 Welcome to our Wednesday weekly webinar. This is a series of ten webinars. And I believe this is the fourth one. And I will be introducing our speakers shortly. My name is Julie Gardner Robinson and I'm a food nutrition specialist here on campus at North Dakota State University. I want to tell you about our upcoming webinars. I think these are a lot of fun. So I hope you'll join us and invite your friends. Our next webinar will be an introduction to home winemaking with Steve Saggiser. And that will be followed by a session on herbs by Holly Moby who's at Dakota College of Botany. And then we'll have a little bit more information on the Food Safety Modernization Act. And that will be done by Kim Koch from the Northern Crops Institute. And rounding out our series will be sessions on fruit flies by Esther McGinnis, canning, low and high acid foods by Dr. Clifford Hall. And finally, last but not least, Todd Weinman who's our horticulture agent here in Cass County talking about introducing youth to gardening. So we have lots of great sessions coming up. And again, I hope that you will join us. In case you will miss any of these, I do want to let you know that we are archiving these thanks to our friends over in agriculture communication who keep our website updated. So they are always available. They're going to stay online. And we also have 14 webinars from last year that are also available. And they're all on slightly different topics. I think we've all figured out about the logistics, but just to let you know, you will be in listening mode that you can always type your comments or questions in the chat pod. And Dave might be asking you to respond to some questions. I know you have some scenarios. So, you know, feel free to interact. It's a great time to interact with some of the researchers and specialists on campus. We will have some time at the end of the webinar for questions and answers. And I do have a short survey that I ask you to do at the end of the webinar. Just so that you know, we are, our funding is from a grant. So your responses to the survey are really important to us. And that link will be directly emailed to you. And also please check out the field to fork website because we're constantly adding new resources to that website. And you can use anything you find. Please go ahead and make use of that resource. If you think of things that we don't have and you're interested in learning more, please go ahead and drop me an email and I'll work on it. So, we are ready to begin our session. I want to tell you a little bit about David Sokowski. He is an associate professor here at NDSU. And his courses have included agricultural law, food law, farm and agribusiness management, and also water law. And Dave really works to enhance student learning by promoting writing, which is great, and adoption of information technology. He uses websites and so on to really bring his courses to life. David has served as the director of the Department of Agricultural Communication as assistant dean of the Graduate School and interim chairperson of the Department of Agribusiness and Applied Economics. And his research is in the area of agricultural law and agribusiness management. With that, I will welcome Dave to teach you about U.S. food law and how to align the pieces of the U.S. food law. Thank you Julie. What a generous introduction. I appreciate the kind words. That list is longer than it probably deserves to be. Welcome everyone. I look forward to working with you this hour. And though there's time for questions and some interaction at the end of the session, please send questions throughout the session. I think it's important that we take the time to answer the questions that you have, address the topics that are important to you, so do not hesitate to send a question if there's something that comes up as we go over the materials. My wife enjoys puzzles. I struggle with puzzles. And yet when it comes to food law, I find that over the past decade or so that I've tried to understand food law. It's just a whole maze of pieces. Somehow can we fit them together and begin to understand an overall structure or a picture of what is U.S. food law? So what we're going to do this afternoon in the coming hour is to try to identify some of those pieces and then try to organize some of those pieces. So we're not going to go into a lot of detail today. Instead, we are going to be just asking ourselves of all those topics that we've heard about, those topics that we work in, how do these pieces relate to one another? And what I have on the screen now is just a list of agencies or organizations that we've all heard about, and we're going to talk about them this afternoon. It feels like it's a vegetable soup that's filled with pasta shaped into letters, or maybe it's alphabet soup or whatever it might be, but it's a conglomeration of different agencies, different organizations that come together in what we call food law. And I make a distinction between agencies and organizations because not everything we're going to talk about today is based on government. Some of the entities that we will briefly introduce are from the industry. So this is more than just government agencies, government regulations. There are industry expectations. I will not buy your product unless your product meets my expectations, and that becomes part of our overall understanding of the food laws. Food and Drug Administration, FDA, we've heard about that. We're going to look at some of the responsibilities of that agency this afternoon. Within the FDA, we have the Center for Food Safety and Applied Nutrition. As the title implies, we're focusing on food safety. One thing that we want to keep in mind is many of the U.S. food laws focus on food safety and not necessarily food quality. You get into a business that's dealing with food and the