National Agriculture Law Update

National Agriculture Law Update

Tennessee College of Law’s Agriculture Law & Policy Symposium

October 9, 2015

By Cari B. Rincker, Esq.

My Background• Grew up on a beef cattle farm

in Central Illinois• Education– A.S. in Agriculture from Lake Land

College– B.S. in Animal Science from Texas

A & M– M.S. in Ruminant (Beef Cattle)

Nutrition from University of Illinois

– J.D. from Pace Law School (2007)

My Background

• Chair of the American Bar Association, General Practice, Solo & Small Firm Division’s Agriculture Law Committee

• New York & Illinois Offices• My food and agriculture client

base– Farmers to ranchers– Small to mid-size agri-business– Food entrepreneurs

Overview• Veterinary Feed

Directive• WOTUS• Syngenta Litigation• Food Labeling– Vermont GMO Labeling

Litigation– COOL

Overview• Food Safety– Raw Milk – FSMA

• Idaho “Ag Gag” Litigation

• Cannabis Law • Farm Bill

Veterinary Feed Directive

Definitions

Antibiotic

• Can inhibit the growth of bad bacteria that cause infections and illness.• Antibiotics belong to a class of drugs called “antimicrobials.”

Antimicrobial

• Any substance of natural, semisynthetic or synthetic origin that kills or inhibits the growth of microorganisms but causes little or no damage to the host.

• All antibiotics are antimicrobials, but not all antimicrobials are antibiotics.

The PlayersU.S. Department of Agriculture (“USDA”) regulates antibiotics in meat, poultry, and eggs via two sub-agencies.• Food Safety Inspection Service (“FSIS”) (Primarily)• Agriculture Marketing Service (“AMS”)• Animal and Plant Health Inspection Service (“APHIS”)

Food & Drug Administration is an agency of the Department of Health and Human Services (“HHS”).• FDA regulates food and drugs in livestock animals excluding meat, poultry, and eggs (regulated by

USDA). • Center for Veterinary Medicine (“CVM”) is a sub-agency which oversees the safety and

effectiveness of animal drugs and the approval process.

Centers for Disease Control and Prevention (“CDC”) is also under the HHS umbrella and safeguards health by monitoring antibiotic resistance.• National Antimicrobial Residence Monitoring System (“NARMS”) is a sub-agency of the CDC

composed of the FDA, CDC, USDA’s FSIS.

Approval of Antibiotics

FDA Must Approve Antibiotics • Federal Food, Drug, and Cosmetic

Act (“FFDCA” or “FDCA”) prohibits an animal drug to be sold into interstate commerce unless is has been approved by an Approved New Animal Drug Application (“NADA”).

• FDA does approve the use of antibiotics in livestock and must approve all antibiotics (for humans, animals, and livestock). See 21 CFR § 530.

• This requirement still exists with VFD.

Background

Prior to 1996, FDA had 2 options for distributing animal drugs:• Over-the-Counter (“OTC”) • Prescription (Rx)

Federal Food, Drug and Cosmetic Act (“FDCA”) didn’t require prescriptions for animal feeds.• Viewed as being impractical because

feed mills would need to have a pharmacist onsite to dispense prescription drugs; thus feeds were OTC.

Background

Statutory History

•In 1996, Congress enacted the Animal Drug Availability Act (“ADAA”) to facilitate the approval and marketing of new animal drugs and medicated feeds.•This law created a new regulatory category for animal drugs used in animal feed – veterinary feed directive (“VFD”) drugs.

•First VFD Rule by Food & Drug Administration (“FDA”) was published in the Code of Federal Regulations in 2000.•The Second VFD Rule was published on June 3, 2015.

Background

Under ADAA, VFD drugs are new animal drugs intended for use in or on animal feed, which are limited by an approved application, conditionally approved application or index listing to use under professional supervision of a licensed veterinarian. • VFD drug requires a VFD

document by licensed veterinarian who authorizes the use.

