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methodologies and new knowledge into effective public health practices for a safe and
wholesome product. She stated that the ordinance is the official national document setting
forth sanitation requirements governing the interstate shipment of milk and milk
products. She stated that adoption of the 2003 version of the PMO will bring Colorado
into conformance, thereby permitting freedom in the movement of milk and milk
products across state lines, and also to federal agencies, federal reservations and certain
school districts. She stated that letters from the Grade A fluid milk industry endorsing
adoption of the proposed regulations were received from Dean Dairy, Robinson Dairy,
Sinton Dairy Foods, Dillon Dairy Company, Leprino Foods, Meadow Gold Dairies, and
the Dairy Farmers of America.
Ms. Hruska stated that the department also is proposing an amendment to include a
definition of “sold or sale,” to clarify the prohibition of the sale of raw milk in the state of
Colorado. She stated that the intent of the proposed definition is to state that the purchase
of raw milk through cow share or cow renting or other animal leasing operations is not
allowed. Ms. Hruska provided background information on the proposed definition. She
stated that the department reviewed this issue in 1995, relative to a petition for
declaratory order concerning a cow leasing
Board of Health Minutes May 19, 2004 Page 11
operation by Guidestone Farm, and at that time it was determined that Guidestone Farm’s
cow share operation was outside the department’s regulatory authority. She stated that
because of a number of very significant factors, the department has revisited this issue
and thoroughly reviewed all the pertinent information. She stated that factors
precipitating the need to reexamine the issue include: a 1996 outbreak of campylobacter
associated with raw milk consumption by a Colorado wrestling team involving 17 ill
wrestlers; a 2001 outbreak of campylobacter linked to drinking unpasteurized milk
procured through a cow leasing program in Wisconsin in which 75 individuals were ill;
and numerous other outbreaks related to consumption of raw milk published in the
Centers for Disease Control and Prevention Morbidity and Mortality Weekly Reports,
and the Journal of the American Medical Association. She pointed out that copies of
these articles were included in the Board’s packets. Ms. Hruska stated that nationally and
internationally recognized health professional organizations have issued policy
statements since 1995 for the pasteurization of milk and against the consumption of raw
milk and raw milk products. She said these organizations include, but are not limited to,
the American Medical Association; the Association of Food and Drug Officials; the
National Association of State Public Health Veterinarians; the National Academy of
Sciences; the Institute of Medicine; and the federal Food and Drug Administration.
She stated that in light of this new information, and because it is the department’s policy
and practice to use a stakeholder process when developing regulations, the division
facilitated a number of meetings to encourage the exchange of information among all
entities impacted by this issue. She stated that stakeholders included those who currently
have cow or goat sharing or leasing operations and individuals wishing to start similar
operations; dietitians; nutritionists; physicians; the Dairy Farmers of America; the Rocky
Mountain Farmers Union; the Milk Marketing Board; a member of the Weston Price
Foundation; and many individuals wishing to consume raw milk. She stated that
extensive information was exchanged and thoroughly reviewed, and that none of the
information supporting the consumption of raw milk was credible, scientifically
recognized and peer reviewed. She stated that alternative proposals were submitted for
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