Illinois Headed For ‘National’ Public Health Accreditation?
At the risk of losing State Sovereignty, the Illinois Health Department released their roadmap for the future of public health in Illinois, but is it the future the public wants - or needs?
By Tom Kocal | The Prairie Advocate News
Embracing the goal of improving public health for all Illinoisans and the need for government transparency, the Illinois Department of Public Health (IDPH) just released its Five Year Strategy 2014-2018.
The IDPH says the strategic plan is a roadmap for IDPH to build the capacity of the Department to better meet the public health needs of all people and communities in Illinois. The plan is also crucial as IDPH works toward becoming a nationally accredited public health department in an effort to improve the quality and performance of the Department in serving all Illinois residents.
“We started developing the strategic plan by asking, how do we (as a Department) maximize our effectiveness, influence and value in promoting health equity, safety and improved health outcomes for residents here in Illinois,” said Illinois Department of Public Health Director Dr. LaMar Hasbrouck. “After a year of hard work, I am excited to present a plan that will help us better direct our efforts to serve the citizens of Illinois as we work to become a mission-driven, high-impact, Illinois Department of Public Health.”
The plan focuses on five strategic priorities: partnership development; data quality, utilization and dissemination; reducing health disparities; regulatory improvement; and branding, marketing and communication. The plan also emphasizes creating a culture of measuring performance, quality improvement and customer service, as well as aligning the Department with the State Health Improvement Plan.
A strategic plan is among the requirements for becoming a nationally accredited health department. Accreditation by the Public Health Accreditation Board signifies that a health department is meeting national standards for ensuring essential public health services are provided in the community. Accreditation increases accountability and credibility to stakeholders, partners and communities, and it better prepares the Department to proactively respond to emerging and reemerging health challenges.
Why ‘nationally accredited’?
One group is not at all pleased with this proposal, as it affects their individual rights, as well as jeopardizing Illinois’ sovereignty. Members of the Dairy Work Group, since February 2013, have been working with the IDPH, who initially stated that they wanted only to reorganize current rules regarding the production and sale of raw milk into one document.
But other members appointed to the IDPH Food Safety Advisory subcommittee’s Dairy Subcommittee - notably the members that either produce and sell raw milk or who purchase the product - have never seen any reason to compromise on rule changes that they say are not necessary.
It’s hard to know exactly what is motivating the Illinois regulators at the IDPH. Grant money from the U.S. Food and Drug Administration is one of the reasons, hence, the “national accreditation.” Are they trying to secure additional FDA funding? Are they attempting to pat the backs of certain state and federal legislators receiving Big Dairy money?
In May 2013, the Illinois Food Safety Advisory Committee of the IDPH conducted its fourth Dairy Work Group Meeting. It was at that meeting where the Food Safety Modernization Act was explained by Larry Trandel, a Regional Milk Specialist with the FDA. The Act is legislated by Congress and “directs FDA to further enhance their program to supply a safe food supply to our nation.”
But members of the DWG that are Raw Milk producers and consumers challenged FDA involvement, stating this was a “state’s rights issue,” and wondered why the FDA was advising the state of Illinois in the first place.
Interstate commerce involving raw milk was the reason given for the FDA’s advisory role, but If the federal government has banned the sale of raw milk across state lines, then how can the federal government fund a state agency, to discuss how to regulate raw milk? Many see the apparent conflict of interest, wondering why the federal government is working with the state on an issue that they specifically said they do not want to be a part of by banning interstate sale of raw milk and raw milk products.
Because of this stance by a federal, unelected agency, the IDPH (a state of Illinois unelected agency) has accepted federal funds in order to “protect the public.” But it is clear that the federal Food Safety Modernization Act, which Trandel states is legislated by Congress and directs FDA to further enhance their program to supply a safe food supply to the United States, is the reason why IDPH has accepted a grant from FDA - for the money.
