In 21st century America, it is easy to take the pipes that carry potable water in and non-potable water out for granted. Out of sight should not be out of mind. My father was a plumber and routinely put me up close and personal….
When it comes to food safety, ventilation is neither the cause nor the solution to odors, vapors, and condensation. You prevent odors with structural containment and exhaust to the exterior, not by relocating odors elsewhere through air…
Light is good. Historically, the federal government agrees. Regulations of the Bureau of Animal Industry, the first federal meat inspection agency, required that there “shall be abundant light…to ensure sanitary condition”
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.
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.
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.
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…
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…
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….
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….