This is a totally bad set of regulations.

By assuming many consumers are idiots and unable to make food choices VaDACS grossly overestimates the importance of their department. The efforts that they have put into harrassing small producers and families that simply have overages in milk production belies their claim for public safety., when there are many other areas that could more appropriately use these resources to address legitimate concerns. By demanding only cooked milk and milk products, and not cooked meat and meat products the department is showing a definite hostility towards small dairy producers, which is not warranted by the health facts presented. In addition, the restriction that ALL farmers may not sell/give away fresh uncooked milk is limiting their contractual rights to sell their goods.

I encourage the inclusion of an exemption for direct to consumer sales of all dairy products, as previously presented by the Office of Planning & Budget, which would allow the part time cheese maker to be able to market their farm products.

The State of Minnesota has a constitution provision which guarantees farmers the right to sell their products unencumbered by licenses and inspection~~~we do not see Minnesotans having these dire health consequences that VaDACS erroneously presents.

Virginia, the cradle of out republic, needs to honor it's farmers, consumers, and home producers by allowing them free trade of their goods rather than kowtow to agribusiness and producer lobbies.

These proposed regulations are totally inappropriate. They place large economic burdens upon the businesses involved, and offer NO place in the system for part time dairy product processors. There should be an exemption for homestead producers and offer them a welcome place in the economic system. Under these proposals they would be put out of business pr have to operate illegally, unless they were able to subsidize sales through other occupations. It is absolutely shamefull that the Commonwealth would have so little consideration for diversified operations, and make such a large effort to move towards the larger producers at the expense of removing consumer choice and producer earning ability. It is absurd that one cannot purchase items from a neighbor who is supplimenting their income without being subject to prosecution, which would follow if these regs were enacted. An exemption is necessary to protect these small producers and the consumers which want the choice of product.

 

The proposed regulations are too demanding and in light of the budget crunch should certainly not be entertained as a postive reduction in expense for the government. They are anti-farmer, anti-cheesemaker, and anti-consumer by making it too expensive and difficult to do business.

Why would there be a need for daily operation? some cheesemakers only make cheese one week a month, or a couple days a week. Why is that a problem?

BAD RULES!!!

I am strongly opposed to increasing the regulatory power of VADACS over home
cheese makers and milk producers. I encourage the inclusion of an exemption
in these regulations which would allow the part-time home producer to sell
directly to consumers without restriction. These proposals would do 1 of 2
things:

1#put small producers out of business and discourage new entrepreneurship

2#contribute to the widespread "blackmarket" in home produced product. If
the state has a concern, it seems they would want these producers to be
above board and paying sales tax, and having herd inspections for TB and
brucellosis which of course they will not do if these regulations are passed
and there is no accomodation for their business.

Who will feed us when small American farm families are forced out of business by the massive weight of bureaucratic regulation?  And exactly how safe are factory farms?  Regulation does not equal safety.  Small farmers take great pride in their products and should not be required to meet standards that would not have any effect on the quality of their product.  These regulations would only serve as another tax burden on the family farmer.

As both a small farmer and a consumer of locally and sustainably grown foods, I am extremely concerned about HB425 and the proposed dairy regulations. HB425 is absurd and unenforceable. How can you regulate an "operation that is conducted in a mobile, stationary, temporary or permanent facility or location, where consumption is on or off the premises and regardless of whether there is a charge for the food?" By this definition, when my poultry club serves refreshments at its monthly meeting or sells baked goods at a farm tour, we are a food establishment to be regulated. The proposed dairy regulations are also too restrictive, regulating even a one cow operation! Why should a dairy conduct business 5 days a week, year round to qualify for a license? Dairy animals naturally freshen once a year, in the spring, and are healthiest when allowed a rest between lactations. Why should we force unnatural production on our animals? Many farms make cheese once a month and sell it at seasonal markets. Moreover, before the first animal may be milked there is much work to do on any farm. Some consumers prefer raw milk. If cheeses are clearly labeled as made with non-pasteurized milk, why can't the consumer be given the opportunity to decide whether or not to buy them? Why would a farmer who makes most of his income at market sell an unsafe product? Farmers are not faceless CEOs of major corporations; but are directly available to the public, week after week, year after year. We MUST sell a good product or there will be no repeat business. What farmer would ever sell milk that has "any abnormal condition, including... curdled, ropey, bloody or mastitic?" Or with "visible extraneous matter such as insects, filth, blood, foreign color or foreign objects or substances?" Or with "extraneous water" or from animals recently given antibiotics or fed on pesticide-laden pastures? We small farmers know our milk is clean. Why should we have to pay for the testing of it? Why should organic farmers who already pay for certification and inspections have to pay again? Small farm products are often WEEKS fresher than what is available at the supermarket. For instance, I collect, wash and package eggs daily, and give or sell them within three days of lay. Grocery store eggs are labeled for a sell by date of five weeks after packaging. How old is the milk on the grocery shelf? Whose farm produced it? Contrast my friend's four Nubian doe dairy with a large commercial dairy. My friend milks all the does herself by hand; she first wipes each udder clean, squeezes some milk from each teat into a cup and after inspecting this milk, gives it to the cat. Then she continues to milk each doe in her own sterilized stainless steel bucket. She feeds this milk to her family and also sells her soft herbed cheese at market. Meanwhile, a commercial dairy employee attaches vacuum tubes to each cow's udder and flips a switch to begin the milking process. He does not spend significant time with any cow, he may allow milk from sick cows to mix in with that of healthy cows. Commercial dairy milk is shipped in tanker trucks to a factory where it is mixed with milk from other farms, bottled and shipped again to hundreds of grocery stores. Yes, inspect the commercial dairies! They have the potential to make MILLIONS of people sick! We worry about these "fieldmen" who have the power to put us out of business. What recourse do we have if we disagree with their findings? Why is VDACS attacking farming, which is advertised as a Virginia tourist attraction? Yesterday I heard a radio ad for Virginia farm products... the "poor Idaho" ad, in which the announcer, auction-fast, rattles off an impressive list of products proudly grown in our state. What will happen if your regulations go through? Will there be any farms left to advertise in the Virginia Home Grown Guide? Farmers markets may cease to exist or may be staffed by employees of major corporations, whose "fresh vegetables" were picked weeks before, unripe, irradiated and coated with wax! What will happen to the very popular Loudon and Fauquier County Farm Tours? To the Shenandoah Valley's apple industry? To the land once owned by small farmers who cared to keep streams clean and flowers growing near the road? Please reconsider!