Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Department of Agriculture and Consumer Services
 
chapter
Rules and Regulations Governing the Production, Handling and Processing of Milk for Manufacturing Purposes and Establishing Minimum standards for Certain Dairy Products to be Used for Human Food [2 VAC 5 ‑ 530]
Action milk for manufacturing purposes
Stage Proposed
Comment Period Ended on 12/9/2002
spacer
Previous Comment     Back to List of Comments
10/10/02  12:00 am
Commenter: Larisa Sparrowhawk

third try to enter comment
 
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!
CommentID: 34