BILL ANALYSIS                                                                                                                                                                                                    �



                                                                AB 1616
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        CONCURRENCE IN SENATE AMENDMENTS
        AB 1616 (Gatto)
        As Amended August 30, 2012
        Majority vote
         
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        |ASSEMBLY:  |56-19|(May 29, 2012)  |SENATE: |33-0 |(August 30,    |
        |           |     |                |        |     |2012)          |
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         Original Committee Reference:    HEALTH  

         SUMMARY  :  Regulates the production and sale of certain 
        non-potentially hazardous foods prepared in a home kitchen.

         The Senate amendments  : 

        1)Recast provisions subjecting a cottage food operation (CFO) to 
          various specified local government regulations with respect to 
          zoning, local ordinances, and use permits from the Health and 
          Safety Code to the Government Code.

        2)Require monies collected by the Department of Public Health (DPH) 
          pursuant to the provisions of this bill relating to inspections 
          and enforcement to be deposited in the existing Food Safety Fund 
          in the State Treasury.

        3)Establish a phase in schedule of gross annual sales limits on 
          CFOs, beginning with a $35,000 sales maximum in 2013, a $45,000 
          maximum in 2014, and a $50,000 maximum beginning in 2015 and in 
          each subsequent year. 

        4)Clarify allowable locations for the direct and indirect sales of 
          cottage food products and require a third party retailer involved 
          in indirect sales to hold a valid permit from the local 
          environmental health department (LEHD).  

        5)Clarify the definition of a cottage food product and make 
          additional clarifying changes to the list of permissible 
          non-potentially hazardous foods to be sold by a CFO that DPH is 
          required to develop.

        6)Authorize the Director of DPH to add or delete food products to or 
          from the approved food products list described above, as 
          specified.  Require DPH to post notice of changes to this list on 








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          its Web site.  Exclude this list from administrative rulemaking 
          requirements.

        7)Revise the definition of "permit" in the California Retail Food 
          Code (CRFC) to include a CFO and deems "registration" to be 
          synonymous with "permit" for purposes of this bill. 

        8)Require kitchen equipment to be clean and maintained in a good 
          state of repair.  Prohibit smoking in the portion of a private 
          home used for a CFO.

        9)Allow for inspections of CFOs in response to a consumer complaint 
          and authorize LEHDs to recover the costs of conducting inspections 
          for those CFOs that engage in direct sales only, as specified.

        10)Limit the sale of cottage food products between counties, as 
          specified.

        11)Modify provisions treating CFOs as restricted food service 
          facilities for purposes of compliance with the CRFC, as specified.

        12)Require a person who prepares or packages cottage food products 
          to complete a food processor course, of no more than four hours, 
          instructed by DPH within three months and direct DPH to work with 
          LEHDs to ensure proper notification is provided to CFOs. 

        13)Prescribe labeling requirements for cottage food products and 
          require a food facility that serves a cottage food product without 
          labeling or packaging to identify it as homemade.

        14)Require the Director of DPH to provide technical assistance and 
          develop, maintain, and deliver commodity-specific training related 
          to the safe processing and packaging of cottage food products to 
          LEHDs and permit LEHDs to impose a surcharge fee on certain CFOs 
          for the administration of this training, as specified. 

        15)Modify provisions governing enforcement to allow LEHDs to suspend 
          or revoke a CFO's permit for specified violations, or immediately 
          close a CFO if an imminent health hazard is found. 

        16)Make a number of other technical, clarifying and conforming 
          changes to address chaptering conflicts.

         AS PASSED BY THE ASSEMBLY  , this bill was substantially similar to 
        the version as approved by the Senate.








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         FISCAL EFFECT  :  According to the Senate Appropriations Committee:

        1)One-time costs of $150,000 to $300,000 (General Fund) for DPH to 
          adopt regulations regarding foods that may be produced by CFOs.

        2)Unknown costs to LEHDs to regulate CFOs (local funds).  Because 
          LEHDs have the authority to levy fees, these costs are not 
          reimbursable by the state.

         COMMENTS  :  The Senate version of this bill differs from the 
        Assembly-approved version in that the Senate amendments, among other 
        things, give DPH the authority to add and remove foods from the 
        approved foods list; establish labeling requirements; include 
        additional health and safety requirements; limit the sale of cottage 
        food products through indirect sales to the county of production, 
        unless actively accepted by another county; give LEHDs the authority 
        to regulate CFOs that engage in indirect sales; require DPH to train 
        LEHDs on how to enforce indirect sales requirements; and, allow DPH 
        to inspect CFOs as needed for the enforcement of the indirect sales 
        requirements.  According to the author, the Senate amendments 
        reflect provisions deemed necessary by the Administration to ensure 
        proper implementation of the bill. 

        The California Association of Environmental Health Administrators, 
        which represents LEHDs, remains opposed to this bill, arguing that 
        it prohibits LEHDs from using their current enforcement authority 
        under the CRFC to appropriately regulate CFOs and would specifically 
        set new parameters on permit conditions and inspection frequencies 
        not found elsewhere under existing law.   
         
        Analysis Prepared by  :    Cassie Royce / HEALTH / (916) 319-2097 
                                                                 FN: 0005815