There really are a lot of rules to follow in life.
If you operate a business with food of any sort, wow, an incredible amount.
What is the intention of these rules?
- safe food
And safe food is:
- produced in a healthy manner
- monitored and checked at regular intervals; verifiably safe.
- clean and attractive
Sure the PMO - Pasteurized Milk Ordinance - who's rules we follow for dairy - says it longer and in more detail than I have. Pages and pages of rules, referring to other standards like 3A sanitation, etc.
But there is a fundamental principle of why we need this whole set of rules. It is an attempt to describe practices, within systems, that they feel bring about the highest possible safety. Feel as in opinion, and static, inflexible.
Those rules are more specific - when they can be, and sanitation practices, machinery, uniformity are easy to be more specific about - easier to control with paperwork and descriptive rules.
Not any more safe, but made easier in one respect. But the thing is, it brings about a giant change in the system it is attempting to control. Larger more factory-like situations.
We have here - at our farm - instead, a:
- safe and effective dairy system
- checks and balances, multiple check points and redundancies
- an active and evolving safety network: people, practices and attitude
We have a problem, though: Our parlor doesn't fit Food Safety's rules.
A new facility, finished September 2008. Design approved, built by professionals, inspected by DATCP 3 times with essentially perfect reports, yet today: No good. DATCP Food Safety made a mistake. Sorry about that they say - but no way.
They would quit arguing real quick it was about safety. And you aren't going to get them to admit that they're leaning on our farm because I speak out against ethical issues within DATCP and for Raw Milk. All they can argue is there are the rules. Yet, they work around rules every day; their inspectors go out and look at the entire situation and make good calls - recall the goal here is safety. They also let stuff go on very dirty farms, but know the milk will be pasteurized so they let it slide. Take a random tour of dairy farms and see for yourself.
The rules as applied by Food Safety in our case take an open design flat 8 stanchion barn-parlor, in a multi-use building, and close it entirely in. Making it far less desirable to be in; more in need of mechanical ventilation; creating of wet areas where there is no ventilation possible with walls.
We have what is considered a "dry" parlor. We do not need to spray down the floor, creating hundreds of gallons of waste soup. We do not promote bacterial growth with dry, naturally ventilated and kept clean environment.
The wall would completely separate the holding area (where cows waiting to be milked wait) from the 'parlor'. What exactly is going to crawl off whatever and across 8 ft of cement and do something bad to a cow no one can explain reasonably. But they can site a rule, and if you're lucky, a fantastic story about a remote possibility as the reason for the rule.
What we use this separated but open - rather than closed off by a wall - area for
- ventilation, drying is rapid and complete under all circumstances with this design. ALL circumstances, with little needed from us (an ideal practice - occurs automatically but not mechanically (breakage)!).
- we are actively observing ALL COW BEHAVIOR while milking. Social order/interaction, acting (off by self, ears/head down, any non-normal behavior etc.), - behavior in a semi-relaxed environment - which is the holding area. Approximately 1/3 of our concern (health) observations come from this area alone. Another 1/3 from the actual milking parlor, and 1/3 from field/pasture observation. On busy days (many in season), it is the single best evaluation situation, as 2 milkers are on duty, observations are discussed, they can be observed more closely, and any action taken.
Close that off: It is isolated. The only observation is when you open the door to let the next group in, reducing observation time dramatically. Windows: Limiting then to sight. Hearing is critical. Direct observation with proximity is far superior to indirect.
- RESULT: Close observation of the health of the animals in multiple situations to reveal the most possible about any health concerns. Relaxed: on pasture; semi-relaxed in the holding area; not as relaxed being milked.
Example: We note even when cows are extra fidgety being prepped. It warrants extra observation and everyday tests for high Somatic Cell Counts. We catch and monitor and act early every time with this system. We have tremendous health in our herd. Start of 3rd year:
- no major disease at all. No metritis (retained placentas), acidosis, ketosis, milk fever, trouble having calves. Zero. Zero divided into as many cows as you'd care to provide. Our entire program works very effectively.
- very low instance of anything more than subclinical mastitis. We milk once a day, which given we see the animals once in 24 hours (but far more thoroughly than in a get-them-in-and-out-fast parlor), is a higher risk. We use a Mas-d-tek electronic mastitis detector to counter-act any increased risk. It's this kind of thorough thought we bring to everything we do. Risk identified, process to identify and minimize that risk. Pretty smart, you'd think. Nope, Food Safety couldn't care less. They care about rules. Not safety, rules.
Risk: Bringing dirt into the parlor. From the path in from the unpaved holding area. From being in a wet pasture. From a bedding pack. From anywhere. Cows and dirt - especially manure - together - are a fact of life.
Minimizing the movement of that dirt towards milk contact points - the milk machine attached to the udder over the parlor concrete floor - is a major concern. That we address through the facility design (distance away) - but also through practice - procedures - and monitoring - together forming a system that minimizes that dirt movement.
Yes, cows on any farm will track in. You can have all the concrete you want and still track in manure. (Remember, they keep the maker of the manure with them at all times).
We sweep up again once the cows are in place to be milked. Each person is monitoring only 2 machines. We have had only 1 machine drop off and continue sucking air in 2 years. We use DeLaval milk machines that shutoff suction if they drop off. Our cleaning procedures are clear and practiced to minimize dirt pickup from udders. Filters are monitored closely and graded daily. Our filters are always very clean. Our coliform and plate counts are always at minimums indicating excellent sanitation. To look at our operation, to look at our cows, to look at our records, to look at our dedication, you would think: WE NEED MORE FARMS LIKE THIS AS EXAMPLES OF HOW TO DO IT - PROFITABLY and with HIGH LIFE SATISFACTION. Nope! Not from Food Safety.
You SHOULD care about this: We love milking cows in our barn like it is; what we have is thoroughly thought through. There is no randomness or chance in our design or procedures. We are exceptionally conscientious. We are open to suggestions that maximizes safety. No one should be for senseless rules that make the situation less safe. There are variances granted. The intention there is to make up for rigidity in a rule set. A pretty good feature of a fair and effective system.
Yet, Food Safety just says no.
This theme of antagonism towards family dairy farmers, towards entrepreneurs, towards any change, towards any new thinking ought concern you. We are not going to get efficient or practical - or more - small - systems with thinking like that. That attitude is costing this state jobs. Their attitude is in fact ignorant.
Come to the table and work with us - but work with the whole situation, not the rule about a physical structure - which is only a piece of the overall pie.
A piece of the overall situation of creating high quality safe milk: Which is something anyone that would consider providing raw milk to consumers needs to know a whole lot more about. Unhealthy cows in a 'conforming structure': Danger. Yet no rules against that. How do you decide what is a healthy environment? Certainly it means something profoundly different to me than it does a CAFO operator.
And I'd like to be in on that conversation about raw milk safety. It must be more than conforming structures. It comes literally from the ground up to include everything in the system.
Food Safety wants a literal - and costly - box around our milking parlor.
We have - and are open to hearing more - about a figurative - but more effective - box around risk in harvesting milk safely from cows. We will live with them happily; we will monitor and record about them, and everyone but everyone ought be happy with this safe happy system.
C'mon people - let's use those things between our ears and innovate - think big thoughts - helping people - not little things like rules vindictively and arbitrarily applied. Too much is at stake. Please help.
Scott Trautman, PROUD and INNOVATIVE Wisconsin Dairyman