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Petition Asks FDA To Stop Enforcing Ban On Raw Milk Products, Require Warning Label

The Real Food Consumer Coalition (RFCC) recently petitioned the US Food and Drug Administration (FDA) to stop taking enforcement action against those who distribute unpasteurized milk and milk products sold in interstate commerce when those products bear labels warning of the health risks of consuming such products.

The RFCC filed the petition in furtherance of several executive orders signed earlier this year by
President Trump that are intended to reduce regulatory burdens and costs. The request that
FDA exercise its enforcement discretion with respect to certain unpasteurized milk and milk products in interstate commerce would “reduce regulatory burdens while maintaining adequate safeguards for the public.”

“Self-pasteurization is as effective as industrial pasteurization in reducing bacterial infection in milk and milk products.”
—Real Food Consumer Coalition

RFCC was formed to empower individuals and organizations to develop community-based food production, distribution, and management systems. It provides guidance and training resources to farmers, food clubs, and other interested parties to reduce “burdensome and costly government regulation in private and peaceful transactions.”

RFCC’s members include dairy farmers who “would like to sell unpasteurized milk and milk products across state lines, and consumers and buying clubs who would like to purchase and consume unpasteurized milk and milk products in interstate commerce.”

The RFCC requests that FDA exercise its enforcement discretion to avoid taking, and to cease taking, enforcement action against those who distribute unpasteurized milk and milk products in interstate commerce when the milk products bear labels that include in “conspicuous bold face type prominently displayed under the statement of identity” for the product: a warning regarding the health risks of unpasteurized milk and milk products; and, when applicable, instructions for safe handling, including self-pasteurization.

In particular, the requested warning and instructions for unpasteurized milk and cream would include a warning that the product “may contain disease-causing organisms”; as well as safe handling instructions, which would include keeping the product refrigerated and, prior to consumption, pasteurize the product.

For other unpasteurized milk products, which “may be difficult to pasteurize,” such

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