Salmonella in Raw Products – Can FSIS Request a Recall?

By Barbara J. Masters, D.V.M.

I am often asked whether or not the Food Safety and Inspection Service (FSIS) can request a recall for meat or poultry products merely because the products test positive for Salmonella.  The answer to that question today is no.  However, there are times FSIS can request a recall of raw meat and poultry products for Salmonella.  If at any point FSIS determines there is specific product (specific lot, specific product date) in commerce making people sick, it will ask for a voluntary recall of that specific production of product, regardless of whether there is a positive test result.

What is important to understand is that for outbreak recalls, FSIS will use the same thought process regardless of whether the pathogen is considered an adulterant or not.  FSIS would look for the following four factors as part of the outbreak investigation:

  • There are related illnesses (an outbreak) as determined by the DNA analysis of samples from case patients;
  • The evidence supports the conclusion that the likely source of the illnesses was a specific product;
  • The plant produces that specific product; and
  • A specific production of that plant’s product was purchased by, or available to, the case patients at the time and location of the illnesses.

If all of these criteria are met, FSIS will request a recall of the product implicated in the outbreak.  In this circumstance, FSIS is not relying on a positive test result (from the product) to request the product be removed from commerce, rather they are relying on evidence that the specific product has been implicated in causing an outbreak.

In summary, today, FSIS can request an establishment to conduct a voluntary recall for products that test positive for an adulterant (e.g., E. coli O157:H7), but not for product that tests positive for Salmonella.  However, in the case of a foodborne outbreak, FSIS applies the same rules to all pathogens.  If the evidence supports that a specific production of product is the likely source of the illnesses in the outbreak, FSIS will request a voluntary recall (not based on test results of the product).

About Dr. Masters

Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service’s (FSIS) Administrator, Dr. Barbara Masters.  Dr. Masters is a veterinarian who spent eighteen years with FSIS – the final three years as Acting Administrator and Administrator.  During her rise to the Administrator’s position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations.  While in these key leadership positions at FSIS, Dr. Masters’ primary focus was on the implementation of science-based policies for the protection of public health.

Hand Washing: A Simple Step

By Barbara J. Masters, D.V.M.

How many of you have ever sat in a public location, such as the airport, and watched the number of people that enter the restroom talking on their cell phone?  Creepy, huh?  Not nearly as creepy as the same number of people that exit a very short time later still talking on their cell phone.  I always question how they washed their hands.

According to the Center for Disease and Prevention (CDC), “Washing hands prevents illnesses and spread of infections to others.”  It is a simple step we can all take before, during, and after preparing food, before eating, after using the toilet or assisting a child use the toilet, after blowing your nose, coughing, or sneezing, after touching animals or animal food or animal waste, and after touching garbage.  Washing hands keeps them clean and prevents the spread of bacteria that can make people sick.

It is especially critical to wash your hands when preparing food to prevent the spread of common foodborne bacteria such as E. coli O157:H7 and Salmonella.  To wash your hands, use soap and warm water and lather your hands for at least twenty seconds.  It is important to get the back of your hands, between fingers and under your nails.  If you are not certain how long twenty seconds is, hum “Happy Birthday” two times while washing.

If you are out on a picnic or do not have access to soap and water, then use of a hand sanitizer can be substituted.  If you must use a sanitizer, first wipe hands with a paper towel or a napkin to remove the visible dirt.  Then apply the sanitizer and rub hands together until the sanitizer dries.

The CDC has promotional materials that can be utilized to encourage hand washing at your work site or in schools.  Clean hands are a simple step we can all take to improve public health.

About Dr. Masters

Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service’s (FSIS) Administrator, Dr. Barbara Masters.  Dr. Masters is a veterinarian who spent eighteen years with FSIS – the final three years as Acting Administrator and Administrator.  During her rise to the Administrator’s position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations.  While in these key leadership positions at FSIS, Dr. Masters’ primary focus was on the implementation of science-based policies for the protection of public health.

Food Defense Plans

By Barbara J. Masters, D.V.M.

One of the goals of the Food Safety and Inspection Service’s Strategic Plan is to “ensure that facilities implement safeguards and systems to protect food from contamination by people who might try to intentionally and maliciously harm consumers.”  The Agency has a FY 2015 target of 90% of all establishments having a functional food defense plan. Since 2006, annual surveys have been conducted to measure progress.  The largest establishments currently exceed the goal (97% have a functional plan) while the very small establishments are not yet at the target.