Background

Currently there are a few VFD drugs (mostly OTC).

• FDA received responses saying that the VFD process was overly burdensome.

• FDA also received public comment about public health, use of antimicrobials/antibiotics in meat producing animals, and concern for antibiotic residence.

• New VFD “responded” to these concerns.

Background

A VFD is a written statement issued by a licensed veterinarian in the court of the veterinarian’s professional practice that orders the use of a VFD drug or combination VFD drug in an animal feed.• This authorizes the livestock

producer to obtain and use animal feed bearing or containing a VFD drug or combination VFD drug to treat the producer’s livestock in accordance with the approved, conditionally approved application or index.

BackgroundThe final rule published in June 2015 on VFD is the third of three core

documents that the FDA is using on its judicious use policy for antibiotics.

Publication 1: Guidance for the Industry (GFI) #209 “The Judicious Use of Medically

Important Antimicrobial Drugs in Food Producing Animals”

Publication 2: GFI #213 “New Animal Drugs and New Animal Drug Combination Products Administered in or on

Medicated Feed or Drinking Water of Food-Producing Animals: Recommendations for Drug Sponsors for

Voluntarily Aligning Product Use Conditions with GFI #209”

Stakeholder Requirements

Veterinarians

Livestock Producers

Feed Distributors

Drug Manufacturers

Veterinary Requirements

Must be in compliance with the state’s veterinarian-client-patient relations (“VCPR”) requirements.

• Engage with livestock producer and assume responsibility for making medical judgment about the animal’s health.• Have sufficient knowledge of the animal by virtue of examination and/or visit the facility where the animal is

managed to initiate a preliminary diagnosis.• Provide for any necessary follow-up evaluation or care.

If state doesn’t require a VCPR then FDA now requires that the VFD be issued within context of Federally defined VCPR, which requires:

21 CFR 558.6(b)


The veterinarian must also provide a written

veterinary feed directive (“VFD”).

The VFD must be in compliance with the

conditions for approved use, conditionally

approved use or indexed use under the ADAA.

21 CFR 558.6(a)


Extra-labeling Use is not permitted • i.e., Use of feed containing a

VFD drug in a manner other than as directed on the label is not permitted.

21 C.F.R. 558.6(a)

Veterinary RequirementsVFD Information

Required information

Optional information


•Vet’s and livestock producer/client’s •Name•Address•Telephone number•Premises at which the animals are located•Date of VFD issuance•Species and production class of animals to be fed the VFD feed

Required

Information


VFD must include the name of the VFD drug.

• Could be the generic name.• Can state that a substitution drug isn’t allowed (optional info). • If substitution is allowed then the feed distributor may choose

to substitute if the generic VFD is part of an approved combination.

21 CFR 558.6(b)


VFD must include an expiration date.

• The vet can write a date up to 6 months from the date the VFD is initiated.

• Duration determines the length of time the VFD is allowed to be fed to the animals as specified on the product label.


VFD Must Include

•Approximate number of animals to be fed by the expiration date of the VFD•Indication for which the VFD is issued •Drug level and duration of use•Withdrawal time•Special instructions/cautions•Number of reorders (refills) authorized – if permitted by the drug approval


VFD Must Include this Statement

• “Use of feed containing this veterinary feed directive (VFD) drug in a manner other than as directed on the labeling (extralabel) is not permitted.”


VFD must include:

• An affirmation of intent for combination VFD drugs

• Veterinarian’s electronic or written signature


VFD must include premises ID but may include more information about the animals.

• This is so someone can locate the animals, if needed.• May include specific information, such as the pen or description

of where the animals are currently located.• If the VFD is intended to authorize the use of a VFD feed in a

group of animals that are located at more than one physical location, then the VFD can specify more than one pen so long as the feed is supplied by a single feed distributor.

