rBGH

How Artificial Hormones

Damage the Dairy Industry
and Endanger Public Health
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 rBGH 101
How Artificial Hormones Damage the Dairy Industry
and Endanger Public Health
Introduction...................................................................................................................................................................1

Behind FDA approval of rBGH..................................................................................................................................................2

FDA ignores and denies possible health impacts..........................................................................................................2

Conflicts of interest?.....................................................................................................................................................3

What the Science Tells Us Now: Post-Approval Studies of rBGH...........................................................................................4

Animal welfare..............................................................................................................................................................4

Antibiotic resistance......................................................................................................................................................5

Hormonal effects in humans........................................................................................................................................5

Harming human reproduction?....................................................................................................................................5

Why rBGH? Growth Hormones and the Push to “Get Big or Get Out”.....................................................................................6

Labeling......................................................................................................................................................................................7

rBGH Has a New Owner.............................................................................................................................................................8

Community Responses to rBGH................................................................................................................................................10

Take Action................................................................................................................................................................................11

Endnotes..........................................................................................................................................................12
Injecting otherwise healthy cows
with genetically engineered growth
hormones is, in my view, unnatural,
unnecessary and unfair to dairy
cows. … Consumers should be able
to decide for themselves whether or
not they buy milk from rBGH-treated
cows. We believe if they had the
information to make the choice, they
will not.
– A representative of Ben and Jerry’s
Homemade, Inc., on filing a lawsuit in 1996
to label their products rBGH-free
Introduction

R ecombinant bovine growth hormone (rBGH), also called recombinant bovine

somatotropin (rBST), is a drug that is injected into cows to increase their milk
production. Developed by the agricultural company Monsanto and approved for com-
mercial use in the United States by the Food and Drug Administration (FDA) in 1993,
by 2000 it had become the largest selling pharmaceutical product in the history of the
dairy industry.1 RBGH has never been approved for commercial use in Canada or the
European Union due to concerns about the drug’s impact on animal health.2 The artifi-
cial hormone’s known side effects include increased udder infections and reproductive
problems in cows. Notably, a growing body of scientific research also suggests a link
between drinking rBGH-treated milk and certain types of cancer in humans.

Consumer pressure on dairy companies to abandon the
use of this controversial drug has resulted in an increas-
ing number of companies moving to rBGH-free milk and
making sure that consumers know they’ve made the change
by labeling their products as such. But across the country,
legislators and state regulators are responding to industry
pressure by trying to ban rBGH-free labels on dairy prod-
ucts. After years of successful campaigns that educated
dairy consumers about the risks of rBGH, banned rBGH
milk in some school districts, and pressured major national
companies to go rBGH-free, we are at risk of losing the
right to know how our milk was produced.
This report will begin with a background on the science,
regulation and politics of rBGH, new risks identified by
scientific research, the influence of Monsanto, and informa-
tion on drug giant Eli Lilly, the new owner of rBGH. We’ll
tell the stories of successful community, state, and national
campaigns to kick the dairy industry off the rBGH wagon.
And we’ll finish up with suggestions for action that will help
readers become advocates for improving the health and
safety of the dairy supply.
 rBGH: How Artificial Hormones Damage the
Dairy Industry and Endanger Public Health

Behind FDA Approval of rBGH

FDA approved rBGH for commercial use on November
5, 1993, despite lingering controversy over the safety and
health impacts of the drug. RBGH was the first genetically
engineered organism that FDA had ever approved.3 The
integrity of the rBGH approval process has been the subject
of considerable investigation and concern due to fears that
the agency ignored possible health risks of the synthetic
hormone as well as potential conflicts of interest with sev-
eral FDA employees who had ties to Monsanto.

FDA ignores and denies possible health

impacts of rBGH
Monsanto submitted preliminary materials on rBGH to
FDA in 1981 and followed with an official application in
1987.4 The FDA first stated that rBGH posed no human
health risks in 19855 and completed the official human
health study in 1989.6 Before approving rBGH for com-
mercial sale and use in 1993, FDA approved the drug “for
research only” but allowed milk from rBGH-treated cows
to be sold and consumed during the commercial investiga-
tion.7 Monsanto was not the only company to petition FDA
for approval of its rBGH drug — competitors at the time
included Eli Lilly, American Cyanamid and Upjohn — but
FDA only approved Monsanto’s “Posilac” brand.8
Outside observers first expressed concern that FDA was
ignoring the negative animal health impacts of the artificial
hormone early on in the approval process.9 Central to their
concern were studies suggesting that rBGH use increased
the frequency of mastitis, an infection of the cow’s udder
that requires treatment with antibiotics. These conclusions
were initially downplayed by Monsanto,10 and FDA denied
them as late as 1993, when Gerald Guest, Director of FDA’s
Center for Veterinary Medicine and the person who had the
final say on rBGH’s approval,11 testified in a hearing that
rBGH did not increase the severity or duration of mastitis
in cows.12
FDA also took a cursory look at the human health impacts of
drinking milk produced with rBGH. FDA initially concluded
that the drug was safe for humans based on rat studies
submitted by each of the four sponsor companies, as well
as experiments conducted in the 1950s, in which rBGH did
not produce any growth when injected into children with
dwarfism.13 FDA only began to look at secondary health is-
sues caused by a related hormone called IGF-1 in 1988, after
the agency learned that human and bovine versions of the
growth hormone were identical (see “Hormonal effects in
humans” on page 5).14 However, according to the Inspector
General audit of the rBGH review, the FDA relied on infor-
mation provided by the sponsor companies when it deter-
mined that exposure to increased levels of IGF-1 was safe.15
One scientist at FDA who did speak up and question the
approval process of rBGH was subsequently fired. Richard
Burroughs was a veterinarian at FDA and worked on the
review of rBGH from 1985 until 1988, when he was termi-
nated, allegedly for incompetence.16 Soon after his termina-
tion, Burroughs became a vocal public critic of FDA’s review
of rBGH, and stated that he was fired after a dispute with
his superior about how to interpret the sponsor companies’
studies.17 Burroughs alleged that FDA was working too
closely with industry, Monsanto was manipulating data that
it submitted, and FDA was ignoring safety problems with
the drug.18 In 1991, the Federal Merit Systems Protection
Board found that Burroughs was improperly terminated be-
cause the agency had not followed the formal rules in firing
him, and it subsequently ordered FDA to reinstate him.19
Burroughs’ allegations were serious enough that at the
prompting of Congress, the General Accounting Office
(GAO, now the Government Accountability Office) conduct-
ed an in-depth investigation into FDA’s review of the rBGH
application.20 The GAO recommended that FDA’s approval
be delayed until further studies could be performed on the
drug’s health effects, particularly regarding the indirect
effects of mastitis in treated cows.21 The GAO was already
concerned about the levels of animal antibiotics that were
making their way into humans through milk consump-
tion,22 and the increased levels of antibiotics that would be