The Food Safety Modernization Act (FSMA) requires the Food and Drug Administration (FDA) to implement measures to protect the food supply from intentional contamination.  A proposed rule to address hazards resulting from intentional contamination was issued on December 24, 2013.

Both FSIS and FDA have taken substantial measures to assist the food industry in the development of food defense plans.  The FSIS webpage includes a tool that an establishment can download to select the specific elements appropriate for their facility.  FDA maintains an on-line food defense plan builder free to all users.  Once a plan is documented, the establishment must implement the plan.  Steps to implementing a food defense plan include:

  • Testing the plan (e.g., check locked doors, take unannounced walks around the perimeter), and
  • Reviewing and maintaining the plan (review and update as needed).

Food defense plans should be tailored to the facility.  Small establishments do not need to make the plan overly burdensome.  For example, a plant that only employs family members would not need background checks on employees as a critical element.  However, this establishment could document the use of door locks and outdoor lighting at key locations in the facility.

Areas to be considered in a food defense plan are: outside security, inside security, personnel security measures and incident response security measures.

When I go visit any establishment, I am always asked to show my identification.  I am always escorted during the visit, and I see emergency plans posted at every facility.  These are all elements of a food defense program.  If these elements for secure food are already in place, it is logical that they could easily be documented and verified by the establishment.

I encourage those plants that are not currently maintaining a functional food defense plan to review the FSIS and FDA websites.  I challenge them to consider that they very likely already have all the elements in place for a food defense plan – the plan just needs to be documented.  By documenting the plan – the establishment is taking the necessary steps to ensure all team members are aware of the program and are taking steps to consistently implement it.

If by maintaining a functional food defense plan we can contribute to a safer and more secure food supply, then I am certain we are all in favor of meeting this objective.

Regulatory Round-Up Newsletter, Spring 2015

On behalf of the Agriculture practice group at OFW Law, here is a copy of our Spring newsletter.  We hope you find it useful.  To receive this periodic newsletter by e-mail, please contact Carrie Morgan at cmorgan@ofwlaw.com.

Don’t Rush the Holiday Preparations – Make Certain the Meat is Properly Cooked

By Barbara J. Masters, D.V.M.

Getting ready for holiday “get togethers”, one often finds themselves in a rush or behind on preparing the food for the party.  Don’t let tardiness be the reason the party attendees end up with a case of foodborne illness.  Don’t rush cooking of product; I am certain the guests would rather wait a few minutes than risk the potential of being sick because the product was not properly cooked.

Always read the product label for specific cooking instructions and follow them!  Be sure to verify whether the product has been pre-cooked and simply needs to be re-heated, or if the product is raw and needs to be thoroughly cooked.   All of this information will be included on the product label.  If there are questions on what temperature to cook a specific product to, USDA’s Food Safety and Inspection Service provides a chart that includes safe minimum internal cooking temperatures:

Cook all food to these minimum internal temperatures as measured with a food thermometer before removing food from the heat source. For reasons of personal preference, consumers may choose to cook food to higher temperatures.

Product Minimum Internal Temperature & Rest Time
Beef, Pork, Veal & Lamb
Steaks, chops, roasts
145 °F (62.8 °C) and allow to rest for at least 3 minutes
Ground meats 160 °F (71.1 °C)
Ham, fresh or smoked (uncooked) 145 °F (60 °C) and allow to rest for at least 3 minutes
Fully Cooked Ham
(to reheat)
Reheat cooked hams packaged in USDA-inspected plants to 140 °F (60 °C) and all others to 165 °F (73.9 °C).

 

Product Minimum Internal Temperature
All Poultry (breasts, whole bird, legs, thighs, and wings, ground poultry, and stuffing) 165 °F (73.9 °C)
Eggs 160 °F (71.1 °C)
Fish & Shellfish 145 °F (62.8 °C)
Leftovers 165 °F (73.9 °C)
Casseroles 165 °F (73.9 °C)

Source: Food Safety and Inspection Service

You can not see or smell bacteria that may be on raw products.  It is important to follow the manufacturer’s cooking instructions to ensure the safety of the product.

