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CU Comments to California Department of Food and Agriculture on Livestock Drug Regulation Modifications

SUMMARY: Consumers Union, the advocacy division of Consumer Reports, comments on California Department of Food and Agriculture (CDFA) Notice of Modifications to the Text of Proposed Regulations on Title 3 Food and Agriculture Division 5 Livestock Drugs, Chapter 1. Sales of Restricted Livestock Drugs and Chapter 2. Sales of California Prescription Drugs. These proposed regulations are part of the implementation of SB 27 on use of antimicrobial drugs in livestock. We support the proposed text modifications in Chapter 1 on sales of restricted livestock drugs which serve to strengthen the regulations by making the licensing procedures more stringent. We also support the suggested text modification in both Chapters 1 and 2 which clarify when a warning notice will be issued upon the finding of a violation, and remove the possibility of contesting any fines that result from those violations.