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 Food & Water Watch
used to treat mastitis could potentially lead to even greater
levels of antibiotic residue in milk.23 The FDA, however,
disagreed and reaffirmed its initial conclusion that the arti-
ficial hormone was safe.24
Unfortunately, consumer, farm and animal welfare groups
could not directly critique the studies submitted to FDA
by the four companies and reviewed by the GAO. In FDA
drug approvals, company studies are generally considered
proprietary business information and are therefore confi-
dential. It is therefore impossible for the public to know
which studies and what data FDA bases its decisions on
until after the decision is made, and even then, the specific
data generally remain confidential. While the GAO report
criticizing FDA’s approval process had access to the FDA
studies, it could not present the specific data to the public
in order to back up its assertion that there were indirect hu-
man health impacts from increased mastitis in cows treated
with rBGH.25
Conflicts of interest?
FDA’s analysis of the human health impact of rBGH was
not the only cause for alarm during the review process.
Three FDA employees working on the synthetic hormone
application appeared to have such close ties with rBGH
manufacturer Monsanto that at the request of Represen-
tatives George Brown from California, David Obey from
Wisconsin and Bernie Sanders from Vermont, the GAO
investigated them for conflicts of interest.26
Michael Taylor, the first target of the GAO probe, started
his career in 1976 as an attorney with FDA before leaving
in 1981 to join the law firm of King & Spalding.27 While at
King & Spalding, one of Taylor’s clients was Monsanto,28
and Taylor drafted a memo for Monsanto on whether it
would be constitutional for states to adopt different rules
regarding the labeling of rBGH.29 Taylor left King & Spald-
ing in 1991 to join FDA as the Deputy Commissioner of
Policy,30 where he helped draft FDA’s guidance on labeling
of rBGH31 that helped prevent dairies from labeling their
products “rBGH free” (see “Labeling” on page 7).32
Despite the fact the Taylor worked on rBGH labeling is-
sues at Monsanto and again at the FDA, the GAO did not
consider this to be a conflict of interest. Since the GAO
felt that the guidance was not a “binding agency decision,”
it was thus not covered by the impartiality standards and
therefore completely excluded from GAO analysis.33 Taylor,
who was also responsible for FDA’s earlier guidance stating
that there was no need to label genetically modified foods,34
eventually left government service in 199835 for a position
as vice president for public policy at Monsanto.36
The GAO also investigated Margaret Miller, a former em-
ployee of Monsanto. While at Monsanto, she was respon-
sible for putting together animal safety studies on rBGH.37
She left Monsanto in 1989 and immediately went to work
for FDA. 38 In 1991 she was promoted to director of the divi-
sion of toxicology and environmental sciences, the division
that was directly involved in the technical review of rBGH,39
and she later became chief of a branch that was responsible
for reviewing the human health impacts of rBGH. 40 Ac-
cording to the GAO, she did not technically violate any con-
flict of interest rules, despite the fact that she did perform
some work related to rBGH.41
The third FDA employee that the GAO investigated was Dr.
Suzanne Sechen, who worked on Monsanto-funded rBGH
studies while in graduate school at Cornell before leaving
in 1988 to join FDA as an animal scientist and the primary
reviewer of rBGH.42 Sechen’s faculty advisor at Cornell per-
formed consulting for Monsanto, and the research Sechen
performed was conducted pursuant to an agreement be-
3
 rBGH: How Artificial Hormones Damage the
Dairy Industry and Endanger Public Health

What the Science Tells Us Now:

Post-Approval Studies on rBGH
Since FDA’s approval of rBGH in 1993, additional research
has raised further questions about the wisdom of the
agency’s decision. The animal welfare problems found in
pre-approval studies remain a major concern. The scien-
tific community also understands more now about impacts
“beyond the barn” — how treating dairy cows with a syn-
thetic growth hormone might impact human health. Some
studies suggest that rBGH use puts human health directly
at risk by altering hormone levels in the humans that con-
sume the cows’ milk, and that it indirectly impacts human
health by driving the emergence and spread of antibiotic-
resistant strains of bacteria.

Animal welfare
Following the uproar over its decision to approve Posilac
for commercial use, FDA required Monsanto to label its
product with a disclaimer listing the many effects that Posi-
lac may have on cows. These include reproductive impacts
— lower birth rates and birth weights of calves – as well as
physical ailments such as mastitis and hoof and leg prob-
lems.47 A total of 16 different animal health impacts were
listed on the Posilac package insert.48

In the years following rBGH’s approval, additional studies

have backed up these findings. The Canadian Veterinary
Medical Association convened an expert panel in 1998 to
review the science on rBGH and found a number of impacts
on cows’ reproductive performance. The use of rBGH sub-
stantially increased the risk that cows would not be able to
conceive, but some evidence suggested that it also increased
tween her advisor and Monsanto.43 Monsanto also provided
the chance that a cow would bear twins or triplets. There
support for several rBGH studies to be performed at Cornell,
was also evidence of increased risk of cystic ovaries.49 A
and some of these were submitted with the rBGH applica-
1999 study published by the European Commission’s Sci-
tion as pivotal studies.44 During Sechen’s time at FDA, she
entific Committee on Animal Health and Animal Welfare
performed a considerable amount of work on rBGH, includ-
found that pregnancy rates in rBGH-treated cows fell by
ing publishing articles on the drug in outside journals based
between 7 percent and 27 percent compared to cows not
on her former research, and then evaluating several of those
treated with the synthetic hormone.50
same articles in her official capacity as a reviewer of the
artificial hormone application.45 Yet the GAO found that she
The Canadian veterinary experts found that as a conse-
did not have a conflict of interest since Monsanto had never
quence of these and other health impacts of rBGH, includ-
employed her or directly given her funding.46
ing evidence that treated cows experienced a 50 percent
increase in the risk of lameness compared to cows that
Despite multiple ties between FDA and Monsanto, the GAO
were not treated, rBGH increased the chance that some
failed to address a relevant question in its report: why did
cows would be culled, or pulled from the herd and slaugh-
FDA approve Monsanto’s version of the rBGH drug over the
tered.51 Both Canada and the EU refused to approve the
other three manufacturers? Given that three FDA officials
drug because of outstanding questions related to animal
with former ties to Monsanto were the subjects of the inves-
welfare.52
tigation, the exclusion of this area of inquiry from the GAO
report is curious. Unfortunately, this sheds no light on why
FDA picked Monsanto over the other applicants.

