Original image was via The Ontario Farmer, subsequently modified to improve legibility.
On February 11th, The Ontario Farmer reported that Health Canada is inviting comments on whether regulations regarding raw milk ought to be made or changed. The story quotes Barfblog blogger Dr. Doug Powell on the risks and dangers posed to consumers by raw milk. It then goes on to talk about how both Health Canada and the FDA are inviting comments on raw milk to help them improve factors such as assumptions, modeling techniques, data, and transparency of documentation. The story, however, only provides links to risk assessments on soft ripened cheese, both from the FDA. And it states that the comment period opens February 11, 2013 for 75 days.
Sounds good on the surface. Finally, it would appear, Canada’s (and America’s) health policy makers are taking notice of the fact that regulations regarding raw milk might be out of sync with public awareness when it comes to matters of raw milk safety and health. One could imagine from reading that story that maybe now the governments are willing to listen to what people think. Wouldn’t that be nice?
And yet, where exactly does one make such comments? The Ontario Farmer story gives no information on that crucial detail. The Health Canada website doesn’t offer any clues. Putting “raw milk comment” into the search box there doesn’t lead to any likely looking pages. A phone call to Health Canada’s switchboard is answered by someone who doesn’t have anything like that in her database, and offers a referral to the CFIA’s “Office of Food Safety”. But a call to Health Canada’s media relations office nets a promise to have someone call back. That was 9:30 am Feb 13th, two days after the comment period opened. We’ll see how long it takes them to get back to us, and what they have to say when they do.
There is a similar story running on Farms.com, dated Feb. 12th. That story provides the following contact information: “U.S citizens can participate in the public comment period by submitting comments electronically – through the docket FDA-2012-N-1182 on regulations.gov. Canadian citizens can find out more information through Government of Canada website.” The Government of Canada website listed seems to provide only information on raw milk, but no obvious means or links to comment.
The Bovine 
Personally I think it is another ploy to appear like they are seriously looking into it and another way to draw in emails to get addresses (now no privacy) and names of those who comment and maybe see what kind of opposition they would face in the farming sector. Unless it is a public mtg I would not submit anything in writing nor waste my time. “They” will not set a precedent nor change. It is PEOPLE that need to get verbal thru media to express what THEY want.
As near as I can tell, what they are really talking about is soft cheeses made from raw milk and they are inviting comments on such. If you go to
regulations.gov or http://www.regulations.gov/#!documentDetail;D=FDA-2012-N-1182-0001 . You can find a place to make a comment.
That is what the Ontario Farmer is talking about. Soft Cheeses not drinking raw milk.
Aren’t soft raw milk cheeses legal in Quebec already? Where certain guidelines are followed, natch!
Good question. I’m not exactly a computer or web Newbie, but so far, I’ve been hunting for over 1/2 an hour and can NOT find a place to leave a comment!
Make comments here at regulations(dot)gov : http://www.regulations.gov/#!docketDetail;D=FDA-2012-N-1182
Editor : It would be an interesting situation and message for Canadians , if Health Canada abdicated managing the link for comments and gave the responsibility to the Americans . If that turns out to be true it would be the first time in Canadian history that a Canadian public survey or poll is managed by Washington ! I hope this proves to be incorrect. But it is now an Open Secret that Mr. Harper is harmonizing as many Canadian laws and regulations as possible with the US without further public discussion.
I am speculating again but I would not be surprised if the Harper Conservative government has already long decided exactly what they are going to do as far as Raw Milk laws and regulations go on the federal level even before the survey was released ! The survey may just be a ” fig leaf” where the federal government pretends to be serious about requesting our opinions and exercising our democratic privileges.
Ironically , in the case of Raw Milk, the libertarian-minded farmers may actually benefit from this situation, as the US laws are less draconian than Canada , and, in fact, allow individual states to decide the level of Raw Milk accessibility (or no accessibility ) . Whereas in Canada we are faced with this blanket and infantile ban .
It is unfortunate that such decisions, even if beneficial , are decided in secret, but I guess we have to take what we can get and try to see how our overall humanitarian thrusts can fit the new bureaucratic paradigm.
Thanks Raoul! Your link worked for me. I hope that all that read the
Bovine that are not in the direct line of fire (farmers producing raw milk) will comment. We must show the officials the demand that there is.
I thought “Health” was clearly regarded as a provincial matter. Not sure a change at the federal level would change anything on the provincial level. Or???
Peter : On this particular issue there is overlap. For example, the Quebec provincial government had to practically beg the federal government for 4 or 5 years just to get an exemption on the regulations pertaining to “Raw Milk Cheeses”. I believe that the Quebec government was and is more than ready to legalize all forms of raw dairy and has been for decades but have been forced to adopt a “go slow ” approach because the topic is so “taboo” in English Canada . This information is from a leading microbiologist of the Quebec Ministry of Agriculture.
I personally am in favour of a decentralized provincial approach like the US rather than waiting another 20 years for some kind of national consensus to maybe or maybe not emerge.
Peter
I think Health Canada and the FDA are looking to support their positions that milk for cheese should be pasteurized and/or that raw milk cheeses be aged for 60 days before sale. Within Canada this is very much a Quebec versus Health Canada issue (since Quebec has already waived the 60 day ageing requirement) with Quebec ‘going it alone’, against Federal Policy. Highly political. For both Canada and the USA, the issue is raw milk cheese imports, primarily from the EU. More politics here, including overall trade with the EU and Cdn supply-management issues.
I can’t say I understand the mechanics of these risk assessments, but the outcome seems to have a clear message, one that Health Canada and FDA are seeking to endorse.
“Safari can’t find the server ‘www.regulations.gov.”
The domain name appears to be registered, but there is no name service responding.
Did Raoul’s like work as clicked, or did you have to edit it? Because it doesn’t work for me!
Apparently the FDA and CFIA aren’t the only ones without ears. I tried to post the following comment to the Farms.com page, and five times it rejected it because of “some error,” without telling me what to fix!
—————-
This may simply be a PR stunt. One blogger (http://tinyurl.com/dxuy96x) went to considerable effort to try to find out how to submit comment, to no avail.
They may *say* they are accepting electronic comments, but they apparently have no ears.
Here is what I found but again it’s about cheese not milk
“Please direct your questions or suggestions regarding the draft joint risk assessment to Health Canada at the address below.
Bureau of Microbial Hazards
251 Sir Frederick Banting Driveway
Tunney’s Pasture, PL: 2204E
Ottawa, Ontario K1A 0L2
E-mail address: bmh_bdm@hc-sc.gc.ca”
http://www.hc-sc.gc.ca/fn-an/securit/ill-intox/info/2012-can-us-eu-listeria-cheese-fromage-eng.php
It would seem that the regulations.gov site is currently down. I did get onto the page a few days ago, however.
A further suggestion : It might be helpful if 2 or 3 or more experts also post their full replies to the FDA/ Health Canada survey here on THE BOVINE ?EDITOR : It might be worth an article in itself ?
As some of the questions are technical in nature so if we can “pool our knowledge base” the result might be more effective. Just a thought .
It could be done anonymously as well. Also a farmer prefering to remain below the radar could ask someone from the consumer side of the equation to post their replies . I encountered a similar situation 2 months ago when Health Canada published a survey about minimal allowable tolerances for GMO’s from foreign food imports . I had to call CBAN to get the best technical expert level guidance on several questions which were not so cut and dry.