managers, the employees, they're interested in making sure that it's not only a safe product, but it's a quality product, a product that will keep the customer coming back, buying whatever it is that we're selling. When it comes to the government perspective on it, the government's not that focused on quality. The government's focused on safety. And then we have the USDA with its role within the food industry, the Food Safety Inspection Service, responsible for our meat and poultry industry. So we have a distinction right there that the meat and poultry, our processed eggs, are regulated or overseen by the Food Safety Inspection Service within the USDA. And I like to simplify by saying all other foods are generally under the FDA. It's not quite that simple. But we'll talk about that this afternoon. The Ag Marketing Service within USDA, the Grain Inspection Packers Stockyards Administration within USDA. The Ag Marketing Service, when you think about organic foods, organic products, it's the Ag Marketing Service that has responsibility for those products, at least those that want to be qualified or considered organic. The Grain Inspection Service or administration is looking at the quality of the grains, and this is coming from the farm level. We've heard about the number two yellow corn or different standards for our grains. But those standards came more from the food industry or the desire to have those standards came more from the food industry than necessarily from the consumer. If I'm going to sell my wheat to you so that you can grind it into flour, you want to know what that wheat looks like. But that wheat might be a thousand miles away. So let's go ahead and have some standards. The grain can be grated. That information about how this grain is grated, the grain that is achieved, we can share that with you. You can go ahead and buy that grain then with confidence without necessarily having to inspect it. How do we do this? That's when we bring in the Grain Inspection Service within the USDA Center for Veterinary Medicine back under the FDA, dealing with the medicine used for our livestock. The Animal and Plant Health Inspection Service USDA. Here we're primarily talking about the animals and plants that are brought into our country to make sure that they aren't carrying a disease that could then spread to our agriculture industry and wreak all kinds of havoc. The Environmental Protection Agency. We're familiar with the EPA, but yes, the EPA has a role in food safety as well. Let's make sure mostly the pesticides, let's make sure that those pesticides aren't rendering our food unsafe. Custom and Border Protection. As that food enters the United States, somebody needs to keep an eye on what is being brought into the nation, and the Customs and Border Protection is part of that effort. The Federal Trade Commission. And then of course at the state level, states almost always have a Department of Health or a Department of Ag that has responsibility for overseeing the food within each state. We'll talk about more of that as we go through our session this afternoon. Then when we step outside the United States, there's international standards, a variety of international standards. I mention only one here, the Codex. The Codex is based in the large part on the United Nations. We have the Food and Agriculture Organization within the United Nations. We have the World Health Organization within the United Nations. Working with a collection of countries from around the world have established standards for our food products, for our food industry. And we just simply refer to it as the Codex. Then we again cannot forget that the industry is also very interested in the safety of the food products that the industry produces or manufactures and makes available to the consumers. And from the industry perspective, again I just chosen one as an example this afternoon, but a variety of standards and one of them would be the Global Food Safety Initiative. So a number of organizations, agencies involved in this complex puzzle of food safety. Again I invite you to submit questions if something comes up why we go through these materials. We continue with that alphabet soup. Now we're going to briefly mention a couple of concepts. Rather than the agencies or the organizations, we hear about the concepts such as the Food Safety Modernization Act, which is now six years old. But we're still in the early stages of implementing this particular piece of legislation from Congress. A person might think six years is a long time. Twenty years might seem like a long time. But when you think about it from a law perspective, twenty years is not long. It takes us a long time to figure out what are the details of how we're going to put these rules in place. Fifty years to a lawyer or to a law is not really long. Even a century. We have legal concepts in our society that stem back to the Roman Empire. So to think about something as being only six years old, we're still trying to figure out the details such as the Food Safety Modernization Act. That is not a long time if you think about it as we often end up thinking about it in the legal profession. HACCP, Hazard Analysis Critical Control Point, certainly is another concept that we've heard about a lot. We've practiced it. You probably applied in your business or you've talked with business people about this particular concept. This concept is about 50 years old, five old, about 50 years old. But it really has taken hold in the past 25 years. The Food Safety Plan. This one comes, I would suggest, from the Food Safety Modernization Act. So again, we're looking at a concept that is no more than six years old. But we've heard that the Food Safety Plan or the preventive controls is really a new version of HACCP. So as we have experienced and used this concept of HACCP over the last 50 