Veterinarian Requirements

VFD may provide the following additional information:

• Approximate age/weight range of the animals

• Any other information the veterinarian deems appropriate to identify the animals specified in the VFD


Importantly, is not a uniform rule for the Veterinary Feed Directive (“VFD”).

• Just needs to meet the requirements promulgated in the regulations.

• Advised that veterinarians have an attorney review for compliance.

Veterinarian Requirements

Copy of the VFD must go to the client (producer) and feed distributor.

• Can be delivered hard-copy, facsimile or electronic (e.g., email).

• Transmitted to the distributor and client gets copy

Must maintain VFD records for 2 years.

• Must retain original VFD. • Other segments can keep copies but VFD must keep

original.

21 C.F.R. 558.6(a)

Producer Requirements

Feed animal feed containing a VFD drug only to animals based upon a duly issued VFD from a licensed veterinarian.

• Keep copy in original form (hard copy v. original).• Must be available for inspection and copying by

FDA upon request.

Maintain all VFD records for 2 years.

21 CFR 558.6(a)

Producer Requirements

Prohibited from feeding a VFD after an expiration date.

• The expiration defines the period of time for which the authorization to provide an animal feed containing a VFD drug is lawful.

• Expiration date specifies the last day the VFD feed can be fed to a group of animals.

Feed Distributor Requirements

Shall only provide a VFD feed if the VFD contains all the required information and conforms to product approval.

• Keep copy in original form (hard copy v. original).• Must be available for inspection and copying by FDA upon request.• Note that manufacturing records only need to be kept for 1 year

under 21 CFR Part 225 if distributor also manufacturers.

Maintain records for 2 years. 21 CFR 558.6(c)


Provide one-time notifications

• To the FDA of the distribution of VFD feeds stating that it intends to handle/distribute VFD drug-containing medicated feeds.

• Acknowledgment of distribution limitations for VFD fees that the purchasers will sell the VFD feeds only to producers with valid VFD orders or to other distributors for whom they have acknowledgement notices.


Notification must include:

• Distributor’s name and business address• Distributor’s signature (or agent’s signature)• Date the notification was signed

Must notify FDA within 30 days of any change in ownership or business info.

• Must send notification to FDA, Center of Veterinary Medicine, Division of Animal Feeds.


If the distributor is distributing the VFD feed to another distributor,

then an acknowledgement letter must be sent from the receiving

distributor under 21 CFR 558.3(b)(11) before shipment of feed.

Consigner distributor must retain copy of acknowledgement letter for 2 years.

Drug Manufacturers

All labeling and advertising for (combination) VFD drugs, feeds containing (combination) VFD drugs must have the following cautionary statement:

“Caution: Federal law restricts medicated feed containing this veterinary feed directive (VFD) drug to use by or on the order of a

licensed veterinarian.”

21 CFR 558.6(a)

FDA Enforcement

General surveillance and

for-cause inspection

assignments

Effective Date Clarification

This second VFD rule becomes effective on October 15, 2015 for

presently approved VFD drugs.

Effective for OTC drugs switching to VFD status under GFI #213 when those drugs change status.• Current target is January 1, 2017.

Waters of the United States (“WOTUS”)

WOTUS Litigation• Rapanos v. United States, 547 U.S.

715 (2006)– Facts: John Rapanos sought to fill in

three wetland areas on his property in order to build a shopping mall. He was warned by Michigan Department of Environmental Quality that the area was federally protected land, which he ignored along with a cease-and-desist order from the U.S. Environmental Protection Agency, which resulted in a civil suit against him by the United States.

WOTUS Litigation• Rapanos v. United States, 547 U.S.

715 (2006)– Argument: Rapanos argued that the

Clean Water Act gives government jurisdiction to regulate only traditionally navigable water, while the government argued that Rapanos’s lands were covered by the CWA as “adjacent wetlands.” The District Court upheld the government interpretation of the Act.