Stuffing Safety 1

By Barbara J. Masters, D.V.M.

It is that time of year again.  I don’t cook –and I continue to provide food safety advice for those of you that do.  Ah, it must be Thanksgiving.  Last year I provided some tips on thawing and cooking your Thanksgiving turkey.  I encourage you to review those tips if you have any questions on safely preparing your turkey.

This year, I am adding counsel on safely preparing the stuffing.  The most important things to remember are: stuffing should be cooked separately from the turkey (you can add it to the bird after both have been properly cooked), the stuffing should not be prepared ahead (unless you plan to freeze it), and the stuffing must reach a temperature of 165°F to be safe.

The safest way to prepare stuffing is to mix the ingredients just prior to cooking and place them in a shallow baking dish. Moist stuffing is always better, as heat destroys bacteria better in a moist environment.   The oven should be set no lower than 325°F and the stuffing should reach an internal temperature of 165°F.   The leftover stuffing should be promptly refrigerated within 2 hours of removal from the oven.  The leftover stuffing should be used within 3-4 days.

While we are all looking for those dishes we can prepare ahead to save time, stuffing is not one of them.  If you must prepare it ahead, you can prepare the stuffing and freeze the mixture in the shallow casserole dish that will be used for baking.  The stuffing can then be cooked from the frozen state (do not thaw) until it reaches 165°F.

If you add meat, poultry or shellfish to the stuffing (if I cooked, I certainly would add this), you should pre-cook the ingredient to 165°F before adding it to the stuffing.  This is true even when you are planning to freeze the stuffing and cook it at a later time.

Finally, if it is not clear by this point, the stuffing must reach an internal temperature of 165°F to ensure that it is safe.  Of course, you learned last year that a food thermometer is part of any “safe Thanksgiving.”  It is critical to use it to measure the temperature of both the turkey and the stuffing.

Have a Thankful and Happy Season.

Before joining OFW Law, Dr. Masters served as Acting Administrator and then Administrator for the United States Department of Agriculture Food Safety and Inspection Service (FSIS) from March 2004 through January 2007.

Phil Olsson and Rick Frank on 35 Years of Life at OFW

By Philip C. Olsson and Richard L. Frank

Phil: Rick, it’s hard to believe that 35 years have passed since we started this firm as a two-lawyer shop in 1979.

OFW Logo 35th AnniversaryRick: It sure is. I remember working with you at the law firm I joined fresh out of the University of Michigan Law School, and which you had joined several years earlier out of the USDA, where you had been Deputy Assistant Secretary for Marketing and Consumer Services.

In 1979, I was 28, with little experience. You were 40, and a well-known fixture in the agriculture and FDA bar. We decided to take a giant leap of faith and started Olsson and Frank. We persuaded Anita Harris to join us as our all-purpose support staff.

Phil: Our initial clients were food and agriculture companies and trade associations, including American Feed Manufacturers Association [now American Feed Industry Association], National Turkey Federation, Pacific Coast Meat Association [now North American Meat Association], The Quaker Oats Company, and Pueblo International.

Rick: Amazingly, many of those clients from 35 years ago are all still our clients today. We appreciate their loyalty and support over the years.

Phil: Today, food and agriculture are still a major part of our practice. But our practice has evolved and grown to include a wide range of industries regulated by USDA and FDA. We are still primarily a regulatory and counseling practice, with litigation capability.

Rick: We have had some notable successes from the outset.

Phil: Our first big challenge involved the National Turkey Federation, defending recently adopted USDA labeling regulations for “turkey ham,” which was allowed as a product name as long as it was qualified by the phrase “cured turkey thigh meat.” Two meat industry associations challenged that regulation. Before the District Court in Norfolk, we had a particularly unsympathetic judge, who began his opinion with an excerpt from Lewis Carroll about “when pigs have wings.” Fortunately for our client, the Fourth Circuit agreed with us and upheld USDA’s regulation. That win showed that our small firm was a feisty advocate. No one has ever doubted that Rick can be feisty, but that victory showed that our small firm had been inoculated with his feisty DNA.

Rick: The “turkey ham” case was important for the food industry, because it allowed product innovation to proceed without artificial constraints on product names. Along the same vein, for years we successfully fought off efforts by the dairy industry to demonize “imitation cheese” used as an ingredient in a wide variety of refrigerated and frozen meat-topped pizzas regulated by USDA.