years, as we have applied it over the last 25 years, we've discovered some things. We've learned some things. So as we then take the next step forward with a piece of legislation such as the Food Safety Modernization Act, we add new features and we come up with a new topic, a new title, preventive controls, good manufacturing practices. What are some of those practices within our food facilities that hopefully help reduce the risk of unsafe food or good agricultural practices? Practices that producers use on their farm, on their ranch, in the feedlot, in the orchards. What are some of those agricultural practices or handling practices? As we prepare that fresh fruit for market, as we prepare the fresh vegetables for market, how do we handle them? And let's make sure that we again are doing whatever we can to reduce the risk. And how do these pieces all fit together? Sanitation standard operating procedures primarily applies to the meat industry. Standards for the produce of human consumption. It's again some terminology that arose with the Food Safety Modernization Act in the past six years. But this one is really, I would suggest, the latest generation of good agricultural practices and good handling practices. So we see these concepts continue to evolve, grow as we gain experience, as we run into some incidences and need to find some new solutions, but we end up with this alphabet soup. The food code, we perhaps have heard about that. It's a document prepared by the Food and Drug Administration. It's not enforced by the Food and Drug Administration. It's offered to local governments, state governments. Here are some standards local government, state governments that you might want to adopt rather than you at the local and state level having to take all the time to study and prepare your own ordinances and statutes. We at the FDA have prepared some for you. We offer them to you as suggestions. And please consider adopting them as your local ordinance or as your state laws. So we're going to talk a little bit about the food code. The grade A pasteurized milk ordinance. This one, again, doesn't come solely from government. It comes from industry working with government at the state and federal level, trying to come up with the code suggestions that the states might adopt as they keep an eye on the dairy industry. And then continuing the examples, the beef quality assurance program. It's industry driven. It's not government driven. But it is expectations within the industry of what do we hope these animals are the standards that they reach, the standards that the meat product reaches in order to be confident in the food that we're supplying to consumers. And SQF, again, I'm just picking a couple of examples here. This is far from an inclusive list, but the SQF is international and it's industry driven. It's also much more than food safety. When you look at the code, this industry code of the SQF, there's concerns about the environment, concerns about working conditions, concerns about sustainability. So it's much broader than the food safety that we find the government focused on when we talk about the U.S. food laws. So how do we bring all these pieces together? Such a collection of ideas and concepts. As I try to understand it, I find myself organizing this variety of entities, this variety of concepts into five broad categories. We begin with, well, it's almost a chain of events from where we start with our food industry and ending with consumers. So we have the suppliers of the inputs for our agricultural products. The next step in this chain of events then is the actual agricultural production that occurs on the farm and ranch in the orchard or wherever it is that we're raising our fruits, our vegetables, our grains, our livestock. Number three in this chain of events, at least in my definition, is processing. We're going to spend a lot of time on processing today because that seems to be the sector of the industry that catches the most attention. So we're going to, in a few moments, begin to explore these five links in the industry by discussing the processing sector. Once the product is manufactured, it moves to the retail, the food service, and ultimately to the consumer. So then we begin to put some of the pieces in these categories. What do we supply to the production agriculture? Well, there's the drugs that are used, the medicines that are used for our animals that are ultimately going to become a food product. Our beef cattle, our dairy cows, our swine. Try to make sure that we have some oversight of the drugs, the medications that are being used for those animals, and also the feed. We don't want unsafe feed that would cause the animal to be unsafe for food. So we are going to have some regulation, some oversight of the actual animal feed industry. Biotechnology, a lot of strong feelings one way or the other about genetically modified organisms and how they are used in our food industry. That biotechnology, we're going to see in a few moments, and as many of you perhaps already know, it's regulated. The pesticide tolerance. How much pesticide residue would be tolerated on our agricultural products and then ultimately in our food products? And again, bringing those plants and animals into the United States. Production Ag, we've mentioned some of these categories already. The fresh fruits, vegetables, the nuts, another subcategory or the dairy farms. And then we have all other agricultural commodities and we can't overlook the fisheries, the seafoods as well. Processing, we're going to have, well, we have that sector of the food industry, I would suggest, subdivided into a number of subcategories. We have the meat and poultry, processed eggs, mentioned those already. We know that those are overseen by the USDA. Many of these other categories are overseen by the Food and Drug