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 Food & Water Watch

Antibiotic resistance
The increased frequency of mastitis, an udder infection, is Recent research shows that
one of the main animal welfare impacts of rBGH use and
is included in the warning label on Posilac.53 In addition when present in the human
to causing the cows pain, mastitis has a secondary ef-
fect: it requires treatment with antibiotics, and increased
body at elevated levels,
antibiotic use in animal agriculture has been linked to the
development of antibiotic-resistant bacteria that can sicken
IGF-1 increases the risk of
humans.54 breast, colon, prostate and
Many of the antibiotics commonly used to treat mastitis other cancers.
in cows are human-use antibiotics, including drugs from
the penicillin and erythromycin classes.55 When rBGH
increases the frequency of mastitis in dairy cows, producers
dairy cows are treated with rBGH, their bodies increase
may have to increase their use of antibiotics.56 Antibiotic
production of a protein called insulin-like growth factor-1
use in dairy operations exposes bacteria to the antibiotics,
(IGF-1).66 IGF-1 circulates in cows’ blood and makes its way
contributing to the development of drug-resistant bacte-
into the animal’s milk;67 it appears to survive pasteurization
ria.57 As antibiotic-resistant bacteria spread, they can be
and is consumed by humans when they drink the milk.68
transferred to humans through the water or air,58 by flies,59
or on the meat that humans consume.60 The U.S. Institute
Humans naturally produce their own IGF-1, and they also
of Medicine has identified antibiotic resistance as one of the
consume IGF-1 in the milk of cows not treated with rBGH.
key threats to health in the United States and the federal
However, because rBGH increases the amount of IGF-1 that
Centers for Disease Control and Prevention has identified
cows produce, humans drinking milk from treated cows
resistance as a top concern.61
will consume more IGF-1 than they otherwise would. What
could that mean for human health?
Researchers are also concerned about the potential for
antibiotic residues to show up in the milk of cows being
A lot, as it turns out. The early research used by FDA to re-
treated with the drugs. Antibiotic residues in milk are a
view Posilac suggested that even if humans ingested IGF-1
significant concern when dairy farmers or veterinarians use
from treated cows’ milk, the human digestive process would
antibiotics in ways other than that directed on the label,62
destroy it. But more recent research indicates that most
a practice that the GAO has called “routine.”63 Indeed, the
IGF-1 actually survives digestion. IGF-1 binds to casein, the
FDA’s failure to consider the effect rBGH use might have on
main protein in milk, and may be absorbed into the human
antibiotic residues in milk was one main reason the GAO
bloodstream along with it.69
recommended withholding approval.64
Recent research also shows that when present in the human
It is hard to know what portion of overall antibiotic use
body at elevated levels, IGF-1 increases the risk of breast,
takes place on U.S. farms and ranches because the federal
colon, prostate and other cancers,70 although scientists still
government does not track it, but estimates suggest that as
do not fully understand why. The American Nurses Associ-
much as 70 percent of all antibiotics used for any purpose
ation determined that the risk to human health was serious
in the United States are fed to animals that are not sick,
enough to warrant the passage of a resolution in 2008 call-
used as growth promoters or to keep them from becoming
ing for hospitals and healthcare organizations to eliminate
ill.65 Treatment of cows for mastitis would be in addition to
the purchasing of dairy products from rBGH-treated cows
this number. Anything we can do to reduce the use of anti-
and to educate nurses on the effects of rBGH.71
biotics on animals will help reduce the spread of antibiotic-
resistant bacteria, including ending the use of rBGH in
dairy production. Harming human reproduction?
It is well known that rBGH impacts cows’ reproductive
systems, but new research suggests that IGF-1 may also af-
Hormonal effects in humans fect human reproduction. A 2006 study comparing women
There is little evidence that rBGH itself impacts humans
who consume dairy products to women who do not found
when they drink milk from treated cows, but rBGH does
that the concentration of IGF-1 in the blood of women
appear to put human health at risk by increasing the levels
who consumed dairy was 13 percent higher than in vegan
of other chemicals that are linked to human illness. When
women. It also found that women who ate dairy products

5
 rBGH: How Artificial Hormones Damage the
Dairy Industry and Endanger Public Health

were five times more likely than vegan women to have had
twins.72 The author of the study, Dr. Gary Steinman, noted
that throughout the 1990s, the rate of human twinning
increased beyond what the scientific community expected.
“The continuing increase in the twinning rate ... [may] be a
consequence of the introduction of growth-hormone treat-
ment of cows to enhance their milk and beef production,”
he speculated.73

Why rBGH? Growth Hormones and

the Push to “Get Big or Get Out”
RBGH didn’t become popular simply because dairy farm-
ers felt like trying something new. Despite all of the health
problems that result for cows treated with rBGH, the arti-
ficial hormone does generally increase the amount of milk
that cows produce, typically by 11-15.6 percent.74 Dairy
producers have been under tremendous pressure to “get big
or get out” — in other words, to scale up their production or
exit the industry — and rBGH was aggressively marketed to
them as a scaling-up tool.

To fully understand why farmers moved to rBGH, it’s help-
ful to look at general trends that have shaped the dairy in-
dustry over the last 25 years. During this period, the num-
ber of dairies in operation in the United States fell sharply.
In 1993, the year that rBGH first came on the market, the
United States was home to 157,000 dairies. Today we have
just over 71,000, a decline of 55 percent.75 The number of
dairy cows has fallen less rapidly during this time, from 9.5
million to 9.1 million head, a testament to the fact that re-
maining dairies are much larger on average than they were
in the early 1990s. Back then, a typical large dairy housed
500 cows; today, several thousand is the norm.76
Despite the falling number of dairies and cows, the amount
of milk produced in the United States has increased since
1993, from 150 million gallons to 170 million.77 Not all of
that increase can be attributed to rBGH, but some pre-
sumably can, given the role it plays in boosting cows’ milk
production. In 2007, nearly 43 percent of large-scale dair-
ies (over 500 head), 30 percent of mid-sized dairies, and 9
percent of small dairies used rBGH on their cows.78

Change in U.S. Milk Prices and Production, Dairy producers have been under pressure to increase their
1970-2006 production because dairy prices have been quite volatile
since the early 1980s, at times dropping so low that pro-
ducers are unable to cover their production costs.79 Dur-
ing periods of low prices, dairy farmers tend not to reduce
their production; after all, they cannot simply turn off their
cows, and selling off such an expensive investment is not
something farmers do lightly. Instead, they try to maximize
production in order to spread their costs across as much
output as possible.

