The Illinois Department of Public Health ("IDPH"), working in collaboration with the U.S. Food and Drug Administration, is proposing a new set of regulations governing Illinois raw milk production and consumption that could make it difficult for Illinois farmers to continue producing and distributing raw milk to their customers.
If you are an Illinois farmer and currently producing and selling raw, unpasteurized milk or products made from raw milk (or plan to in the near future), please take a few minutes to complete this brief survey. Your answers are very important to help us determine the potential impact of these new regulations on raw milk farmers and consumers.
Your answers are confidential and cannot be traced back to you in any way. This survey is sponsored by the Farm-to-Consumer Legal Defense Fund, Weston A. Price Foundation Members, and a number of Illinois raw milk farmers and consumers that want to keep raw milk available from Illinois-based farms.
Here is a summary of the new proposed regulations:
1) All Farms producing raw milk for human consumption would need to obtain a permit from the Illinois Department of Public Health. A Tier I Permit will allow on-farm sales only, the Tier II Permit will allow farms to sell and distribute through buyers clubs and/or herdshare agreements where a single individual can pickup for multiple families.
2) Obtaining a Tier 1 Permit will require an initial and ongoing farm inspection by the IDPH, which will require the farm operator to:
- Have a written procedure for recalling product and notifying consumers
- Maintain a log of each raw milk sale with consumer name, address, and phone number for one year
- Report any consumer complaints to the IDPH
- NOT make or sell any value added products made from raw milk, such as cheese or yogurt
- Submit to IDPH an annual report of the total gallons of raw milk sold
- Post a warning sign at point of sale stating that Raw Milk is not pasteurized and may be hazardous
- Provide IDPH-approved consumer awareness information with each sale or transaction
- Affix a label to each customer container with the name, address, permit number, and product date along
with WARNING information and consumer notification instructions for the local health department
- Grade and drain cow yard and loafing areas adjacent to dairy animal housing and shall have no
standing pools of water or accumulation of organic waste.
- Ensure the flanks, udders, bellies, and tails of lactating animals are free from visible dirt prior to milking
- Milking shall take place in an area with overhead protection, ceilings, walls and floors shall be made of
smooth,easily cleanable material, and shall have sufficient lighting.
- Clean and sanitize all milking equipment and milk contact surfaces prior to each use.
- Cool the milk to less than 45 degrees within 4 hours after beginning milking.
- Test milk at least four times every six consecutive months, samples to be collected by a certified sampler
- Samples must meet the following standards: Coliform less than 10 cfu/ml - SPC less than 25,000/ml,
SCC less than 400,000/ml and water supply shall have less than 1.1 cfu/100 ml of coliform bacteria.
- Store two milk samples daily for 14 days (one frozen and one refrigerated)
3) Obtaining a Tier 2 Permit will also require initial and ongoing inspections by the IDPH, with the farm operator required to:
- Comply with all of the Tier 1 requirements stated above
- Meet all inspections requirements for the Grade A Pasteurized Milk and Milk Products Act
- Obtain a permit for a receiving station with inspections every 3 months.
4) A dairy farm without a permit may only produce raw milk for consumption by family members living on the dairy farm premises, all other family members, friends, relatives, or visitors would not be allowed to consume raw milk produced on the farm.