Administration. But the fish is handled by the FDA, a little different than the juice is handled. And then it's handled a little different than the low acid food or the acidified canned foods. They're handled differently than infant formula. We have the collective category of all other foods. And then again, we have dairy. The retail and food service, just the two broad categories, but we know there's a lot more detail for each of these. Retail, the grocery stores, food service, fast food restaurants, cafeterias on a university campus, cafeteria in a hospital, the food service within a nursing home. Those all fall into this category of retail and food service. And then of course, the ultimate, the final step in the food, and that is the consumer. So just beginning to take some of these pieces, think about the pieces without going into a lot of the details today, but willing to take questions and trying to get them organized in a way that can we better understand how these variety of agencies, variety of concepts relate to the overall U.S. food laws. Just a couple of points before we go on. The food is subject to state government oversight in whatever state the food is located. Simple example, manufactured cheese in Wisconsin, and we're going to bring it to North Dakota. Put it on a truck in Wisconsin. The truck drives across Minnesota, reaches North Dakota. While that cheese is in Wisconsin, it's subject to oversight or regulation by the Wisconsin government, Wisconsin state government. Obviously, when it arrives in North Dakota, it's subject to oversight by North Dakota state government. But while that truck is driving through Minnesota, that cheese is subject to Minnesota law. So wherever that food is located, that state has authority to regulate that food, even if that food is passing just temporarily through the one state to reach the next state. So that's the state government, or general statement about state government. Where does the federal government come in? The FDA, the FDA has oversight over all food that crosses the state boundaries. We refer to that as interstate food, or food in interstate commerce. So once that food crosses a state boundary, the FDA's authority triggers. But it's broader than that. The definition of food isn't just that final food product, it's also the ingredients. So if I bring the spice from some other state, from some other nation, and I bring it into the state where I'm processing food, that spice, that flavoring is obviously an interstate commerce. And now because that one component of my food product is an interstate commerce, and that spice or that flavoring has been incorporated into the food that I'm manufacturing, all of my food product is considered an interstate commerce subject to the FDA. Of course, we know that the USDA, Congress 111 years ago, gave responsibility for meat, poultry, to the USDA. So we have these two broad categories, the FDA-USDA. USDA, Congress took a little different approach. Congress and its initial legislation, which holds true to today, says any meat and poultry, even if it has never crossed the state line, it's subject to USDA oversight. So review for just a moment. FDA has responsibility for the foods once they cross the state line, except for the meat and poultry. The meat and poultry are always under the USDA responsibility, and the USDA has responsibility even if that meat and poultry never crosses a state line. Again, fire off questions if you have questions. So obviously we have state laws that regulate food. We have federal laws that regulate food. If there's a conflict between a state law and a federal law, the federal law prevails. The federal law preempts the state law. That comes from the U.S. Constitution. That's the way the U.S. Constitution was written in the late 1700s when the United States was formed. So that's not a new concept. Well, if the federal law is going to preempt my state law, I might as well prepare my state law to be somewhat consistent with the federal law. If I write my state law to conflict with the federal law, the Constitution says the federal law is going to prevail. So I might as well take the time, try to make my state laws consistent with the federal law as possible. The food doesn't include just what us humans eat. We've already said that it includes the feed that is provided to our animals. It includes pet food. Whatever we buy for our dogs, our cats, those pet foods, they're subject to these food laws, just like the cans of beans or peas or the beef roasts that you might buy for this evening's meal. A couple of points that I should have had on this visual, and I failed to get them in here as I prepared my thoughts for today, but I'd like to add them now orally. U.S. Food Law regulates the food product. It does not necessarily regulate the facility. If there's a problem with the food product, the federal law, the state laws essentially address the food product itself. And then secondarily addresses the food facility. So when it comes to food law, the focus is on regulating the food product. As we continue this afternoon and we look at these different subcategories, we look at these different pieces of the puzzle, there's almost always a historical event that triggers these food laws. And you'll recognize some of those as we continue the next few moments. But I wanted to bring that point up to you, and I just want to reinforce also the industry expectations. It's not only the government regulations, which we hear so much about, we're going to be talking about, but we can't lose sight that the industry has expectations for the other firms that are providing the food products that we then process into whatever food product we are manufacturing for the market. Processing. This is again the beginning of our looking into the details of our puzzle. Processing is very broadly defined. There's requirements