That may sound confusing at first, but try applying the con-
cept to a different scenario. Say that you own a copy store
and the going rate for copies falls from 25 cents to 20 cents
per copy. Your first response won’t be to immediately sell
off all of your copy machines; instead, to avoid losing cus-
tomers, you’ll accept the lower price. At the same time, you
still have all those copy machines to pay off, so you’ll try

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 Food & Water Watch

to increase the number of copies that you sell each day in
order to make up for the price decline. In other words, you
will increase the number of units sold to make up for the
lower price you receive for each unit. This is the same situ-
ation in which dairy producers find themselves when prices
fall, and they tend to respond the same way – by increasing
the volume of milk they sell to make up for the lower price
(see graph above). And in the mid-1990s, when producers
heard about Posilac, some saw the drug as a way to do that.
Unfortunately, rBGH was no panacea. When they begin
using it, dairy producers take on the added cost of buying
the drug and treating their cows for the diseases associ-
ated with it, including mastitis, reproductive problems, and
lameness. Meanwhile, actions by commodity speculators
impacted the complicated formulas used to set milk prices,
80
and the prices that farmers received fell ever lower. 81
Today, for every dollar that consumers spend on milk, dairy
farmers receive only $0.27 — 25 percent less than they
received in 1993.82
Labeling
When it approved rBGH, FDA found that since it could find
no distinguishable difference between the milk that comes
from cows treated with rBGH versus those that were not,
it could not require any label on milk that was produced
using the synthetic growth hormone.83 Given the amount of
controversy surrounding rBGH, this decision was surpris-
ing, and dairies that weren’t using the artificial hormone
quickly began labeling their products as such. However,
FDA went even further by making any attempts at label-
ing the absence of rBGH extremely difficult. According to
FDA guidance on rBGH labeling that was signed by Michael
Taylor in 1994, the simple phrase “rBGH free” was mislead-
ing, and a lengthy qualifying sentence stating FDA’s conclu-
sions should be included on any rBGH related label.84 The
disclaimer must state, “No significant difference has been
shown between milk derived from rbST-treated and non-
rbST-treated cows.”85
labels to appear on milk, claiming that the practice was
damaging its business.89
Ben & Jerry’s was one company that made an immediate
and significant push to label its products as free of rBGH.
The Vermont-based ice cream manufacturer first included
an rBGH-free label on its ice cream in February 1994,90 and
aggressively defended that decision by continually modify-
ing its label to in order to withstand challenges91 as well as
suing the state of Illinois in order to protect its right to label
its products.92 Illinois was one of the first states to ban any
labeling of an absence of rBGH, and this essentially made
it impossible for Ben & Jerry’s to market their products
nationwide as not produced with rBGH.93 A serious side
effect of state labeling requirements is that dairy compa-
nies can find it next to impossible to make one label that
can be used in every state. This effectively prevents dairy
manufacturers and milk retailers from truthfully labeling
their products as rBGH free since it is significantly easier to
have no label than to make a different label for each state.94
The company’s settlement with the state of Illinois in 1997
enabled Ben & Jerry’s and other companies to market and
label their products nationwide as not produced with rBGH.
As a result of the settlement, Ben & Jerry’s products include
the disclaimer, “the FDA has said no significant difference
has been shown and no test can now distinguish between
milk from rBGH treated and untreated cows.”95

Just days after FDA released the document, Monsanto filed

suit against two dairy farms that had labeled their milk
“rBGH-free.”86 King & Spalding, Taylor’s former law firm,
also sent a number of letters to dairy farmers on behalf of
Monsanto, using the guidelines Taylor helped draft at FDA
to show that the farmers were out of compliance with FDA
regulations.87 FDA also got involved and sent warning let-
ters to several dairies that had labeled their milk “hormone
free,” stating that they were violating the Food Drug and
Cosmetic act for misbranding.88 Monsanto even com-
plained to FDA and the FTC for allowing any rBGH related

