As the comment period on proposed Food Safety Modernization Act rules winds down, attention is turning to the methods the U.S. Food and Drug Administration will use for enforcement. "The design and mechanism for FSMA is to be enforced by private litigation," said Marc Sanchez, an FDA attorney and founder of Contract In-House Counsel and Consultants, which represents FDA-regulated companies. "So we will see FSMA enforced through a combination of traditional practices, such as warning letters, as well as through third-party, private litigation."

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