under federal law that if you're subject to FDA regulation, you must register your business, your facility with the FDA, and you must, most states require getting a license from the state. Or if you're meat and poultry and you're subject to USDA, you need to be approved for inspection by the Food Safety Inspection Service. The ingredients or the additives that we use in our food products, regulated by large part by the FDA. And then we need to again verify the supplier that's providing us the ingredients or the add commodities or whatever it might be that we're using in the manufacture of our food products. So keeping track of if this food's hopefully safe. Of course, the business also is interested in making sure that this commodity will produce a quality food product. But when it comes to the law, we're focused on the safety. So verify the supplier, standards for the products, are the facilities clean, cleanliness, is the equipment such that it won't contaminate the food. Again, the focus is on let's make sure the food is safe, but the food might become unsafe because of where the food is being stored, how the food is being transported, where the food is being manufactured. It's at that point that we begin to look at the facilities and the equipment. First we think about the food, but then we realize that the facilities and the equipment can impact the safety of that food. GMOs, the SSOPs introduced those under the concepts a few moments ago. What are the practices that we use for our food manufacturing? Also within this broad definition of processing is defense or security to protect our food from an intentional attack. Because we don't want somebody coming in and contaminating our food product. My colleague tells the story of working with a dairy farmer in Minnesota who had a dispute with his neighbor. And the dairy farmer found that his milk wasn't acceptable for processing. He eventually set up cameras and sure enough in the dark of night, literally in the dark of night, the Minnesota neighbor was coming on to the Minnesota dairy farm and contaminating the milk. This defending our food product isn't just international terrorists. It sometimes can be an upset employee, it can be an upset neighbor. So we need to take steps to make sure that our food is as safe as possible. Being ready for inspections, whether those inspections are coming from a federal agency or from a state agency. Likewise, we're seeing the industry audit one another. If you expect me to buy your product, I want an opportunity to audit your operation. So I'm confident that what I'm buying from you is going to be safe for my product. So it's not only government inspection, it's becoming industry audits as well. The packaging, the labeling, making claims about the food. Our food, if you consume it, will help you lower your blood pressure. Okay, which of those claims are legitimate? The FDA has strict regulations on the claims that can be made and the claims that are not allowed. Advertising, what type of claims can you make in advertising? Likewise, we don't want anything that misleads the consumers. That's what Congress said, that's what the FDA and the USDA tried its best to reinforce. Keeping records, how were these food products handled? How were they manufactured? And you need the records to show to the agency inspectors as well as to industry auditors. This is how the food product was handled while it was under my control. Training employees, if I want to import food products, need to provide notice to the FDA so that the Custom and Border Protection is aware that it's coming. FDA's in communication with that second agency, Custom and Border Protection. And then the Custom and Border Protection knows to be looking for those food imports or if we want to export food, a certificate that this food has been subject to U.S. oversight before it is shipped out of the U.S. And hopefully that gives more confidence to the nation that's buying the food from us. Transportation, storage, we don't want these products to be in dirty facilities. The federal law says, as passed by Congress more than 100 years ago, if the food is in a dirty facility, even if the food is safe, it's still considered illegal to sell, it's considered adulterated. Just being in a filthy facility, even if it does not contaminate the food, it renders the food illegal for sale. So just a long list there to help us understand the breadth of the definition of processing. But now we need to do some subdividing. Within that processing, the first subcategory, meat and poultry processed eggs, we've already said the Food Safety Inspection Service of USDA is responsible, and the USDA uses the SSOPs and HACPs as the standards for those products. So now we're beginning to see, again, some of these pieces sitting together. But the state is involved. In North Dakota it's the Department of Agriculture. Whatever agency it is, by the way, only about half of the states are involved in meat inspections. The other half of the states, they just rely exclusively on USDA. North Dakota is one of those states that we rely on both state and federal inspection, and it happens to be the Department of Agriculture. But in order for the Department of Agriculture to inspect the meat in North Dakota, it needs to be approved, the inspection process needs to be approved by the USDA. Then we begin to continue down the list, and we look at where the FDA is involved. Fish and fish products, FDA is responsible. FDA has HACP regulations and good manufacturing practices, and some of us can remember when fish, there was such a concern about 30 years ago about the safety of our fish products. Congress responded by saying, FDA, you need to regulate those fish products. Juice, much the same happened in the past. That we had some concerns about juice, that juice, somebody called it juice, but it