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banned or made safe to begin with. This crucial distinction has not been lost in many
other jurisdictions throughout the world besides Canada, where raw milk is freely
available. The Canadian government has ignored important differences in raw milk
production. It has failed to recognize and publicize the risks introduced by modern
off-farm dairy processing, by diverting attention with isolated incidents of infection of
uneducated consumers of raw milk (www.healthplanning.gov.bc.ca/hlthfile/hfile03.html)
and by failing to develop, maintain and publicize actual food poisoning statistics for all
food groups against which raw milk consumption could be evaluated in an unprejudiced
manner.
This is the essence of this submission: Raw milk can be made safe for human
consumption. The raw milk that can be made safe is expressly for raw consumption.
It is distinct from raw milk made strictly for and used by the current Canadian off-
farm mass production dairy industry.
Definitions of food safety, et al.
Part of the difficulty we experienced in coming to understand the safety issues
surrounding raw milk was a lack of clear definitions for many of the concepts.
This began when we asked Health Canada for their definition of food safety. We were
expecting one which took into account the fact that all food groups cause food poisoning
on a regular basis (www.magma.ca/~ca/rawmilk/graph.jpg) and against which we could
therefore easily compare raw milk. However, we were surprised to receive from Health
Canada a qualitative idealistic definition, prejudiced towards processed foods, which took
no account of empirical results. Upon reflection, this position appears designed to support
big business and to protect Health Canada from litigation because pasteurized milk food
poisonings can be conveniently blamed on manufacturing errors, which are promptly
investigated and forgiven, and pasteurized foods continue to be sold on the market
because the law is prejudiced towards them to begin with.
For a definition of food safety, we were initially directed by Health Canada to the Section
4 definition in the Food and Drugs Act, which states:
No person shall sell an article of food that:
(a) has in or on it any poisonous or harmful substance;
(b) is unfit for human consumption;
(c) consists in whole or in part of any filthy, putrid, disgusting, rotten,
decomposed or diseased animal or vegetable substance;
(d) is adulterated; or
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