Page 95 - Winter2014

sive and often ambiguous requirements in both or conduct associated with the qualified [farm or facility] that are mate-
proposed rules leave plenty of room for alleged rial to the safety of the food manufactured, processed, packed, or held at
violations that are in the eye of the beholder, such [farm or facility].” The agency would then notify the producer of this
namely the local FDA inspector. finding, without being required to specify what the alleged problems are,
Many of WAPF’s comments on the proposed and the producer would have only ten days to respond.
rules focused on the ambiguities and potential Under the proposed rules, the agency can choose whether or not to
avenues for abuse. In particular, the provisions provide a hearing before it makes its final determination. And once the
that govern FDA’s ability to revoke a producer’s FDA makes a final decision to revoke the exemption, the farmer or facil-
Tester-Hagan exemption are very problematic. ity would then have only sixty or one hundred twenty days (depending on
As proposed by FDA, a local inspector can which rule) to come into full compliance with the extensive, expensive
simply allege that revocation “is necessary to FSMA requirements. In practical terms, almost any small producer tar-
protect the public health and prevent or mitigate geted in this way would go out of business. While FDA is unlikely to use
a foodborne illness outbreak based on conditions this power often, even a few cases of arbitrary revocations could create a

BACK ISSUES OF WiseTraditions AND OTHER INFORMATIVE LITERATURE
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Winter 2007 Children’s Issue: Gut and Psychology Syndrome; Vitamins for Fetal Development, Traditional Remedies.
Summer 2010* Activator Update; Holistic Treatment for Allergies; Acid Reflux; Dangers of Root Canals; Soul Food Recipes.
Fall 2010 Essential Fatty Acids; Magnesium; Healthy Skin; Sacred Foods for Children; Tale of Two Calves.
Winter 2010 Joel Salatin on the Politics of Food; Saving the Polish Countryside; Biological Farming; Bitters; Glutathione in Raw Milk.
Spring 2011* Liver Health; Vitamin B6; USDA 2010 Dietary Guidelines; Good Breakfasts; Stoneware; Cheese is Serious.
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Spring 2012* Good Fats, Bad Fats; China Study Myth; Salt and Our Health; Sustenance from Soup; Soy and Thyroid Cancer.
Summer 2012 Nutrient Deficiencies from Drugs; Vaccination Update; Raw Milk Microscope Study; GAPS Diet for Mental Illness.
Fall 2012 Vitamin & Mineral Synergies; California's Ancient Cornucopia; All About Bacon; The Raw Milk Institute; Tooth Decay.
Winter 2012 Vitamin A Synergies; The Story of Zinc; Natural Skin Cream; Slovenian Soups and Stews; Soy Infant Formula.
Spring 2013 Nutritional Roots of Violence; Glycine for Mental Stability; Pork Study; Homeopathy for Mental Illness.
Summer 2013 Our Broken Food Supply; The Marketing of Crisco; GMOs in Europe; Insights of a Meat Processor; Natto.
Fall 2013 GMO Dangers; RoundUp Dangers: Culinary Traditions in Romania; The Battle for the People's Milk.
Winter 2013 Beyond Cholesterol; Cancer as a Healing Strategy; Grain Traditions in Russia; Push to Pasteurize Breast Milk.
Spring 2014 Dr. Price's Scientific Approach; Weston Price and the Fluoridationists; Cows and Climate; Economics of Raw Milk.
Summer 2014 Nutrition for the Elderly; A New Look at Alzheimer's Disease; In Defense of Wheat; Dangers of Vegetable Oils.
Fall 2014 What Causes Heart Attacks? The Myogenic Theory of Heart Disease; Thrombi in Heart Disease; Liver Detoxification.

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