was diluted and was down to no more than 10% juice, but it was still being called juice. So Congress came back saying FDA regulated, FDA said we'll use HACP, and we're going to use some good manufacturing practices as well as some SSOPs to lay the details or the foundation for this juice regulation. The low acid, the acidified canned foods, I remember these from decades ago, and I was a youngster of that botulism. So FDA, Congress said, let's get some regulations in there. FDA, get some regulations there, and some people say that those regulations, even though they're several decades old, they're not much different than HACP. Infant formula, in the 70s and 80s, a lot of international concern about infant formula. Congress has a response in the United States, plus FDA, you need to set forth some good manufacturing practices. And by the way, this time Congress said not only for the safety of the product, but also the quality of the product. We want to make sure that these infant formulas have the nutrition necessary for those young people, those young bodies, our little babies. And then we have the overall, sort of catch-all, all of the food products. And there the FDA has responsibilities using the good manufacturing practices. And now in the last six years with the Food Safety Modernization Act, the preventive controls. What's going on at the state level? Looking at the right-hand column, we're seeing that the state agency is involved as well. We mentioned that a few moments ago. Any food in the state is regulated by the state. But here the state is primarily applying that food code that the FDA has prepared and shared with the state and local government. It comes to dairy processing. Okay, it's a way different approach. The state has primary oversight, but the FDA has responsibility according to Congress for the interstate transport of milk. And then the state is looking at that pasteurized milk ordinance that we briefly introduced. And that ordinance was a combination of the industry working with state government, working with federal government. So we have these different pieces in the processing sector coming together. The puzzle does come clear once a person has a chance to think about the pieces. Now I've deleted some of the information from the previous slide, and I just want to focus on the bottom two lines on this particular slide for only a minute. And that is to reinforce when it comes to those imported foods, the standards for those foods come from the FDA as well as the Food Safety Inspection Service, depending on whether you're talking about meat and poultry or you're talking about some other food. And then those are enforced by the Customs and Border Protection Agency. The pet food, the standards comes from the FDA Center for Veterinary Medicine, and there needs to be a food safety plan for those pet foods. So we're seeing some of these pieces come together, some differences among these different segments, but also some consistencies. At the retail level, now we're finally stepping out of the processing, and we have the two broad categories, the retail, the food service. There again, it's almost exclusively state regulation, heavily reliant on the food code that was prepared by the FDA and offered to the states. Nearly all states have adopted the food code. The municipal government is also involved with oversight of the retail and food service. Food advertising, the FDA sets forth the standards and the Federal Trade Commission enforces them so we can again begin to see the pieces coming together. But when it comes to the retail and food service, the bottom line to take away is it's state government and it's heavily the food code. We spend several days talking about the food code. I'm not going to go into that detail today. I'm just going to mention some of these broad concepts. Some real quick questions. If I'm a North Dakota jam maker and I want to sell my jams in Montana, who regulates me? Time for you to type in some quick answers. Just think about it for a moment. You're manufacturing food in North Dakota, processing food. You want to sell it in Montana. Who regulates your food product? Any answers coming into the chat room? Both states. Both states. That's correct. While that food is being processed in North Dakota, why that food is located in North Dakota, North Dakota certainly has responsibility over that food. Once it crosses the state line, technically the Food and Drug Administration now has authority as well. But if we're talking about a relatively small business, the FDA is going to stand back. It's going to let the states take care of it. If a problem arises and it looks like it's going to be a substantial problem, the states are probably going to call on the FDA to become involved. But the answers of both states, that's a good way to answer the question. Or another question. I produce cheese. Again, relatively small business. I want to start marketing it over the Internet. So I'm hoping to reach a much broader audience. Who regulates my business, my cheese business? Any answers? FDA? Anyone else? Dairy is complex. Your dairy processing is primarily at the state level. The Department of Ag in North Dakota, for example, works with the cheese manufacturing. Yes, the FDA has a role with the forming, the codes, setting the standards for the food product. But much of the oversight is still at the state level. Talk about that one a little bit more. That one is always complex. That dairy industry was one of the first industries to be regulated. Well, let me give you a quick statement. Federal US Food Law first arose in the early 1900s, 1906. But before 1906, in the 1800s, and even before that, our local governments were concerned about dairy. So the dairy industry has a strong, long history that is local regulation. Going to jump forward now, production agriculture. The fresh