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 rBGH: How Artificial Hormones Damage the
Dairy Industry and Endanger Public Health
In 2007 and 2008 a number of states, at the urging of
groups backed by Monsanto,96 made significant moves to
restrict the type of rBGH free labeling that could appear on
dairy products. AFACT, a pro-rBGH organization that was
created during this time and founded in part by Monsanto,
lobbied for the passage of labeling rules in many of these
states.97 Some states, such as Utah,98 had proposals that
were modeled after FDA guidelines, while others, includ-
ing Ohio, made more specific requirements in terms of the
type, size, and location of FDA’s disclaimer.99 Missouri and
Pennsylvania went even further and attempted to ban any
mention of an absence of rBGH.100 In Pennsylvania, the agri-
cultural secretary attempted to create an outright ban on any
rBGH labeling, but this was reversed due to consumer back-
lash and reduced to a rule that was similar to the original
FDA proposal.101 Missouri’s proposal was met with a similar
reaction, and due to consumer protest the original bill had to
be modified102 before eventually dying in committee.103
With state legislatures and agriculture departments around
the country continuing to grapple with this issue, the fight
over labeling rBGH is not over. However, industry support
for these bills may begin to change now that Monsanto has
sold all of its rBGH operations to Elanco, a division of the
drug manufacturer Eli Lilly.104
rBGH Has a New Owner
In August 2008, pharmaceutical giant Eli Lilly announced
that it was acquiring Monsanto’s rBGH operations for $300
million.105 Posilac (Monsanto’s brand name for rBGH) and
its supporting operations became part of Eli Lilly’s Elanco
division, which handles animal health and nutrition.106
Elanco was already the exclusive international seller of
Posilac in the decade preceding the acquisition.107 Among
other things, Elanco sells antibiotics that are used to treat
mastitis in dairy cows. 108
Eli Lilly is the pharmaceutical company responsible for Pro-
zac and other psychiatric drugs, as well as the Viagra com-
petitor Cialis and a number of other medications used to
treat various conditions, including cancer.109 Lilly reported
$18.6 billion in revenue and almost $3 billion in profit in
2007, significantly more than Monsanto’s $11.3 billion in
revenue and $2 billion in profit that fiscal year.110
It is easy to understand why Monsanto would sell its rBGH
business. The synthetic hormone is banned for commercial
sale in Canada and the European Union,111 national retail-
ers and food companies like Kroger and Starbucks refuse to
use milk that was produced with rBGH112 and Dean Foods,
the largest milk distributer in the United States,113 states
that virtually all of its milk is sourced from cows not treated
8
with the artificial hormone.114 Both Yoplait and Dannon
also announced they would be dropping rBGH from their
products.115 Even Wal-Mart now uses rBGH-free sources
for its private label milk.116 In fact, Monsanto’s stock went
up 4.63 percent on the day that it became news that it was
eliminating rBGH from its portfolio. It was not immedi-
ately clear why Eli Lilly decided to acquire the rBGH opera-
tions at this point in time, and in fact, Lilly’s stock declined
that same day.117
In its quarterly conference call following the acquisition, Lil-
ly touted the decision as part of a strategy to build its global
business.118 The company did not elaborate further, but
given the supposed benefits of the product and the current
push to expand animal agriculture around the world, it is
possible that Lilly will market rBGH to developing countries
as a tool for increasing domestic milk production. RBGH is
currently approved for use in twenty countries,119 including
the United States, South Africa, Brazil, Columbia, Hondu-
ras, Kenya and Mexico.120 Whether Eli Lilly will be promot-
ing this product ethically, however, remains to be seen, as
Eli Lilly has been involved in a number of controversies over
its questionable business and marketing practices.
On January 15, 2009, Lilly agreed to settle an “off-label”
promotion case with the U.S. Justice Department for a re-
cord-setting $1.42 billion.121 Off-label refers to the process
of using drugs for purposes that have not been approved by
FDA.122 While doctors have discretion to prescribe medica-
tions for non-approved purposes, it is illegal for drug com-
panies to promote and market the drugs for these uses.123
This was the largest sum for both a corporate whistleblower
claim as well as the largest criminal fine ever imposed by
the U.S. upon a single company.124 Lilly was facing criminal
and civil charges for violating the Food, Drug and Cosmetic
Act and was accused of engaging in a multi-year scheme to
persuade doctors to prescribe its anti-psychotic drug Zy-
prexa for use in two groups of patients for whom the drug
was particularly risky and not approved, children and the
elderly. 125 As part of the settlement, Lilly agreed to plead
guilty to one misdemeanor charge of illegally marketing the
drug for use in treating the elderly for various symptoms of
dementia.126 The company paid a $615 million penalty for
the criminal charges and also paid $800 million to stop the
civil investigation from proceeding further.127 In addition,
Lilly agreed to be monitored for five years by a federal re-
view organization that will assess and report on the com-
pany’s practices, policies, and procedures.128
Lilly had already settled claims for improperly marketing
Zyprexa prior to this latest agreement. In October of 2008,
Lilly paid out $62 million to 33 states for improperly mar-
keting the drug,129 this time setting a record for the largest
 Food & Water Watch
sum in a state consumer protection claim.130 The company
was accused of the same illegal behavior, which was pro-
moting the drug for uses that were not approved by FDA
and urging doctors to prescribe it for those uses.131
In addition, in 2005 Lilly pled guilty to similar charges of il-
legal off-label promotion of its drug Evista. Evista was only
approved for the prevention and treatment of osteoporosis
in post-menopausal women. However, Lilly was allegedly
promoting the drug as reducing the risk of cardiovascular
disease and breast cancer, a use that FDA had specifically
rejected. 132 Lilly agreed to pay a $36 million to settle the
Evista case with the U.S. government.133
Lilly also happens to market another drug, Gemzar, which
is approved by FDA for treating metastatic breast cancer.134
It needs to be questioned whether Lilly knows that cows
injected with rBGH show elevated levels of the hormone
IGF-1 in their milk, and that this hormone has been linked
to increased rates of breast cancer in humans.135
In addition to its illegal off-label marketing campaigns,
Eli Lilly has also engaged in other questionable forms
of drug promotion. In 2006, an article appearing in the
peer-reviewed New England Journal of Medicine criticized
Lilly’s marketing tactics for the drug Xigris, which is used
to treat sepsis, otherwise known as blood poisoning. The
FDA approved the drug in 2001, although not without some
controversy. The approval was based on a single problem-
atic trial of the drug, and half of FDA advisory panel voted
to require another confirmation trial before approval.136
When initial Xigris sales were lower than expected, Lilly
hired a public relations firm to help boost sales of the drug.
137
During the period that this PR campaign was taking
place, issues continued to arise over the safety and effec-
tiveness of the drug, with increasing calls for further testing
of the product.138 While not accusing Lilly of illegal activity,
the NEJM article did shed light on what it considered to be
particularly unethical marketing strategies;139 as a result
of Lilly’s actions, the NEJM article called for a system of
creating drug-use guidelines that prohibit pharmaceutical
companies from funding or influencing these guidelines.140
Lilly has repeatedly engaged in illegal and unethical mar-
keting of its drugs to doctors and has paid millions of
dollars in fines and settlements for doing so. The company
9
 rBGH: How Artificial Hormones Damage the
Dairy Industry and Endanger Public Health

has also used marketing and promotion to increase the

sale of drugs suspected of having ill effects. The money
lost settling lawsuits does not seem to have deterred Lilly
from continuing its behavior; the company appears to have
accepted the fines as just another cost of doing business. It
would seem then that Eli Lilly is an excellent choice to take
over the reins of a such a controversial product as rBGH,
as the company has demonstrated a willingness to engage
in illegal marketing to sell its products and may very well
continue to use unethical tactics to sell rBGH to unsuspect-
ing people around the world.