Two other victories come to mind. We successfully got “Fresh Choice” orange juice and “Fresh Italian” pasta sauce off the market. Those products, which were made from previously processed, heat-treated concentrates, were anything but “fresh.” We also helped get approvals for lean, finely textured beef, a highly innovative, nutritious, and lower cost meat component widely used in ground beef and related products. (Note: Unfortunately, a disgruntled USDA employee, a “mommy blog,” and a national TV network disparaged this wholesome product as “pink slime” several years ago.)

Phil: One of my favorite clients was an egg distributor. On a trip with him to Cuba, we got to spend about five hours with just Fidel Castro, Castro’s trade director, and Castro’s interpreter. We heard Castro talk at length about improvements in Cuban literacy and life expectancy that had taken place since he took power in 1958. I have a treasured photo of me with El Presidente in my office.

Rick: It’s been a great 35 years, with lots of interesting matters. From the beginning, we always worked hard, tried to develop “creative solutions to difficult problems,” and fought to win our cases. We charged fairly for our services and worked in a very collegial environment. We still follow those guiding principles, which have served us well.

Phil: Indeed, those principles have worked well for us, as we have grown and prospered over the years.

Rick: In our early days, I was usually the youngest person in the room; Phil, you were the tallest. Today, I am often the oldest person in the room, but you are still the tallest. Some things change; some things don’t.

Thirty-five years have sped by. You, Anita, and I are all grandparents. The firm has grown, slowly but steadily, from two lawyers to almost 40 lawyers and Policy Advisors today.

Phil: In the beginning, you and I quickly realized we needed someone with more FDA expertise. In 1981, we were extremely fortunate to be joined by David Weeda, who had worked in FDA’s Office of Chief Counsel. David’s practice focused on drugs and biologics.

Next, Dennis Johnson joined us in 1982 after completing a Food and Drug Law Institute internship with FDA’s Office of Chief Counsel. He rapidly developed a practice representing packing and processing firms on their individual issues with USDA’s Food Safety and Inspection Service. Despite government warnings on each cigarette package, DJ has never been able to give up his Lucky Strikes, and he developed close friendships with a number of FSIS decisionmakers while sharing their smoking breaks.

Rick: David was responsible for recruiting his former FDA Office of Chief Counsel colleagues, Arthur Tsien and Steve Terman, to join us. Both have fit in very nicely. Today, Arthur is the head of our drug practice and our animal food and animal drug practice, while Steve heads our medical device practice.

Phil: Marshall Matz and I have known each other since the days when he was counsel for Senate George McGovern’s Hunger Subcommittee and I was working on hunger issues for the Nixon Administration at USDA. Marshall joined us in 1992 and has built a world-class policy and lobbying practice.

Rick: Marshall’s practice fit in neatly with the non-lawyer Senior Policy Advisors that have joined us over the years. The first was John Block, President Reagan’s first Secretary of Agriculture and the youngest member of the Reagan Cabinet. Jack is to-this-day a corn and hog producer and before coming to Washington he had been the Illinois Secretary of Agriculture. We also have former Congressman Charles Stenholm. Charlie had been the leader of the Blue Dog Coalition in the House, a group of moderate Democrats who worked to build bipartisan consensus.

We are also pleased to have Dr. Barbara Masters, a veterinarian and a former (non‑smoking) Administrator of FSIS. Barb began working for USDA straight out of vet school and burst through several (age and gender) glass ceilings to become FSIS Administrator before she was 40.

Phil: And we’re privileged to have had many other talented individuals join us over the years.

Rick: Absolutely. We have the O’Flaherty Brothers from Chicago. Michael heads our food practice. Neil is a stalwart in our medical device practice. David Durkin and Tish Pahl are an important part of our drug practice. Brett Schwemer and Jolyda Swaim are part of our meat and poultry practice, while Evan Phelps works on medical device matters. Jon Weinrieb is our resident maven on medical privacy. We added Gary Baise and his team to work on agriculture-related litigation. Bob Hahn works on food matters. There are others, of course.

Phil: David Weeda is an “almost founder” of this firm. Unfortunately, David succumbed to lymphoma at an all-too-early age in 2001. We are now fortunate to have a next generation Weeda, David’s son Mason, as one of our up-and-coming associates.

