FDA routinely recommends seizure actions under the FDCA (authorized by 21 U.S.C. § 334) by direct referral to USAOs. Most of these actions involve filthy storage conditions at food warehouses and similarly clear FDCA violations. However, some seizure recommendations are based on novel or difficult legal theories. Consultation with CPB as required under JM 4-8.200 will ensure USAOs have access to the most recent guidance.

[updated April 2018]