Georgia Raw Dairy Act 2022, HB-1175, details and opposing arguments

Big thanks to Rahul Bali for status updates.

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Georgia Raw Dairy Act

Official Summary

A BILL to be entitled an Act to amend Chapter 2 of Title 26 of the O.C.G.A., relating to standards, labeling, and adulteration of food, so as to authorize and regulate the production, handling, transporting, and sale of raw milk and raw milk products for human consumption; to provide standards for safety, cleanliness, and health for such products and animals producing them; to authorize the Commissioner of Agriculture to enforce such standards; to amend Article 7 of Chapter 2 of Title 26 of the O.C.G.A., relating to milk and milk products, so as to provide for conforming changes; to provide a short title; to provide for related matters; to repeal conflicting laws; and for other purposes.

GRM summary

Before this bill, Georgia raw milk farmers could only sell their milk in compliance with state policy under a feed license. Labeling would include phrasing like “animal feed” or “pet food” and the raw milk products could be sold in retail locations.

Now comes HB-1175, The Georgia Raw Dairy Act, to free up sales of raw milk to include explicit use for human consumption. However, this bill does not permit the sale of raw milk through retailers. This bill essentially only allows farmers to sell direct to consumer, without the feed use labels. Accepting this permit system also requires the farmers to submit to testing and inspections as a requirement.

That’s underwhelming, if this were to become the sum of raw milk laws in the state it would be a step backwards in terms of accessibility.

Fortunately, this law does not remove the feed sales permit. Farmers can choose to stick with the feed license system and sell their milk in retail stores with the “pet food” label.

This is wonky, but since the feed license option is still around this bill becomes an addition to accessibility instead of the forward-looking step backwards that it might have been. Overall good news.

We’ll hear from the Rep who wanted to remove the feed license option later in this article.

Bill Sponsors

Full republican list of sponsors.

You can view how each Georgia representative voted on the Georgia Raw Dairy Act in Rahul’s tweet.

Key takeaways

From the bill’s official text from the Georgia General Assembly.

Raw milk sales for human consumption

Starting on line #30.

Raw milk for human consumption which is in compliance with this article and in compliance with the rules and regulations promulgated pursuant to this article may be sold, offered for sale, or delivered by the producer directly to the consuming public for the purpose of human consumption.

This includes testing, inspections, permitting as requirements.

Labeling

Starting on line #130.

All bottles, containers, and packages enclosing raw milk for human consumption shall be conspicuously marked with:

The words ‘Grade A Raw’ on the exterior surface. Acceptable locations shall include the principal display panel, the secondary or informational panel, or the cap or cover
The identity of the farm where packaged. This identity shall include the name, address, and permit number
The following information statement, in print no smaller than 12 point font, shall be included on the package: ‘This is a raw milk product that is not pasteurized’
The common name of the hoofed mammal producing the milk shall precede the name of the milk when the product is made from other than cattle’s milk.

Arguments against the Georgia Raw Dairy Act

Comments from House Minority Leader Rebecca Mitchell.

Rep Mitchell says she would like to see the bill pass, but has some reservations that caused her to vote No. Two things.

She didn’t want raw milk for human consumption sold at large retailers, this option was eliminated in an update to this bill.
She wanted the program for selling unpasteurized milk as feed tapered off and removed, the program was not eliminated in this bill.

Rep Mitchell cited institutions such as the FDA as cause to believe the risk of raw milk is elevated compared to pasteurized milk. If you’ve been following my work for any amount of time, you probably know I take the FDA’s data and conclusions with a dab of salt.

Later she goes on to compare raw milk with raw chicken. I’ve eaten several hundreds of pounds of raw chicken while I was adhering to the raw Primal Diet, so this point doesn’t resonate with me, personally.

Mitchell also was concerned that the warning label did not contain enough of a warning. As of now the required label under this bill states, “This is a raw milk product that is not pasteurized.” She’d like it to include more phrasing to emphasize the elevated risk that the FDA claims is inherent to raw milk.

I think if someone is reaching for raw milk, a food virtually all of us were informed of the FDA’s opinion on in grade school, they’ve already made up their mind.

If a “pet food” label wasn’t stopping anyone from drinking unpasteurized milk, I doubt more words on the label will dissuade consumers. It makes no difference to me, but I fully believe the day will come when we look back on those labels as silly and insane.

HB-1175 is moving forward and is expected to become law.

We’ll see how many farmers jump on board and how many stick with the feed program.

Suggested policy improvements

Two laws to maximize access to raw milk on the state level:

Full retail sales, for any and all raw dairy products. RAWMI operational standards for large farms is a worthwhile compromise
Cottage freedom, zero regulation, for small raw milk dairies and other cottage producers (see Wyoming and Montana)

Both of those in combination would make sure the smallest farmers are not excluded from the market, while making sure big farms keep their facilities clean.

Good luck to Georgia, get raw milk!