WOTUS Litigation• Rapanos v. United States,

547 U.S. 715 (2006)– Appeal: The case was

appealed to the Supreme Court of the United States where in a 5 to 4 opinion the Supreme Court held that: the definitional term “waters of the United States” can only refer to “relatively permanent, standing or flowing bodies of water,” not “occasional,” “intermittent,” or “ephemeral” flows.

New Rule to Define WOTUS

• The rule, published on June 29, 2015 and becoming effective on August 28, 2015, identifies six types of waters that are categorically within federal jurisdiction and two categories of water for which a case-by-case determination is required.


Case-by-case analysis is required if the water in question is either:

• a member of a series of named formations such as prairie potholes, Carolina and Delmarva Bays, pocosins, western vernal pools in California, or Texas coastal prairie wetlands; or

• a water body that, due to its location within a certain distance from a high tide or high water mark of a jurisdictional water, has a “significant nexus” to that water.


Having a significant nexus means “that a water, including wetlands, either alone or in combination with other similarly situated waters in the region, significantly affects the chemical, physical, or biological integrity of [waters used in interstate or foreign commerce, interstate waters, and the territorial seas].”


•On August 28, 2015, the new WOTUS Rule went into effect in all states except 13, where a federal district court in North Dakota granted a preliminary injunction blocking the implementation of the new rule.•The 13 states (Alaska, Arizona, Arkansas, Colorado, Idaho, Missouri, Montana, Nebraska, Nevada, New Mexico, North Dakota, South Dakota, and Wyoming) claimed that the new WOTUS rule is a threat to state sovereignty because it asserts federal jurisdiction over wetlands and waters that should be subject to state government control.

Temporary

Injunction of WOTUS

Rule

Syngenta Litigation

Syngenta Litigation

• In 2013, China refused to accept shipment of corn that contained Syngenta’s MIR 162 trait because the GMO had not yet received a safety certification due to incomplete submission of materials and statistics by Syngenta.

Syngenta Litigation• China rejected 887,000 tonnes of

US corn shipments due to the presence of MIR 162 trait.

• This loss of China as a trade partner caused a decrease in demand in the United States for corn.– This arguably caused a decrease in

the market price of all U.S. corn, regardless of its variety and who the corn seed was bought from.

– Allegedly causing more than $1 billion in losses for US farmers.

Syngenta Litigation

•Cargill v. Syngenta•Trans Coastal v. Syngenta

Lawsuits by Companies

•U.S. farmers have also filed a class action lawsuit against Syngenta in federal courts in 11 states – consolidated into Kansas case and waiting for class certification.

Lawsuits by Farmers

Food Labeling Laws

Food Labeling Update

GMO Labeling

• Vermont Litigation• GMO Labeling bills

mCOOL

Vermont Litigation

In April 2014, the Vermont State Legislature passed a bill that will go into effect in July 2016 that requires that all food sold within Vermont be labeled stating that it contains GMOs.• The law also prohibits manufacturers from advertising or labeling foods that

contain GMOs as “natural” or “all-natural.”

Vermont Litigation

Challenge to Vermont Law• In June 2014, the Grocery

Manufacturers Association, the Snack Food Association, the International Dairy Foods Association, and the National Association of Manufacturers filed a lawsuit in federal court in Vermont challenging the constitutionality of Vermont’s law.

Vermont Litigation• Challenge to Vermont Law– The lawsuit claims that the Vermont GMO labeling law is:

• Unconstitutional under the First Amendment • Unconstitutional under the Commerce Clause• Preempted by the Federal Food, Drug, and Cosmetic Act

(“FFDCA”), the Nutritional Labeling and Education Act (“NLEA”), the Federal Meat Inspection Act (“FMIA”), and the Poultry Products Inspection Act (“PPIA”)

– The lawsuit also claims that the ban on “natural” labeling is unconstitutional under the First Amendment and Commerce Clause as well.

