I have a final note. In light of the FDA's broad
jurisdiction to regulate the
industry, even if it is conceivable to produce cider without any part of
the
production being part of interstate commerce, it would be extremely risky
to
not label the cider as required by the final rule. If a producer did not
label it's cider according to the regulation and there was an outbreak or
illness, the producer would most likely be liable.
The bottom line here is that the FDA has very broad
jurisdiction to regulate
the health and safety of our food. They promulgated a rule requiring cider
producers to provide a warning label on their product unless it has been
specifically processed to prevent, reduce, or eliminate the presence of
pathogens. As of today, September 8, 1998, this rule goes into effect for
all
apple cider producers in theUnited States.
Alicia Rosamilia
(Rutgers Law student studying FDA regulations of cider industry)
*******************************************************
Note: This material is not intended as legal advice. If you
have a legal
question or problem, please consult an attorney.
*******************************************************
for further contact:
Alicia Rosamilia
Rutgers Cooperative Extension of Hunterdon County
4 Gauntt Place
Flemington, NJ 08822
908-788-1338
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