The Food Safety Modernization Act (“FSMA”) was supposed to result in a dramatic restructuring of the US food industry.  And someday soon it might.  But to implement its strategic vision, tactics (i.e. rules) need to be implemented.  The four key rules (for preventative controls for food facilities, preventive controls for animal feed facilities, the foreign supplier verification program and the produce safety rule) were supposed to be ready for comment in January.  But, the proposed rules have yet to be published by the White House Office of Management of Budget’s Office of Information and Regulatory Affairs.  The cause of the hold-up is unknown, but in this election cycle (and given Congress’s unwillingness to fund the FSMA), our guess is that politics (and not in the good Artisotelian sense) is to blame.

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