/johnny
The FDA won't respond to your challenge. They don't care about you, and dang sure don't care about the constitutionality of their authority.
It's time for people to people to understand that the Constitution as written and amended is a dead letter. De facto, the President interprets the Constitution as he pleases and the US government does what he wills. (And this did not begin with Obama. He's just taken it up a notch.)
11 states and DC have banned raw milk. They mentioned it's legal in 10 others but that must mean it's specifically allowed by law rather than just "not banned" otherwise I'd expect them to have written it's legal in 39 states, not 10.
MD has gone so far as to forbid people from shared ownership in a real cow kept for purposes of having raw milk!
“My position is that there is no power delegated to the federal government to regulate milk made and consumed within a state. I challenge the FDA to show me where in Article 1 Section 8 of the Constitution that the States delegated the power to regulate milk. Ain’t there.”
/johnny, ours is a government by outlaws.