Vermont Litigation• On April 27, 2015, US District Court in

Vermont issued a decision that mostly favored the State of Vermont and those in favor of labeling GMO-containing foods.– First Amendment Claim– Commerce Clause Claim– Supremacy Clause Claim – “Natural” Labeling Prohibition

Vermont Litigation

Second Circuit Appeal

• On June 24, 2015, the Grocery Manufacturers Association and other plaintiffs appealed the decision of the District Court in the Court of Appeals for the Second Circuit arguing that the District Court erred in concluding that the labeling mandate was constitutional and in failing to grant an injunction.

• Oral argument was on Oct. 8, 2015.

GMO Labeling Legislation

Federal GMO Labeling Bill• In July of 2015, the U.S. House of Representatives passed a bill that would block any

mandatory labeling of food with genetically modified organisms, including pre-empting Vermont’s state law that goes into effect in 2016.

• The U.S. Senate has yet to vote on the bill.

Conditional GMO State Law

Connecticut•In June of 2013, Connecticut became the first state to mandate labeling of foods that contained GMO ingredients. •Section 3 of the Bill states that this law only goes into effect if four other states also enact mandatory labeling of foods containing GMOs that are consistent with Connecticut’s statute.

Maine•In January 2014, Maine enacted a GMO labeling food statute that requires at least five other states to enact similar legislation or states that total a population of 20 million people.

Country of Origin Labeling• Food products covered by

the law are:– Muscle cut and ground meats

(beef, veal, pork, lamb, goat, & chicken)

– Wild and farm-raised fish and shellfish

– Fresh and frozen fruits and vegetables

– Peanuts, pecans, and macadamia nuts

– Ginseng

Country of Origin Labeling

In October 2014, the World Trade Organization ruled in favor of Canada and Mexico in a dispute over COOL on meat.

• The WTO stated that these rules unfairly discriminate against meat imports and give advantage to domestic meat products.

• However, the WTO Compliance Panel did state that the labels provide U.S. consumers with information regarding source of meat therefore dismissing Canada and Mexico’s claim that the labels did not serve their intended purpose.

Country of Origin Labeling

After the October 2014 ruling, the United States appealed the WTO decision, which was rejected by the WTO in May 2015.

In June 2015 following the WTO ruling, the U.S. House of Representatives passed a bill to repeal COOL for beef, pork, and chicken in order to avoid possibly $3.6 billion in tariffs imposed by Canada and Mexico in retaliation. Will likely face opposition in the Senate.

Food Safety Laws

Food Safety

• Raw Milk• Peanut Corporation

of America Trial• Food Safety

Modernization Act

Food Safety• Raw Milk– The federal law prohibits

dairies from distributing raw milk across state lines in final packaging, i.e. ready for consumption. • It may only be distributed

across state lines if it is going to be pasteurized or used to make aged cheese.

Food Safety

• Raw Milk– The sale of raw milk is

completely prohibited in 18 States.• Alabama, Delaware, Florida,

Georgia, Hawaii, Indiana, Iowa, Louisiana, Maryland, Michigan, Montana, New Jersey, North Carolina, North Dakota, Ohio, Virginia, West Virginia, Wyoming

Food Safety

• Raw Milk– 17 states restrict sale of raw

milk only to the farm where milk is produced along with specific labeling.• Alaska, Arkansas, Colorado,

Illinois, Kansas, Kentucky, Massachusetts, Maine, Missouri, Mississippi, Nebraska, New York, Oregon, Oklahoma, Tennessee, TEXAS, Wisconsin

Food Safety

• Raw Milk– 16 states allow sale of raw

milk at retail stores separate from farms where milk was produced with appropriate labeling.• Arizona, California, Connecticut,

Idaho, Maine, Missouri, New Hampshire, New Mexico, Nevada, Oregon, Pennsylvania, South Carolina, South Dakota, Utah, Vermont, Washington

Food Safety

Litigation with Raw Milk

Organic Pastures v. U.S. Food and Drug Administration

In 2012, the U.S.’s largest raw milk dairy sued the FDA for failure to respond to petition by Organic Pasture to have law changed banning sale of raw milk across state lines.