Community Responses to rBGH

The road to a healthier, more humane dairy production
system starts with the removal of rBGH from our dairy sup-
ply. A 2008 poll showed that more than 90 percent of U.S.
consumers want the right to choose rBGH-free products
and want them to be labeled.141 RBGH use is falling among
U.S. dairies, too: the most recent USDA survey of U.S. dairy
production estimated that rBGH was used on 17.2 percent
of cows, compared to 22.3 percent five years earlier.142 It is
still fairly common among industrial dairies, though; 42.7
percent of large-scale industrial dairies used it in 2007,
compared to 9 percent of small operations and 29 percent
of midsized dairies.143
Milk consumers around the country have already made
huge headway by urging food companies to go rBGH-
free. Thanks to their pressure, major companies including
Kroger,144 Wal-Mart,145 Hood,146 Dannon,147 Yoplait148 and
others have phased out the use of rBGH milk in some or all
of their dairy products.
A 2008 poll showed that
more than 90 percent of
U.S. consumers want the
right to choose rBGH-free
products and want them to
be labeled.
A schoolgirl in Philadelphia voices her support for rBGH-free
school milk during Food & Water Watch’s “Know Your Milk Day” in
March 2009.
If so many companies are no longer accepting rBGH milk,
where is the remaining milk going? One possibility is that
it is being funneled to U.S. schoolchildren through school
food programs, which require that milk be offered with
every school lunch. Schools have therefore become another
area where pressure from consumers — in this case parents,
teachers, and school board members — has turned the tide
against rBGH use. Following the release of rBGH on the
market and consumer outcry over it, National Geographic
Society’s Green Guide reported in 1997 that “numerous
parent and teacher associations have passed rBGH-free
resolutions, and over 100 school systems across the coun-
try buy only rBGH-free milk.”149 The school board of River
Valley, Wisconsin was one of the early participants in the
campaign and in the early 1990s passed a resolution asking
that the district not purchase milk from suppliers who have
knowingly accepted milk from farmers using rBGH. Board
member and dairy farmer Randy Smith, who introduced
the resolution, was quoted in papers saying, “I’ve got a lot of
parents in the district that have told me that they don’t want
their children to drink rBGH milk. As a dairy farmer, I don’t
want to see a decline in consumption because of rBGH.”
The resolution passed the school board five to one.150
Unfortunately, many school districts continue to source
milk that is not rBGH free. They do so either because they
are not aware that they have the option to choose rBGH-
free milk or because they fear it would be too expensive;
the school lunch program is notoriously underfunded, with
most public schools making do with federal funding equiva-
lent to $2.57 per child per meal.151