Just as we were in the process of moving our offices to The Watergate in 2011, Marshall persuaded his old friend and mentor Senator McGovern to join us as a Senior Policy Advisor. Marshall liked to point out that we had brought Senator McGovern back to The Watergate. The Senator remained one of us until he passed away.

Rick: In 35 years, much has changed, but much remains the same. We are still a relatively small, quirky boutique, specializing in food, agriculture, drugs, devices, and related litigation.

Phil: Along the way, we’ve done many different kinds of things. Rick has been heavily involved in community activities as the founder of the Lawyers Have Heart 10K foot race and fundraiser, which has raised millions of dollars for the American Heart Association during the 25 years of its existence. He has also worked closely with a number of consumer organizations, building credibility to obtain consumer support for some of our client causes.

In the 35 years since 1979, our country has been led by six presidents. We have seen many of the national and international mega-law firms stumble and disappear. From the beginning, our firm has been fortunate to have had Rick’s prudent management skills, which I believe he absorbed while watching his parents and grandparents run a small family business. Thirty-five years at OFW has been a great ride with a great group of people, both those within the firm and those on the outside, the clients who have made it all possible.

Rick: It sure has been a great ride and it’s not over. We are in the process of grooming tomorrow’s leaders. I still love my view of the Potomac from my office in the Watergate Building – the planes and helicopters and boats coming and going. Our cases were and are challenging and interesting. Washington is a wonderful place to work and raise a family.

On to the future!

Data Driven Decision Making by Dr. Doom

By Barbara J. Masters, D.V.M.

When asked to visit an establishment to assess compliance, my first step is always to ask for data.  Establishment food safety data, laboratory results, regulatory data, audits…. What story is being told?  Is there a trend in the making?  Upward trend?  Downward trend?

It is important for establishments that are regulated by the Food Safety and Inspection Service (FSIS) to recognize that the Public Health Information System (PHIS) provides a tool for the Inspection Personnel to understand what (using data) is happening on a day to day basis at our facilities:

  • Lab data
  • HACCP compliance/non compliance
  • Sanitation compliance/non compliance.

In the past, FSIS relied on managers to generate “alerts” or flag data trends in the PHIS.  However, there is now enough data in PHIS that the system will “send” alerts to inspection program personnel when the data suggest a trend is developing at an establishment that warrants further review.

For example, the Agency focuses on data related to public health NRs for HACCP and sanitation non-compliances.  The Agency has indicated that for 2015, the “cut point” for public health NRs in processing establishments will be 6.55% and in combination (or pure slaughter) establishments, it will be 9.37%.  Establishments that experience higher noncompliance rates than these can expect that the inspection personnel will receive “alerts” within PHIS indicating the need for additional verification.

FSIS also is using the PHIS data to schedule Food Safety Assessments and Hazard Analysis Verification tasks.

As FSIS supervisors are “looking into the system” and gaining a better understanding of what is happening at establishments based on our data, are we doing the same?

  • Are we reviewing our own data?
  • Do we track trends and take actions based on the findings?
  • Have we signed up for PHIS-industry access?
    • A report for public health NRs will be available beginning November 16th.
  • Do we know where we are relative to the FSIS “cut points” for public health NRs?
    • What is our HACCP compliance rate?
    • SSOP compliance rate?
      • If we have had failures, have they been for a specific area, e.g., failing to maintain records?
      • Do we have similar findings in our own data?

I encourage you not only to maintain the necessary records, but to review them and use the data to improve your processes.  The only thing worse than having information and not using it, is having the regulatory agency use it “for” you.

About “Dr. Doom”

Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service’s (FSIS) Administrator, Dr. Barbara Masters.  Dr. Masters is a veterinarian who spent eighteen years with FSIS – the final three years as Acting Administrator and Administrator.  During her rise to the Administrator’s position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations.  While in these key leadership positions at FSIS, Dr. Masters’ primary focus was on the implementation of science-based policies for the protection of public health.  Dr. Masters issued the initial Federal Register Notices for a systematic approach to humane treatment of livestock and poultry.

