious foods, but so that the UK can compete to sell products in the global market.  Agri-tech (agricultural technology), by the way, is the use of machines, chemicals, genetic modification, cloning, and nanotechnology to manipulate food crops and livestock.
 
The government is investing £160 million in agri-tech and that may seem like a lot of money, but it pales in comparison to what is being spent by corporations as well as academia.  For example, I found a helpful example online showing the money spent in the US in 2008 (p.25) on food and agriculture research and development.  The government (USDA) spent $1.5 billion (16%) while the Academic input was $3.7 billion (39%) and Business was $4.4 billion (46%).  Not that this breakdown really matters that much because the US and UK governments (and many others I’m sure) and the academic institutions in these countries are all controlled by global corporations that translate this R&D into money-making products.  Well, what do we expect?  At any rate, this shows that a lot more than £160 million will be spent on agri-tech in the UK.  In addition, since corporations that are big food suppliers in the UK, such as NestlĂ©, Uniliver, Associated British Foods plc, etc, etc that use milk in their products are global, R&D in other countries will have affect on UK milk as well.
 
Defra also claims that the government supports the dairy industry’s Code of Best Practice for Contractual Relations.  This Code was drawn up by Dairy UK and the National Farmers Union both in the UK and Scotland, and Dairy UK made its view very clear at the Food Standards Agency Conference on 31 March 2014 (available in conference video) that all milk should be pasteurised.  Dairy UK does not, therefore, support small dairy farms that produce raw milk for consumers.  As Defra and the Food Standards Agency readily point out, sales of raw milk are banned in Scotland.  Furthermore, this Code relates to sales under contract such as to supermarkets where it is not possible to sell raw milk, not even in vending machines.  And, raw milk is not sold under contract to consumers!  More nonsense in relation to small dairy farms.  Finally, more evidence that the government has the same views on raw milk as Dairy UK comes from its top adviser of the Advisory Committee on the Microbiological Safety of Food which works closely with the Food Standards Agency.Gov.UK (also available in a video from the same conference).
 
None of the questions in my letter to Defra were addressed properly in Defra's reply, but this is what I now believe the answers are:
 
1.      British small family farms do not need a global programme with European input to save them, they need to embrace agri-tech and the New World Order.
 
2.     Small family farms in Britain will continue to struggle and close down with or without any International initiative if they do not embrace agri-tech and the New World Order.
 
3.     The replies to numbers 1 and 2 are true because the British government is solely investing in agri-tech, never mind the investment from others with the focus of competing globally as shaped by the Global Harmonisation Initiative for a New World Order.
 
4.     The Food Standards Agency is headed by an ex-Unilever employee because, like Unilever, it is primarily concerned with global competition and the New World Order.  The FSA is a propaganda spewing organisation that serves global corporations via the government, the European Commission and global organisations such as the World Trade Organisation, etc, etc.  For example, please see my letter to the FSA Chief Executive in 2010 which I wrote when the FSA launched a public campaign to denigrate organic food for the second time since it was formed in 2001.
 
5.     The Food Safety and Hygiene (England) Regulations 2013, Schedule 6 does not cover requirements for a TB-free herd.  Because this is an important issue, I have written a separate article on this blog called UK Law on Raw Milk, to show that the law regarding TB-free herds is from the European Commission and that this is inappropriate despite the global harmonisation movement.
 
6.     The government chooses to ignore or provide robust scientific evidence of the nutritional value of raw milk because there is no real money in the product.  Generally, they are focused on sterilising food products as they have been for quite some time now and have little interest in live food.  If raw milk were to become a money-maker, it would be taken over and basically reformulated by big business as has been done many times before in the so-called organic foods industry (please see for example my book review on Corporate Power in Global Agrifood Governance edited by Jennifer Clapp and Doris Fuchs, Chapter 3).
 
7.     The requirement for a TB free herd to maintain a licence for selling raw milk is simply a restrictive measure to make it harder for the producer to stay in the business of supplying raw milk to consumers and has little, if anything, to do with protecting anyone’s health.  In my article What is Food? A Brief Legal Perspective, I discussed the legal framework in which food is developing which gives credence to this response.  A wise old nursing home resident recently reminded me that this legal framework is actually changing food to suit human desires.  But aren't desires an illusion that lead to suffering?  Whether one believes that desires are an illusion or not, it is plain to see that in the pursuit of desires, humans are disregarding anything that does not help them make money.  The pursuit of desires is inevitably leading us away from nature and causing a lot of suffering.  This would explain why our food is becoming more and more artificial and why the so-called health industry is growing so fast.
 