Lawsuit v. Claravale Farm Company

In April 2015, a Santa Cruz, CA resident commenced a lawsuit against Claravale Farm Company after he became ill with Campylobacter bacteria from drinking tainted raw milk that led back to Claravale’s dairy.

Food Safety

• Peanut Corporation of America Trial– In 2008, a salmonella

outbreak traced back to peanut butter manufactured by the Peanut Corporation of America, which killed nine people and sickened 714 across 46 states.

Food Safety

• Peanut Corporation of America Trial– In September 2014, after a

seven week jury trial, the former CEO of Peanut Corporation of America, Stewart Parnell, and his brother, Michael Parnell, were found guilty of 76 counts linked to intentionally shipping out salmonella contaminated peanuts

Food Safety

• Peanut Corporation of America Trial– In September 2015, Steward

Parnell was sentenced to 28 years in prison for knowingly shipping out deadly food.

– Michael Parnell was given a 20 year sentence, while Mary Wilkerson, the plant’s quality assurance manager, was sentenced to five years.

Food Safety

Food Safety Modernization Act (“FSMA” pronounced “Fiz-ma”)

• FSMA was signed into law on January 4, 2011 with purpose of overhauling the United States’ safety oversight system.

• FSMA requires facilities that produce and sell food to be registered and it provides regulations for facilities to ensure food is processed and sold safely.

Food Safety

FSMA

• Analysis of hazards and risk-based preventative controls • FSMA creates a food safety plan that “food facilities” follow for identification of hazards in food and preventative

controls to ensure hazards are treated properly.• FSMA also provides for oversight and management of the preventative controls requiring that processes to kill

pathogens are monitored with appropriate temperatures being carefully monitored. • FSMA requires that a plan be in place for disposing of foods that are discovered to contain hazardous pathogens.

Food Safety

Primary Producing Farm

“Operation under one management in one general, but not necessarily contiguous, location devoted to the growing of

crops, the harvesting of crops, the raising of animals (including seafood), or any combination of these activities”

This also includes farms that can pack or hold raw agricultural commodities, such as fresh produce, and some

manufacturing/processing activities such as dehydrating grapes for raisins.

Definition of “Farm” (exempt)

Idaho “Ag Gag” Law

Overview of “Ag Gag” Laws

“Ag gag” refers to anti-whistleblower laws that restrict

employees from taking photographs or videos illustrating alleged cruelty to animals, food

safety issues, and/or poor working conditions, during the farming process and/or restrict

people such as activists and undercover journalists from

obtaining illegal access (commonly through job application fraud) onto

agricultural operations for this same purpose.

Other Existing “Ag Gag” Laws

Kansas

North Dakot

a

Montana Iowa Misso

uri Utah Arkansas

Idaho’s “Ag Gag” Law• In 2012, an animal welfare group

released graphic video that was taken while undercover of workers at an Idaho dairy allegedly mistreating cows.

• In response to this video, the Idaho Dairymen’s Association drafted legislation to criminalize undercover investigations in the future, which the Idaho governor signed into law in 2014.

Idaho’s “Ag Gag” Law• The law provides that a person commits the

crime of interference with agricultural production if the person knowingly: – “Enters an agricultural facility that is not open to

the public and, without the facility owner’s express consent or pursuant to judicial process or statutory authorization, makes audio or video recordings of the conduct of an agricultural production facility’s operations.”

Idaho’s “Ag Gag” Law

This led animal activist groups to file suit against the state challenging this law for violation of free speech.

• As of September 2015, the Idaho Attorney General is awaiting Judge Winmill’s formal order striking down the law before deciding whether or not to appeal the decision.

In August 2015, U.S. District Court Judge in Idaho found that Idaho’s Ag Gag Law was unconstitutional for criminalizing certain types of speech.

