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The Colorado Department of Public Health
Denver, Colorado
May 19, 2004
Dear Sirs,
I have been requested to share with you our commercial organic raw milk production and
sales experience. For the last four years, Organic Pastures Dairy has produced a full line
of raw organic dairy products for retail sale ( 300 stores including Wholefoods) and
consumption here in California. The state of California (CDFA) monitors and tests all of
our raw dairy products multiple times per month. The state has never found one pathogen
(salmonella, E. coli O157:H7 or listeria) in any of our products. Even more interesting is
the fact that not one human pathogen has ever been found in the hundreds of
environmental swabs that have been taken in our plant facility.
Dr. Caterina Berge, DVM and PhD candidate at UC Davis, tested our milk cows’ fresh
manure and did not find any human pathogens. That’s right. . . no Salmonella. She was
able to show that when antibiotics are not ever used on the herd (as stipulated in the
organic standards) and when cows are not stressed (grass-fed and kept healthy) they
simply do not slough off pathogens in their manure. The data collected at Organic
Pastures was quite different from that found at other dairies. The typical conventional
milk tank had either salmonella or E. coli O157:H7 detected about 30 percent of the time.
In comparison, Organic Pastures has never had one pathogen—ever.
To study this issue further, Organic Pastures contracted with BSK labs in Fresno to
perform multiple challenge and recovery tests on our raw milk and raw colostrum. When
7 logs (10 million counts) of pathogens were added to one-milliliter samples of organic
raw milk they would not grow. In fact they died off. The salmonella was so badly out-
competed that it could not be found less than 24 hours later. The listeria drop was less
dramatic and was similiar to the E. Coli O157:H7 samples that were studied, but they
also did not grow and declined substantially over time.
The lab concluded: “. . . organic raw milk and colostrum do not appear to support the
growth of pathogens. . .”
During the period 2000 through 2004 there were several listeria-related food recalls in
California associated with pasteurized milk products and ice cream. During this same
period more than 12 million servings of Organic Pastures products were consumed and
not one person complained of illness and not one pathogen was ever found either by the
state, FDA or Organic Pastures.
This begs the bigger question. What is it that causes raw milk to kill pathogens? Just in
the last 24 months, the FDA has approved lactoferrin as an approved method of treatment
for pathogen reduction in beef slaughter plants. Raw milk naturally has levels of this
enzyme-based pathogen killer. Pasteurization inactivates this and other enzymes that kill
pathogens. These enzymes include lactoferrin, xanthine oxidase, lactoperoxidase,
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