fruits and vegetables, as they move directly from the farm to the retail, the last person to handle that fresh fruit, fresh vegetable, the nuts before it reaches the retail outlet is the producer. It's not going to go through a processor. So Congress, with the food safety modernization access, we need to make sure that those producers are handling those fresh fruits and vegetables as safely as possible. And FDA, you have the responsibility for overseeing what's going on in those packing facilities. And yes, we had some problems in the 80s, the 90s. We probably recall some of those problems. Congress responded with the Food Safety Modernization Act says, okay, producers, you're going to have to meet some standards. Those standards are going to come from the FDA. The dairy farms, again, awful lot of it is at the state and municipal level. But it's underpinned by the pasteurized milk ordinance, the other agricultural commodities. They're graded, but they're not assessed for the safety. Is this grain going to produce flour that's safe to be used in bread? The government doesn't get that involved with that small portion of the industry. It's more from the industry imposing standards on itself. I'm not going to buy your wheat. I'm not going to buy your flour unless you can convince me that your product meets the standards that I need for my ultimate food product. Fisheries, Department of Commerce, working with the Food and Drug Administration. Again, removing some of the information from the previous slide and just adding a line at the bottom, organic foods, USDA Ag Marketing Service, responsible for overseeing from the production practices on the farm to the food product labeling. The input suppliers for production ag, the drugs for our food animals, the Center for Veterinary Medicine under the FDA, the feed for our food animals is also regulated by FDA, need HASAP, essentially HASAP standards, Biotechnology, FDA asks the question whether or not this new technology be safe for food. USDA at the same time is asking whether or not this new technology will harm existing plants and animals, and the EPA is asking at the same time whether or not this technology, this GMO, will have an adverse impact on the environment. So the three agencies work together in overseeing biotechnology. The pesticide tolerance, the EPA sets the standards, and the FDA enforces them. How much pesticide will we tolerate in our foods, on our crops, on our ag commodities, and the FDA then enforces those tolerances on the food products. The imported plants and animals, we've already talked about that, so we can move on. And we get to the consumers. We don't regulate consumers, we educate them, we inform them. And a lot of that important information comes from the labeling. And of course the consumers have the legal right to bring an action against someone that provides an unsafe food. So don't want to have that reputation of providing unsafe food. Don't want to run the risk of being liable for an ill consumer. Try my best to make sure my food product is safe, but we do not regulate the consumers. One more quick question. I'm the manager of an elevator in rural North Dakota. I buy grain, buy wheat, for example. I sell bags of animal feed to livestock producers. Is my business subject to federal regulation? Any quick answers? The answer is yes. And to the extent that that business is, or those products are subject to federal regulations, is primarily under the FDA. I see I have a question here. Why is it that I can buy raw milk in South Dakota but not in North Dakota? Those are differences in state laws. That dairy industry is regulated at the state level. And you're going to find that there's differences in the state laws. Those are not federal laws. So South Dakota apparently has a statute that says, yep, we'll tolerate the raw milk. And North Dakota says, nope, we're not going to tolerate the raw milk. We want to have that milk pasteurized before it's sold. There's exceptions to that. But it is an example that the dairy industry is regulated more at the state level than at the federal level. Are there other questions? Just to close out real quickly, don't overlook the international standards. We've mentioned the Codex briefly. We've mentioned the SQF and good agricultural practices. Europe follows good agricultural practices, perhaps more than North Dakota does, or should I say has standardized them, enforces them more strictly than the United States. But don't overlook those standards from around the world. We certainly have the beef quality assurance program in the United States, but that's driven more, again, by the industry than by government. So my closing thought for you this afternoon, as we look at the pieces of the puzzle, I would encourage you to think about that food industry as perhaps five links, numerous pieces within each of those links. When I am asked a food law question, I try to identify which of these five links this question applies to. I then try to identify the laws or the standards that would be relevant for that particular food product, whatever it is that you're thinking about. And then I try to identify the government agency or the industry organization that would have those standards, and that would be interested, be responsible for making sure those standards apply. So that's my closing thought. Any questions or comments from anyone? Any questions? Well, it looks like you're off the hook, Dave. Thank you so much for providing this webinar. It's a very complicated subject, and you really pulled us through a lot of information. One final plea for me. You will be getting a survey by email, so please go ahead and fill that out. And in that survey, I think you also have the option of giving us ideas for future webinars. So thank you again, everybody, and hope to see you all next week. Thank you, everyone.