8.     I found out by looking on the Defra website that the British government announced plans on 22 July 2014 to improve access to local wholesome nutritious food products (the day before I received my reply from Defra).  However, they are actually in the process of destroying real food and reconstituting it in a man-made fashion with patents wherever possible in partnership with global corporations via the European Commission.  This is evident when considering how scientists are changing our food at an ever greater speed at microscopic and seed level.  For example, in the biopharmaceutical industry, plants can now be used to produce pharmacologically active proteins, including mammalian antibodies, blood product substitutes, vaccines, hormones, cytokines, and a variety of other therapeutic agents.  And just in case one thinks this is not plants that we eat, I quote further from this lovely Oxford Journal article called Biopharmaceuticals derived from genetically modified plants:
 
“Pharmaceutical production in plants may create the potential for the flow of pharmaceutical materials into the human food chain, especially when food crops are used. This could occur as a result of inadvertent cross-contamination of foodstuffs, through spontaneous growth of genetically engineered plants where they are not desired, or by virtue of pollen flow with some plants (e.g. corn), but not others (e.g. potato). While some have therefore suggested restricting pharmaceutical production to non-food crops such as tobacco, it is the food crops that present the greatest opportunities for efficient production of biopharmaceuticals and that will be most useful for the production of edible vaccines.”
 
Cross contamination, mix-ups and intentional contamination would inevitably lead to the demise of our freedom of choice not to eat these products.  It is already happening to some degree and back in 2011 I discussed this in relation to genetically modified organisms in imported animal feed in Zero Tolerance or Zero Protection?  In addition, it is well known that pharmaceuticals have already entered the food chain through water.
 
This is some of what the government is up to with agri-tech and its millions that it gets from us, the taxpayers.  I even have first-hand knowledge of this because not long ago I attended a conference by Inprofood.eu (short for Improving Food in the European Union) and chatted with a lady there who works for a UK company involved in this research.  She said that she is working on developing food products that are grown with enhanced nutrition and pharmaceuticals.
 
9.     Because the British government is tied up with agri-tech, despite its millions, it cannot facilitate any scheme whatsoever to reduce the price of organic produce from small family farms in a local market as a means of encouraging this type of enterprise and greater consumption of these products.  As mentioned in the Oxford Journal quote above, they may not even be able to ensure that it is possible to produce organic produce at all in the near future because of reckless, unrestrained scientists and ineffective government.

      The British government's plans include a scheme called ‘The Plan for Public Procurement’  to “commit to buying fresh, locally sourced, seasonal food, through a new, simplified food and drink buying standard.”  “The commitment from central government to use this new buying standard means that just over half of the £400 million will be up for grabs by British farmers.”  However, this buying standard will be contingent upon suppliers satisfying five key criteria: (1) how and where food is produced, (2) health? and nutrition content, (3) efficient use of natural resources, (4) meeting government’s socio-economic priorities, and (5) quality of service and value for money.  It seems clear to me when considering these criteria along with the claim that the “announcement comes as 15 agri-tech projects are told they will receive a share of £18 million of funding from government and industry to help accelerate agricultural innovation and their commercial viability” that raw milk does not fit in the picture.

To conclude, I think too many people are too busy in the global race for harmonising and standardising life for the New World Order.  Prince Charles said that harmony is a nice idea in his book, Harmony, a New Way of Looking at the World.  But as another wise old nursing home resident put it, “harmony is a nice idea, but ...”.  As it is unfolding, global harmonization of laws is not amounting to harmony on Earth, but rather, it is decreasing the variety of our foods and leading us down the road to the lowest common denominator at the bottom of the heap in food quality.  Of course, food is one of the pillars of life along with air and water which, as is obvious, are also being systematically made lifeless (KILL those bacteria!).

Pasteurise all Milk!  It appears that the days of raw milk for consumers are numbered, unless, for example, sterilising the cows before milking isn’t counted.  Think sterilising cows is preposterous?  The medium of growth for certain crops such as tomatoes and mushrooms is being sterilised.  Why not sterilise the medium of growth for milk.  It will be done, if it's at all possible, if scientists have their way and it would make money.  The prediction by British cosmologist, Martin Reese, that this is our Final Century is looking more feasible by the day.  Because for one thing, we need bacteria to be healthy human beings!!!  Raw milk, especially when fermented or made into cream, butter and cheese, is a lovely source of health sustaining/giving bacteria.

Best wishes to the government in its endeavours.
 

 
Thanks to Inprofood for the photo.

Reply From Defra


Dear Ms Wilson,
 
Thank you for your letter of 7 July about small farms and raw milk. I have been asked to reply.
 
The government wants to see a profitable, thriving and sustainable dairy sector and recognises the vital contribution small dairy farms make to the UK’s economy.
 