10
 Food & Water Watch
Take Action
You can help get rBGH out of our schools and the dairy
supply by taking action in your community:
Help make your school district rBGH-free. Some
school districts have successfully built rBGH-free milk into
their school wellness policies,152 (in 2004, all districts were
required to draft a wellness policy that addressed physi-
cal activity, nutrition, and other issues) and others have
required the dairy companies that contract with them to
supply rBGH-free milk. You can prepare a presentation
for parent groups or your local school board about the
problems with rBGH and ask the school board to adopt
an rBGH-free policy. For more resources on how to make
your district rBGH-free, see Food & Water Watch’s School
Milk Campaign, www.foodandwaterwatch.org/food/
school-milk.
Preserve your right to know. Bills have been intro-
duced in several states that would prohibit farmers and
dairy processors from labeling their milk as rBGH-free.
These bills could keep the market for rBGH milk alive by
pulling the wool over consumers’ eyes. Check to see if a
labeling bill has been introduced in your state and organize
letter-writing and call-in campaigns to your state legisla-
tors. Let them know that they should preserve consumers’
right to information about their food and preserve rBGH-
free labeling!
In 2006, Food & Water Watch “dairy cows” engaged consumers
in Washington, D.C., and elsewhere to ask Starbucks to switch
to rBGH-free milk. After hearing the response from their patrons,
Starbucks eliminated all rBGH milk from its stores less than two
months later. Photo by Brendan Hoffman.
With labeling under
attack, it’s more important
than ever to send a
clear message to dairy
companies that consumers
want rBGH-free milk
and will choose it if it is
properly labeled.
Tell dairy providers and restaurants to go rBGH
free. Past consumer campaigns have successfully turned
the tide against rBGH use — but there is still much to be
done. With labeling under attack, it’s more important
than ever to send a clear message to dairy companies that
consumers want rBGH-free milk and will choose it if it is
properly labeled. If the dairy products you buy are not
labeled rBGH free, then call the dairy company, ask them
if their suppliers use the drug, and tell them that you are
switching to an rBGH-free brand unless they commit to
prohibiting its use. If the company claims their products
are already rBGH-free, tell them to label their products so
that consumers can make the right choice. For information
on dairy products that are already produced without rBGH
go to: http://www.foodandwaterwatch.org/take-action/
consumer-tools/milk-tip/rbgh-free-guide.
Ask FDA to revoke its approval of rBGH. The
research that has been done since FDA approved rBGH
in 1993 has raised enough concerns that Canada and the
European Union refused to approve the drug in 1998 and
1999.153 The FDA’s approval process was nontransparent
and relied heavily on confidential industry-funded studies.
While we still have much to learn about how rBGH impacts
human health, the evidence is clear enough: We should not
be risking public health by continuing to allow rBGH use.
The FDA should revoke rBGH approval and appoint an
unbiased panel of scientists to carry out a thorough, public
review of existing research. Tell your members of Congress
that you are concerned about rBGH in the dairy supply.
They should bring attention to the issue through hearings
and should follow the lead of Canada and the EU by in-
structing FDA to revoke its approval of rBGH.
11
 rBGH: How Artificial Hormones Damage the
Dairy Industry and Endanger Public Health
Endnotes
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cvma-rap_acdv_tc-tm-eng.php. November 1998, section 7; Groves,
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Los Angeles Times. January 15, 1999; European Commission,
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3 “Monsanto’s BST barely beat tomato to market.” The Chicago Sun-
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4 U.S. General Accounting Office. “Comments on FDA employees al-
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6 U.S. General Accounting Office. “Comments on FDA employees al-
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7 U.S. General Accounting Office. “Recombinant bovine growth hor-
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27 U.S. General Accounting Office. “Comments on FDA employees al-
leged conflicts of interest in drug approval.” (B-257122). October 19,
1994 at 18.
 Food & Water Watch
28 U.S. General Accounting Office. “Comments on FDA employees al-
leged conflicts of interest in drug approval.” (B-257122). October 19,
1994 at 19.
29 U.S. General Accounting Office. “Comments on FDA employees al-
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44 U.S. General Accounting Office. “Comments on FDA employees al-
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82 US Department of Agriculture, Economic Research Service. “Price
Spreads from Farm to Consumer: At-Home Foods by Price Group
(Dairy).” Available online at http://www.ers.usda.gov/Data/
FarmToConsumer/pricespreads.htm. Accessed August 7, 2008.
83 “Interim guidance on the Voluntary Labeling of Milk and Milk
Products From Cows That Have Not Been Treated With Recombinant
Bovine Somatotropin.” 59 Fed. Reg. 6279, (February 10, 1994).
14
84 “Interim guidance on the Voluntary Labeling of Milk and
Milk Products From Cows That Have Not Been Treated With
Recombinant Bovine Somatotropin.” 59 Fed. Reg. 6279, (February
10, 1994).
85 “Interim guidance on the Voluntary Labeling of Milk and
Milk Products From Cows That Have Not Been Treated With
Recombinant Bovine Somatotropin.” 59 Fed. Reg. 6279, (February
10, 1994).
86 Rosenfeld, Steven P. “Dairy cooperative says it will fight Monsanto
suit.” The Associate Press. February 21, 1994.
87 Puzo, Daniel P. “Conflict of interest alleged in BGH approval.” The
Los Angeles Times. April 21, 1994 at H2.
88 U.S Food and Drug Administration. [Press release]. “FDA Warns
Milk Producers to remove ‘hormone free’ claims from the labeling of
dairy products.” September 12, 2003.
89 Hedges, Stephen J. “Monsanto having a cow in milk label dispute.”
Chicago Tribune. April 15, 2007 at C1.
90 McCarthy, Colman. “Monsanto’s cash cow trips milk alarm.” The
Washington Post. March 1, 1994 at D20.
91 Gilgoff, Henry. “Dairy labels go sour; it’s hard to milk antihormone
sentiment.” New York Newsday. March 24, 1994 at A49.
92 Wu, Olivia. “Dairy companies sue Illinois to allow change in
labels.” Chicago Sun-Times. May 8, 1996 at A14; Berselli, Beth.
“Settlement reached in hormone labeling case; Ben and Jerry’s,
states agree food makers can indicate absence of added product.”
The Washington Post. August 15, 1997 at A22.
93 Berselli, Beth. “Settlement reached in hormone labeling case; Ben
and Jerry’s, states agree food makers can indicate absence of added
product.” The Washington Post. August 15, 1997 at A22.
94 “Ben and Jerry’s, state in accord on growth hormone statement.”
The Chicago Tribune. August 14, 1997 at BU4; Berselli, Beth.
“Settlement reached in hormone labeling case; Ben and Jerry’s,
states agree food makers can indicate absence of added product.”
The Washington Post. August 15, 1997 at A22.
95 Berselli, Beth. “Settlement reached in hormone labeling case; Ben
and Jerry’s, states agree food makers can indicate absence of added
product.” The Washington Post. August 15, 1997 at A22.
96 Melcer, Rachel. “Lawmakers consider bill to restrict labels on milk
containers.” St. Louis Post-Dispatch. April 17, 2008 at B1.
97 Martin, Andrew. “Fighting on a battlefield the size of a milk label.”
The New York Times. March 9, 2008, at BU7.
98 “Utah proposes rules on milk labels.” The Associated Press State &
Local Wire. February 28, 2008.
99 Lewis, Zachary. “State eases label rule for hormone in cows.”
Cleveland Plain Dealer. March 27, 2008 at C1.
100 Melcer, Rachel. “Lawmakers consider bill to restrict labels on milk
containers.” St. Louis Post-Dispatch. April 17, 2008 at B1; Avril,
