On February 27, 2020, four years after the Petition filed by FTCLDF and member Organic Pastures Dairy Company, the FDA issued a decision denying our request to permit the interstate sales of raw butter. We now plan to challenge this decision, asking the federal court to overturn the…
FDA
FTCLDF and Member File Raw Butter Lawsuit
This week, the Farm-to-Consumer Legal Defense Fund (FTCLDF) and one of its members, Mark McAfee of Organic Pastures Dairy, filed suit against the U.S. Food and Drug Administration (FDA) in the United States District Court for the District of Columbia. Our lawsuit seeks to force…
Construction
As a kid, I picked cherries from the cherry tree in our backyard. Another form of cherry-picking occurs when FSIS inspectors base an allegation of noncompliance on isolated regulatory text and ignore the qualifying regulatory text. 9 CFR 416.2(b): Construction is often cherry-picked.
Grounds and Pest Control
An undeniable truth: someone will disappoint you at some point in your life. An undeniable falsehood: 9 CFR 416.2(a) prohibits insects and rodents within an official establishment.
Appealing FSIS Noncompliance Records
A noncompliance record is the basic building block for FSIS enforcement actions. Like my grandchildren’s LEGO objects, some noncompliance records have purpose; others are pure imagination.