Rules not needed
In the meantime, “We have been fired,” said Donna O’Shaughnessy, who operates South Pork Ranch LLC in Chatsworth, IL. “[IDPH’s Molly Lamb] is moving ahead as we always knew she might, deciding herself the discussion is over. The group has ended.”
On November 21, Molly Lamb, Division Chief, Food Safety Advisory Committee of the IDPH, told the members of the Dairy Work Group, who had been meeting since February 2013, to submit their final ideas to her by Tuesday, Dec. 2.
“I have compiled my comments related to the draft summary of comprehensive recommendations, which will then serve as a framework to draft the rule-making for raw milk sales in Illinois,” O’Shaughnessy said. “None of my comments are new and were stated many times at several of the past Dairy Work Group Meetings.”
O’Shaughnessy said that looking at the proposed rules, there are definitely some minor wins - two tiers, voluntary registration (with an annual inspection), no limits on sales, and annual testing (which is better than monthly, as initially proposed).
“But the extensive requirements under Tier 1 as a whole is not what we wanted or needed in Illinois!” O’Shaughnessy submitted the following recommendations, urging Lamb to “take the time to read and seriously consider each of my concerns.”
Here are O’Shaughnessy’s points of consideration:
1. Since 1999 there has not been a single outbreak in which it was verified that the illness was caused by an Illinois Raw Milk Producer. (This statistic comes from Ted Beals, MS, MD, a physician and board certified pathologist, who served on the faculty of University of Michigan Medical School. He is now retired after 31 years of clinical and administrative service in the Veterans Health Administration. A pathologist with personal interest in dairy testing and safety of milk, he has been presenting testimony on dairy safety in North America for the last several years). The CDC itself reports from 1998 through 2011, there were 148 outbreaks due to consumption of raw milk or raw milk products that were reported to them. This means approximately 11 outbreaks per year in all 50 states combined. The Dairy Work Group only briefly evaluated Raw Milk related illnesses in Illinois, but statistics have proven the numbers to be very low.
2. For over 30 years small farmers in Illinois have been safely and successfully producing and selling raw milk under the “policies” of the Illinois Department of Public Health, in the absence of any enforceable rules, thus begging the question, why are extensive, costly and difficult to enforce rules being drafted now?
3. If these proposed rules are passed as currently written, many small farmers will be forced out of business and the barn doors of a thriving “meet your farmer, buy local” rural trade will close forever. Meeting the Grade A requirements alone will cost farmers who have never been permitted before, thousands and thousands of dollars which cannot be easily recouped with just a few cows producing raw milk for sale.
4. In addition, the small farmers who decide to stay in business will feel forced to produce “underground,” and less ethical producers will thrive recognizing the income which can be made illegally. Prohibition in the 1920’s was a huge government-controlled failure. Raw milk will not disappear but will instead flow rapidly across state lines from possibly unscrupulous dealers in the back of trucks and cars, the sellers concerned more with making cash than with the distribution of a healthy, wholesome, natural product.
5. Finally, the Dairy Work Group was disbanded and told their services were not needed BEFORE there was any discussion by the farmers and consumers regarding what Level 2 might look like. We felt strongly agreement had to be in place under Level 1 before proceeding to Level 2. That request was ignored.
With Lamb’s deadline for the DWG, it is clear that there is a desire for the IDPH to have the strategic plan pushed through for a Spring 2014 target approval date, in order to gain FDA funds. After December 2, the Chair will then provide the final version to the Chair of the Food Safety Advisory Committee for distribution to the membership for review, input and approval on December 3, 2013. The Chair will then take forward to the Department the final, endorsed version. The Department will draft the rule-making based on the framework and recommendations from the summary report put forth. The target timeline is for the Department to take the rule-making to the State Board of Health in March 2014.
When will the Illinois House and Senate get a chance to approve these regulations, submitted by an un-elected board?
For a copy of the plan and to learn more about how it was created, go to http://www.idph.state.il.us/about/StrategicPlan_Final_2014-2018.pdf.