Tom. “Hormone labeling of Pa. milk to end.” The Philadelphia
Inquirer. December 23, 2007 at A01.
101 Malloy, Daniel. “State reverses on dairy labeling, allows hormone
claims.” Pittsburgh Post-Gazette. January 18, 2008 at A1.
102 Melcer, Rachel. “Lawmakers consider bill to restrict labels on milk
containers.” St. Louis Post-Dispatch. April 17, 2008 at B1.
103 Actions on Missiouri SB 1279. Available at: http://www.senate.
mo.gov/08info/BTS_Web/Actions.aspx?SessionType=R&BillID=15
4026. Accessed 04/01/09.
104 Clapp, Stephen. “Kansas is latest battleground in “rBST-free” label-
ing fight.” Food Chemical News. December 22, 2008 at pg 5; Eli
Lilly. [Press release]. “Elanco Announces Acquisition of Posilac(R)
Dairy Business.” August 29, 2008.
105 Eli Lilly. [Press release]. “Elanco Announces Acquisition of
Posilac(R) Dairy Business.” August 29, 2008.
106 Eli Lilly. [Press release]. “Elanco Announces Acquisition of
Posilac(R) Dairy Business.” August 29, 2008.
107 Eli Lilly. [Press release]. “Elanco Announces Acquisition of
Posilac(R) Dairy Business.” August 29, 2008.
108 Elanco - Veterinary. Elanco Australia. Available at http://www.
elanco.com.au/veterinary/index.html. Accessed 05/05/09.
109 Eli Lilly & Company >> Products. Available at: http://www.lilly.
com/products/. Accessed 05/05/09.
 Food & Water Watch
110 Monsanto. Securities and Exchange Commission. 10-K filing.
October 24, 2008 at 49; Securities and Exchange Commission. 10-K
filing. October 21, 2008 at 18.
111 Yousfi, Jennifer. “Monsanto sells off controversial milk-hormone to
focus on seed product lines.” Money Morning. August 23, 2008.
112 Yousfi, Jennifer. “Monsanto sells off controversial milk-hormone to
focus on seed product lines.” Money Morning. August 23, 2008.
113 Dean Foods. Securities and Exchange Commission. 10-K Filing.
February 24, 2009 at 1.
114 Dean Foods. 2008 Corporate Responsibility Report at 12.
115 General Mills. [Press release]. “General Mills Announces
Commitment to Make Yoplait Yogurt Products 100 Percent Free of
Milk from Cows Treated with rBST by August 2009.” February 2,
2009; Heller, Lorraine. “Dannon removes growth hormone from
dairy products.” Dairyreporter.com. February 23, 2009.
116 Wal-Mart. [Press release]. “Wal-Mart Offers Private Label Milk
Produced without Artificial Growth Hormone.” March 21, 2008.
117 Yousfi, Jennifer. “Monsanto sells off controversial milk-hormone
to focus on seed product lines.” Money Morning. August 23,
2008.
118 Eli Lilly & Co. Q3 FY08 Earnings Call. October 23, 2008.
119 Martin, Andrew and Pollack, Andrew. “Monsanto to sell off hormone
business.” New York Times. Section C1. August 7, 2008.
120 Raine, George. “Got rBST in your milk?; Dairy co-op bows to pres-
sure to stop use of hormone.” San Francisco Chronicle. Pg D1.
March 25, 2008.
121 Harris, Gardner. “Lilly Said to Be Near $1.4 Billion Settlement on
Drug.” New York Times. Jan. 14, 2009.
122 “Eli Lilly fined nearly $1.5B in drug marketing case.” CNNMoney.
com. January 15, 2009.
123 Harris, Gardner. “Lilly Said to Be Near $1.4 Billion Settlement on
Drug.” New York Times. Jan. 14, 2009.
124 Fisk, Margaret Cronin et al. “Lilly to pay biggest fine ever to end
Zyprexa Probe.” Bloomberg News. Jan. 15, 2009.
125 Harris, Gardner. “Lilly Said to Be Near $1.4 Billion Settlement on
Drug.” New York Times. Jan. 14, 2009.
126 Loftus, Peter. “Lilly to pay $1.42 billion to settle Zyprexa charges.”
Dow Jones Newswires. January 15, 2009.
127 Fisk, Margaret Cronin et al. “Lilly to pay biggest fine ever to end
Zyprexa Probe.” Bloomberg News. Jan. 15, 2009.
128 Fisk, Margaret Cronin et al. “Lilly to pay biggest fine ever to end
Zyprexa Probe.” Bloomberg News. Jan. 15, 2009.
129 Berenson, Alex. “33 states to get $62 million in Zyprexa case settle-
ment.” New York Times. Oct. 6, 2008.
130 Berenson, Alex. “33 states to get $62 million in Zyprexa case settle-
ment.” New York Times. Oct. 6, 2008.
131 Berenson, Alex. “33 states to get $62 million in Zyprexa case settle-
ment.” New York Times. Oct. 6, 2008.
132 U.S. Department of Justice. [Press release]. “Eli Lilly and company
to pay U.S. $36 million relating to off-label promotion.” Dec. 21,
2005. Although in 2007, FDA did approve the use of Evista to reduce
the risk of breast cancer in post-menopausal women. See “FDA
Approves New Uses for Evista.” FDA News. September 14, 2007.
133 U.S. Department of Justice. [Press release]. “Eli Lilly and company
to pay U.S. $36 million relating to off-label promotion.” Dec. 21,
2005.
134 Gemzar.com - Home. Available at http://www.gemzar.com.
Accessed 05/05/09.
135 Hansen, Michael, Ph.D, et al. “Potential Public Health Impacts Of
The Use Of Recombinant Bovine Somatotropin In Dairy Production.”
Consumers Union. September 1997.
136 Eichacker, Peter Q., M.D. et al. “Surviving Sepsis — Practice
Guidelines, Marketing Campaigns, and Eli Lilly.” New England
Journal of Medicine, vol.355, iss.16. Oct. 19, 2006 at 1640.
137 Eichacker, Peter Q., M.D. et al. “Surviving Sepsis — Practice
Guidelines, Marketing Campaigns, and Eli Lilly.” New England
Journal of Medicine, vol.355, iss.16. Oct. 19, 2006 at 1640.
138 Eichacker, Peter Q., M.D. et al. “Surviving Sepsis — Practice
Guidelines, Marketing Campaigns, and Eli Lilly.” New England
Journal of Medicine, vol.355, iss.16. Oct. 19, 2006 at 1642.
139 Eichacker, Peter Q., M.D. et al. “Surviving Sepsis — Practice
Guidelines, Marketing Campaigns, and Eli Lilly.” New England
Journal of Medicine, vol.355, iss.16. Oct. 19, 2006 at 1642.
140 Eichacker, Peter Q., M.D. et al. “Surviving Sepsis — Practice
Guidelines, Marketing Campaigns, and Eli Lilly.” New England
Journal of Medicine, vol.355, iss.16. Oct. 19, 2006 at 1642.
141 Consumer Reports National Research Center, 2008, Food Labeling
Poll 2008, November 2008.
142 USDA Animal and Plant Health Inspection Service. “Info Sheet:
Bovine Somatotropin.” May 2003.
143 United States Department of Agriculture. “Dairy 2007.” October 2007
at 79.
144 Kroger Co. [Press release]. “Kroger to Complete Transition to
Certified rBST-Free Milk by Early 2008.” August 1 2007.
145 Lentini, Nina. “Wal-Mart’s Milk Now Comes from Non-rBST Cows.”
Marketing Daily. March 24 2008.
146 “Newsline: Dean, Hood Going no-rBST.” Dairyfoods.com. October 1,
2006.
147 Heller, Lorraine. “Dannon removes growth hormone from dairy
products.” Dairyreporter.com. February 23, 2009.
148 General Mills. [Press release]. “General Mills Announces
Commitment to Make Yoplait Yogurt Products 100 Percent Free of
Milk from Cows Treated with rBST by August 2009.” February 2,
2009.
149 Baxter, Carol. “Reading, ‘riting and rBGH: What Kind of Milk is Being
Served in Your Child’s School?” National Geographic Green Guide
No. 36. Available online at http://www.thegreenguide.com/doc/36/
milk . March, 1997.
150 Bio/Technology/Diversity News Bulletin. “School Districts say No
to BGH.” Vol. 2, No. 21, December 1993; Food & Water Watch staff
interview with John Kinsman, Wisconsin dairy farmer (September 10
2008).
151 Food Research and Action Center. “Federal Food Programs — National
School Lunch Program.” Available at http://www.frac.org/html/fed-
eral_food_programs/programs/nslp.html. Accessed March 31, 2009.
152 See, for example, the San Francisco Unified School District Wellness
policy, available at http://www.sfusdfood.org/; see also the Berkeley
Unified School District Wellness Policy, available at http://www.
chefann.com/html/tools-links/BUSD/BUSD-documents/BUSD-
Wellness-Policy.pdf.
153 Dohoo, Ian, DesCouteaux, Luc, Leslie, Ken, Shewfelt, Wayne, et al.
Health Canada, Drug and Health Products. “Report of the Canadian
Veterinary Medical Association expert panel on rBST.” Available
at http://www.hc-sc.gc.ca/dhp-mps/vet/issues-enjeux/rbst-stbr/
rep_cvma-rap_acdv_tc-tm-eng.php. November 1998, at Section
7; Groves, Martha. “Canada Rejects Hormone that Boosts Cows’
Milk Output.” Los Angeles Times, January 15 1999; European
Commission, Directorate General for Health and Consumer
Protection. “Report on Public Health Aspects of the Use of Bovine
Somatotrophin.” Available at http://ec.europa.eu/food/fs/sc/scv/
out19_en.html. March 1999.
15
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