Dr. Masters was involved in the drafting of the training of inspection personnel on the Hazard analysis and critical control points (HACCP) and Sanitation Standard Operating Procedures (SSOP) regulations.  She was the lead of the FSIS HACCP Hotline.  In addition, Dr. Masters provided technical review for establishment’s hazard analysis, HACCP plans and supporting documentation.  She started her career at FSIS as a public health veterinarian that had responsibilities for ante-mortem inspection, sanitation inspection and all post-mortem inspection responsibilities.  She has a good understanding of what happens at the in-plant location, because she has spent many of long days working there.

Pontifications by Dr. Doom

By Barbara J. Masters, D.V.M.

As described by Dennis Johnson in his recent article from our Regulatory Round-Up Newsletter, the current human illness rate for E. coli O157:H7 has not gone down as documented by the Centers for Disease Control and is, in fact, trending upwards. This is very concerning.  Our firm has been advocating that the beef industry be aware of this information, review their food safety systems and ensure they are doing everything possible to “attack this pathogen at the slaughter and processing levels.”  As a prior regulator and a current advisor to the beef industry, I feel very strongly that this is necessary and that the beef industry has and will continue to remain vigilant in the “war on this pathogen.”

For a moment however, I must speak as a consumer, which I am.  As I search the internet, I compare downloadable menus to the FDA Food Code.  Yes, I realize the Food Code is not mandatory, and the one in use varies by state.  That said, at the “local burger joints,” this is what I have been finding:

According to the various editions of the Food Code, my burger should be cooked well done (e.g. the FDA 2013 Food Code indicates comminuted meat should be cooked to 158°F).  The Food Code does permit “consumer advisories” alerting the person ordering “of the significantly increased risk of consuming such foods by way of a disclosure and reminder such as on the menu or brochures that consuming raw or undercooked meats, poultry, seafood, shellfish, or eggs may increase your risk of foodborne illness.”  Restaurants are not permitted to serve undercooked burgers to children.

While many of the internet menus that I have found for “local burger joints” do contain the necessary advisory statement, I am left to ponder whether the consumer is more intrigued and motivated by the highlighted ordering options than they are concerned by the advisory in fine print.  “Select your protein and cooking temperature” seem to be a very popular way of presenting burgers at the current time.  The selection for rare and medium rare cooking temperatures are not discouraged, and in fact, at some locations are “suggested” as preferred.

I am very concerned that individuals ordering may be relying on the restaurant to assist them in making “safe” ordering decisions rather than on the “fine print” advisory at the bottom of the menu alerting them that eating raw or undercooked meat may cause illnesses.  It seems possible that the association between rare and undercooked has been lost. In reading “yelp” reviews of these restaurants, it is clear that the individuals eating at these locations are enjoying burgers cooked to the rare temperatures; no one is focusing on the consumer advisory.

As for me, I will continue to “advise” the beef industry to do all they can to prevent E. coli O157:H7 contamination.  I will make certain my family orders their burgers well done; as well as educate all those I can to do the same!

About “Dr. Doom”

Mixed in with the attorneys at OFW Law is the former USDA Food Safety Inspection Service’s (FSIS) Administrator, Dr. Barbara Masters.  Dr. Masters is a veterinarian who spent eighteen years with FSIS – the final three years as Acting Administrator and Administrator.  During her rise to the Administrator’s position, Dr. Masters served as the Deputy Assistant Administrator for Office of Field Operations.  While in these key leadership positions at FSIS, Dr. Masters’ primary focus was on the implementation of science-based policies for the protection of public health.  Dr. Masters issued the initial Federal Register Notices for a systematic approach to humane treatment of livestock and poultry.

Dr. Masters was involved in the drafting of the training of inspection personnel on the Hazard analysis and critical control points (HACCP) and Sanitation Standard Operating Procedures (SSOP) regulations.  She was the lead of the FSIS HACCP Hotline.  In addition, Dr. Masters provided technical review for establishment’s hazard analysis, HACCP plans and supporting documentation.  She started her career at FSIS as a public health veterinarian that had responsibilities for ante-mortem inspection, sanitation inspection and all post-mortem inspection responsibilities.  She has a good understanding of what happens at the in-plant location, because she has spent many of long days working there.

Regulatory Round-Up Newsletter, Spring 2014

On behalf of OFW Law’s Agriculture practice group, here is a copy of our new newsletter.  We hope you find it useful.  To receive this periodic newsletter by e-mail, please contact Carrie Morgan at cmorgan@ofwlaw.com.