We continue to support the UK dairy industry’s work in a number of key areas, including the dairy industry’s Code of Best Practice for Contractual Relations. The Code already covers in excess of 85 percent of raw milk production in the UK and is helping to improve contractual relationships between farmers and milk buyers.
 
The UK’s agri-tech strategy was published on 22 July 2013. BIS, Defra and DFID, with support from UKTI are managing implementation. The strategy is being driven by a Leadership Council (LC), which brings together government departments, farming and industry as well as the agricultural science community. The Government is investing £160 million, to improve this country’s uptake of research into farming so that the UK can remain globally competitive.
 
You have also raised a number of questions about raw milk which is produced on small farms in the UK.
 
You may be aware that in 2012 the FSA Board agreed to review current controls and possible approaches to managing the risks associated with consumption of raw milk and cream from all species in England Wales and Northern Ireland.
 
The consultation process started on 30 January 2014 and set out options, ranging from a requirement to pasteurise all milk prior to sale, through to removal of all sales restrictions. This was a full public consultation and comments were welcomed from all interested parties. The consultation closed on 30 April 2014.
 
Options were reviewed in light of consultation responses and evidence obtained from wider engagement activity. This included a stakeholder event held on 31 March 2014, which gave consumers, producers and other interested parties the opportunity to discuss the proposals directly with the FSA. Over 100 stakeholders attended the meeting, which was open to the public and webcast live on the day.
 
The FSA received 536 responses to the consultation on Raw Drinking Milk (RDM) controls. Most were from individual consumers, with many expressing similar views to those raised in your letter. The majority supported continued access to sales of RDM, with the main focus on individuals being allowed to make informed choices and having the freedom to choose to consume the product. Many consumers indicated the need for greater accessibility of RDM, and cited perceived health benefits as the reason for consuming the product. Many RDM producers, as well as consumers recognised the need for the stringent regulations to safeguard consumers and the industry.
 
Following the additional evidence provided by the consultation responses and wider engagement with consumers and farmers, the FSA is exploring alternative approaches to the current control model and options presented in the consultation. The FSA Board discussed the outcomes of this review and initial proposals for future controls at its open meeting on 23 July 2014. Link to FSA Board Paper on RDM: http://multimedia.food.gov.uk/multimedia/pdfs/board/board-papers2014/fsa-140704.pdf
 
The FSA has worked closely with producers during the review to understand the sector better, inform policy options and consider the impacts of options and will continue to consult producers on future controls. The conclusions of the FSA’s Board meeting will be reported on the FSA’s website in the usual way.
 
You have asked why European law governs raw milk dairy farms when Regulation (EC) No 853/2004 has a clause stating that small local enterprises, such as this should be regulated at national level. EU food hygiene rules [1] that came into force on 1 January 2006 allow Member States to introduce their own national rules to prohibit or restrict the sale of raw milk in domestic markets. In the UK, these such rules are provided in Domestic legislation [2] which in England, Wales and Northern Ireland permits the restricted sale of raw cows’ drinking milk and raw milk from other farmed species (i.e. goats, sheep and buffalo). The restrictions on sale were introduced to control outbreaks from RDM consumption. Sales in Scotland are banned.
 
In your letter you also make reference to the fact that Plaw Hatch Farm has lost its licence to sell raw milk due to a cow being test positive for TB. I understand the concern you have over this. However, unpasteurised milk is a proven route for human TB infection as evidenced by the high number of human cases of bovine tuberculosis before the adoption of widespread pasteurisation and the introduction of the compulsory TB eradication programme. The TB eradication programme controls disease in the UK cattle herd by regular testing of cattle and removal of infected animals.
 
One of the statutory control measures in place to protect public health is to ensure that raw milk comes from animals belonging to herds/holdings which are officially tuberculosis free, and brucellosis free. If a herd or holding is not disease-free, raw milk and colostrum from non-reactor animals can only be sold to a wholesaler who must heat treat the milk and colostrum before marketing it for human consumption. If the raw milk is from sheep or goats, this could also be made into cheese that has a maturation period of at least two months. Milk from reactor animals cannot enter the food chain.
 
We hope that the information provided is helpful and wish you the very best in your endeavours.
 
[1] Regulation EC No. 853/2004, Annex III, Section IX, Chapter 1, 2
 
[2] The Food Safety and Hygiene (England) Regulations 2013, Schedule 6 (similar requirements apply in England, Wales and Northern Ireland)
 
Omrina Nawaz
Customer Contact Unit
Defra


Photo credit with thanks:  Department for Environment, Food and Rural Affairs, GOV.UKLike me, they like strawberries!  Too bad we disagree on how to grow them.