NEHA May 2024 Journal of Environmental Health

15–18 in Pittsburgh, Pennsylvania, where there will be presentations on advocacy, regulatory challenges, and how new laws are impacting the practice of environmen- tal health. Diplomates from the American Academy of Sanitarians will be participating in at least two of these presentations—Navi- gating the Future: Anticipating the Evolving Needs of Our Profession and Advocacy in Iowa: Environmental Health’s Navigation of a Changing Political Climate. Corresponding Author: Eric Bradley, Execu- tive Secretary and Treasurer, American Acad- emy of Sanitarians. Email: References Hoffman, S., Maculloch, B., & Batz, M. (2015). Economic burden of major foodborne illnesses acquired in the United States (Eco- nomic Information Bulletin Number 140). Economic Research Service, U.S. Depart- ment of Agriculture. https://www.ers.usda. gov/webdocs/publications/43984/52807_ eib140.pdf The Iowa Legislature. (2020). Chapter 34: Home bakeries (481—34.1–5[137D]). ter/11-18-2020.481.34.pdf The Iowa Legislature. (2022). House file 2431: An act relating to the regulation of home- based businesses, including food establish- ments and home food processing establish- ments, and providing civil penalties . https:// LGR/89/attachments/HF2431.html The Iowa Legislature. (2023a). Chapter 34: Home food processing establishments (481— 34.1–14[137D]). docs/iac/chapter/03-08-2023.481.34.pdf The Iowa Legislature. (2023b). House file 661: An act providing for the issuance of annual statewide licenses for certain establish- ments o€ering food for sale, including license fees and including e€ective date provisions . Book?ba=HF661&ga=90

by cooking, baking, drying, mixing, cutting, fermenting, preserving, freezing, dehydrating, growing, raising, or other process” and sets an application fee of $50 (The Iowa Legislature, 2022). Home food items are required to be labeled with the name of the home food pro- cessing establishment, the common name of the food, ingredients in descending order, net quantity of contents, expiration date if it is a TCS food, and a statement declaring that “this product was produced at a home food process- ing establishment.” If the food contains aller- gens, a statement must be on the product that identifies the allergen by its common name (The Iowa Legislature, 2022). All non-TCS baked goods now fall under cottage food along with “home-processed and home-canned pickles, vegetables, or fruits that have a finished equilibrium pH value of four and six-tenths [4.6] or lower or a water activ- ity value of eighty-five hundredths [0.85] or less for which each batch has been measured by a pH meter or a water activity meter and each container that is sold or oŒered for sale contains the date the food was processed and canned” (The Iowa Legislature, 2022). The law requires some labeling, including the name, address, phone number, or email address of the person who prepared the food; common name of the food; ingredients; an allergen statement if any are used in the prod- uct; and a statement declaring that this “prod- uct was produced at a residential property that is exempt from state licensing and inspection” (The Iowa Legislature, 2022). Since HF 2431 also exempts cottage food from permitting, licensing, inspection, pack- aging, and labeling laws of Iowa, there is no way to determine if the cottage food facility is complying with the law unless an outbreak were to occur (The Iowa Legislature, 2022). It should be mentioned that local jurisdic- tions that have food inspection programs do so through a 28E agreement with the Iowa Department of Inspections, Appeals, and Licensing (formerly DIA) as of 2023. Fur- thermore, per state code, local jurisdictions are not allowed to have a local ordinance or

enforce anything that is not part of the Iowa Food Code or that is not delegated to juris- dictions through the 28E agreement. Once the bill became law, inspection staŒ reached out to the existing home bakeries to review their menus and determine if the facil- ity would become a home food processing establishment or fall under cottage food. At the same time, new applications were being submitted for home food processing estab- lishment licenses, and inspection staŒ were spending an average of 4–7 hr going over law requirements with the applicant and review- ing the proposed menu, not including the time spent conducting preopening inspections. During the approval process for the admin- istrative rules, the Iowa legislature was insis- tent that the bill allowed for home restau- rants. DIA argued that the law defined “home food item” as a non-TCS food and the law clearly stated that the “home food item” be consumed oŒ the premises. The administra- tive rules committee agreed (The Iowa Legis- lature, 2023a). The 2023 state legislature passed HF 661, which redefined “home food item” to include made-to-order food that is “intended for immediate consumption” (The Iowa Legisla- ture, 2023b). As of now, these types of home food processing establishments are consid- ered takeout restaurants, and consumption on the premises is not allowed. The $50 application fee will not cover the time spent on the application, preopening inspection, or routine inspection. When a facility submits its annual renewal, inspection staŒ will have to review the menu in case it has changed. If the menu has changed, more time will be spent reviewing the new items to ensure compliance with the law. There is also the burden of foodborne illness outbreaks. In 2013, a report found that foodborne illness cost the U.S. >$15.5 billion in economic bur- den every year, which is equivalent to $20 bil- lion today (HoŒman et al., 2015). Please plan to attend the National Envi- ronmental Health Association’s 2024 Annual Educational Conference & Exhibition on July

Our practice exam for the Registered Environmental Health Specialist/Registered Sanitarian (REHS/RS) credential has been redesigned and updated! The practice exam was redesigned by subject matter experts and constructed to better simulate the experience of taking the actual exam. Learn more at

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