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.
poultry
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.
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…