San Diego County Crackdown on Raw Milk

The San Diego County Crackdown on Raw Milk occurred in response to a proposal to allow homeowners to keep miniature goats in San Diego.

Proposed Urban Agriculture Rules
On October 5, 2011, the San Diego City Council Land Use and Housing Committee heard the draft rules for urban agriculture and took public comment. The proposed rules, as drafted, allowed for keeping miniature goats within the City of San Diego.

County Opposition
The day before the meeting to review draft rules, the San Diego County Department of Environmental Health sent the following letter to the city council:


 * "When the County of San Diego became aware of the Urban Agriculture Ordinance, the County facilitated a couple of meetings with city staff, representatives from the California Department of Food and Agriculture and the County's Departments of Environmental Health, Public Health and Agriculture Weights and Measures. The purpose of the meetings was to inform city staff of the public health concerns with some of the provisions in the Urban Agriculture Ordinance. Based upon the September 28, 2011 city staff report, the County of San Diego's Department of Environmental Health and Public Health Services would like to take this opportunity to clarify why the County of San Diego still expresses concern with the allowance of backyard goats. We would like to thank your committee for this opportunity to review and comment on the Urban Agriculture Ordinance.


 * "It is important to understand that milk has potential health risks when unpasteurized or not pasteurized properly, therefore, we discourage promoting the practice of producing milk at home. The public health risk of this practice would significantly outweigh any potential health benefits. Raw milk may harbor a host of disease-causing organisms (pathogens): such as, the bacteria Camplylobacter, E. coli, Listeria, Salmonella, Yersinia, and Brucella. People with weakened immune systems, such as the elderly, children, and those with certain diseases or conditions, are most at risk for severe infections from pathogens that may be present in raw milk. In pregnant women, a Listeria monocytogenes-caused illness can result in complications, and E. coli infection has been linked to hemolytic uremic syndrome, a condition that can cause kidney failure and death.


 * "Fortunately, San Diegans have access to fresh milk produced in California State Certified Dairies that is either pasteurized or unpasteurized (raw). It is illegal in the State of California to sell or give away milk that does not come from a California State Certified Dairy, which is appropriately recognized in the City staff report. The County also supports the removal of goats from inclusion in community gardens and retail farms, which will eliminated some of the concerns.


 * "While the County agrees that education would be appropriate and necessary for any changes, it is still the recommendation of the Department of Environmental Health and Public health Services(sic) that backyard goats are not included in the Urban Agriculture Ordinance. The Centers for Disease Control and Prevention (CDC) has recently updated their raw milk website that contains useful information and materials, including a list of relevant publications and other scientific resources on illnesses associated with raw milk consumption.


 * "During our meeting, we also provided city staff with a letter from Dr. Christopher R. Braden, Director of the CDC's Division of Foodborne, Waterborne, and Environmental Diseases that specifically states, "To protect the health of the public, state regulators should continue to support pasteurization and consider further restricting or prohibiting the sale and distribution of raw milk and other unpasteurized dairy products in their states."


 * "The County of San Diego appreciates the opportunity to work with the City on the Urban Agriculture Ordinance, and will continue to work with the City to provide support to protect the health and safety of the residents in the County of San Diego. For any questions or additional information, please contact Liz Pozzebon at (858) 505-6672.


 * Sincerely,
 * Jack Miller, Director
 * Department of Environmental Health


 * Sincerely,
 * Wilma J. Wooten, MD, MPH,
 * Public Health Office
 * Public Health Services"

The City Tables Goats
In the October 5, 2011 meeting, the issue of goats was addressed as follows:


 * "Regarding the keeping of goats, as discussed in the report, the state director of animal health and food safety and the county department of environmental health have expressed concerns regarding the keeping of goats for milk and cheese production, due to the health risks of raw or poorly pasteurized products. I believe the committee members have all received a letter this morning from the county department of environmental health, expressing their concerns about keeping any goats. At this point, staff is recommending that this item be pulled from the current proposal and that we be directed to look... work with the county at a future amendment to see what will work properly."

Citizen Response
As citizens were given little notice to prepare to comment on the county's letter and the City Council Land Use and Housing meeting only allowed for comments that were one minute apiece, only three citizens made comments on the matter at the meeting. One goat advocate demonstrated to the Council how simple it would be for goat owners to pasteurize their own milk. Another noted that the reason the urban agriculture issue was moving so quickly was due to a grant that would soon run out, urging the council to consider legalizing backyard goats before the grant ran out. The third noted that people might want to keep goats as pets and not for milk. Additionally, Jill Richardson submitted written comments on behalf of goats, saying:


 * "I'm quite upset about the notion that goats should be outlawed because they might produce raw milk. Please consider that people are permitted to buy raw meat under the expectation that they will cook it. What's more, under U.S. law, it's legal for up to 49.9% of ground turkey samples tested to test positive for salmonella. This is disturbing as ground meat can have pathogens in the center and not just on the surfaces of the meat, which means consumers can become ill unless they cook the meat extremely thoroughly. When Consumers Union tested a random sampling of fresh supermarket broilers (chicken) in 22 states, 66 percent were found contaminated with either campylobacter, salmonella, or both. Most of the pathogens detected were resistant to at least one antibiotic. And consumers are trusted to cook this tainted meat sufficiently to avoid illness and allowed to risk it if they want to cook their turkey burgers rare instead of well done. Why are we not trusted to produce and/or pasteurize our own milk?


 * "What's more, the most dangerous food statistically is not raw milk but raw oysters - and those remain legal."

Related SourceWatch articles

 * Raw Milk
 * Raw Milk Raid Timeline

External articles

 * Jill Richardson, "San Diego's Urban Ag Makeover - The Good and the Baaaaaad," La Vida Locavore, October 7, 2011.