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.
Things I Wish I Knew Before Beginning to Farm
Over the last few months, we have collected responses from our members and supporters about aspects of farming that they wish they would have known about before they began their journey.
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.
Tangles with the USDA: A Member Testimonial
I’d been selling grass-fed meat products for several years and had never had any issues with the USDA. Until one day, I received a phone call from a distraught lady about the photo of our meat that I had posted online. The image was a big pile of meat that had “not for sale” written on…
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.
Insanitary Condition
My definition of insanitary condition is not always my wife’s definition of insanitary condition. Not a problem. In our house, my wife’s opinion rules the day. The same should not be true in an official establishment…
Adulterated: The Most Significant Term in Food Law
In 1991, I entered a graduate program in veterinary pathology. I knew the pathological conditions. Recognizing them under a microscope took practice, but I got there. The same is true of the term “adulterated,” arguably the most significant term in food law…
The Devil is Always in the Details: A Member’s Question
Understanding FSIS compliance is a challenging component of farming, and oftentimes can be confusing. Recently, an FTCLDF member had a question regarding the 20,000 exemption for poultry. Dr. Fisher provided a thoughtful, thorough response, and we thought it would be helpful….
Understanding FSIS Language
Fall 1979. I received the book list for my first semester classes in veterinary college. Top of the list: Dorland’s Illustrated Medical Dictionary. That first year, I opened this book more than any other. Regulatory agencies, like medicine, have their own language. Unless you understand that language, you do not know what you are talking….
The Rules of the Game
We are pleased to announce that Dr. Michael Fisher joins the FTCLDF website as a monthly contributor. Dr. Fisher is a retired United States Department of Agriculture (USDA) Food Safety and Inspection Services (FSIS) veterinarian, bringing decades of experience enforcing FSIS regulations during the slaughter and processing of animals for which the USDA…