Cannabis Law/ Medical Marijuana


• Federal Law– Producing, distributing,

and possessing marijuana for any purposes if illegal under federal law

– The federal government does not recognize an exception for medical uses for marijuana

Cannabis Law/ Medical Marijuana• Federal Law

– In August 2013, the U.S. Department of Justice announced an update to their marijuana enforcement policy, stating that while marijuana remains illegal federally, the USDOJ expects states that make marijuana legal to enforce its laws properly and the USDOJ maintains right to challenge the laws of the states at any time if it feels necessary.

Cannabis Law/ Medical Marijuana• Medical marijuana is legal in 23

states and Washington D.C. as of July 2015.– Alaska, Arizona, California,

Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, Montana, Nevada, New Hampshire, New Jersey, New Mexico, New York, Oregon, Rhode Island, Vermont, Washington


• As of September 25, 2015, Pennsylvania and Ohio have pending legislation regarding legalization of medical marijuana.


• Legislation has failed in 17 states in 2015.– Alabama, Florida, Georgia,

Indiana, Iowa, Kansas, Kentucky, Mississippi, Missouri, Nebraska, North Carolina, North Dakota, South Carolina, Tennessee, Texas, Utah, and West Virginia

Farm Bill

Farm BillMajor Farm Policy Changes

in the 2014 Farm Bill

• Repeals Direct Payments and limits producers to risk management tools that offer protection when they suffer significant losses.

• Limits on payments are reduced, eligibility rules are tightened, and means tests were more streamlined.

Farm Bill

Major Farm Policy Changes in the 2014

Farm Bill

•Added a “sodsaver provision” to the Federal Crop Insurance Program•Reform to dairy policy

Farm Bill

Major Farm Policy Changes in the 2014

Farm Bill •Voluntary, margin protecting program•Livestock disaster assistance•Training and Access to Capital

Farm BillChanges with the Supplemental Nutrition Assurance Program (“SNAP”) (f/k/a “Food Stamps”)

• Eliminates “heat-and-eat” loophole.• Establishes 10-state pilot program to

engage able-bodied adults in mandatory work programs.

• Prohibits USDA from engaging in SNAP recruitment activities and advertising SNAP on TV, radio, billboards, & through foreign governments.

Farm Bill

SNAP Changes• Ensures illegal immigrants, lottery

winners, traditional college students, & the deceased do not receive SNAP benefits.

• Ensures SNAP recipients are not receiving benefits across multiple states.

• Prevents abuse such as water dumping to exchange bottles for cash.

• Demands outcomes from existing employment and training programs.

Farm Bill

SNAP Changes

• Eliminates medical marijuana as an allowable medical expense.

• Institutes pilot investigation program to battle retailer fraud and crackdown on trafficking through data mining, terminal ID, and other measures.

• Increases access to local, tribal, Kosher, and Halal foods in food assistance programs.

Farm Bill

SNAP Changes

• Provides grants to eligible nonprofit organizations to improve community access to food through development of innovative projects, such as school garden programs and urban greenhouse initiatives.

• Increases assistance for food banks.

Questions on Being an Agriculture Lawyer

• Fridays with Cari Skype Calls– First Friday of the

month at 2pm ET– RSVP to

[email protected]– No charge

mailto:[email protected]

I Wrote a Book

Cari B. Rincker & Patrick B. Dillon, “Field Manual: Legal Guide for New York Farmers & Food Entrepreneurs” (2013)

Available at http://www.amazon.com/Field-Manual-Legal-Farmers-Entrepreneurs/dp/1484965191

Please Stay in Touch• Send Me Snail Mail: 535 Fifth Avenue, 4th Floor,

New York, NY 10017• Call Me: (212) 427-2049 (office)• Email Me: [email protected]• Visit My Website: www.rinckerlaw.com • Read My Food, Farm & Family Law Blog:

www.rinckerlaw.com/blog• Tweet Me: @CariRincker @RinckerLaw• Facebook Me: www.facebook.com/rinckerlaw • Link to Me:

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