A reality based independent journal of observation & analysis, serving the Flathead Valley & Montana since 2006. © James Conner.

2 February 2015

Do raw milk test sample collectors need only 30 minutes training?

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Anyone who’s spent productive time in a science laboratory knows that a bit of training is required before a person is qualified to collect samples for lab tests. One must learn the protocol for collecting the sample without contaminating it, the protocol for shipping it to the laboratory, and the protocol for documenting the chain of custody. Not all sampling protocols can be learned overnight, nor do most sampling program administrators believe they can.

But Rep. Nancy Ballance (R-Hamilton) believes that even a day’s training can be too long.

Ballance, sponsor of HB-245, which would legalize the sale of raw milk in Montana, claims a technician hired to collect samples of raw milk for legally required tests can be trained in 30 minutes. And she’s put that in writing in her rebuttal (PDF) to the official fiscal note (PDF) on HB-245:

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Not only would that save the taxpayers $54,840, it would save dairies from embarrassing written reports by professional sanitarians who might observe unclean practices while collecting the samples of raw milk. The report of a professional sanitarian would carry weight. The report of a 30-minute wonder would make helium seem heavy.

Ballance’s rebuttal contains amateur hour assumptions

All fiscal notes are based on assumptions. The official fiscal note may be a worst case scenario, but Ballance’s rebuttal to it is less a best case scenario than an amateur hour scenario. A good sampling protocol for raw milk should require containers suitable for maintaining a cold chain (PDF). Figuratively speaking, the Ballance protocol brings to mind a Mason jar and a beer cooler:

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Ballance asserts that only 30 dairies would obtain the $20 small herd exemption permit. The fiscal note assumes 70 dairies would. Therefore, the net taxpayer cost per dairy in the table below provides a better basis for comparison than the overall differences in program costs. The per dairy differential is almost five to one.

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What both the fiscal note and Ballance’s rebuttal to it prove is that HB-245 would have Montana’s taxpayers subsidize lab tests that might reveal when raw milk is bad, but would not assure that untested raw milk was safe. Those who drink raw milk may pay for their folly with their health or even life. The rest of us would pay for it through our noses.