Since we first published “FDA Continues Proposed Extra-Statutory Authority Over Compounded Animal Drugs,” a number of impacted stakeholders have been expressing concern about the intended and unintentional consequences of FDA’s current approach. First, as a result of widespread concern about the proposed guidelines, FDA will be extending the time to comment, previously scheduled to close on February 18, 2020. According to the American Veterinary Medical Association (AVMA), [t]he FDA agreed Friday to…

Veterinarians in New Jersey are hereby notified of amendments to existing regulations governing continuing veterinary educational requirements and supervision of veterinary students in training by state licensees. First, continuing veterinary education (CVE) requirements have been amended to require one credit hour of CVE “in topics concerning prescription opioid drugs, including the risks and signs of opioid abuse, additional, and diversion,” beginning with the biennial renewal period beginning on June 30, 2019.  N.J.A.C. 13:44-4.10 (b)(3). There…

In 2008, the Department of Justice (“the DOJ”), Civil Rights Division, published a Notice of Proposed Rulemaking seeking to amend the regulations which enforce the ADA’s prohibition of discrimination in public accommodations.[1] As part of the proposed changes, the DOJ wished to clarify the obligations of public accommodations regarding the use of service animals by persons with disabilities.[2] According to the DOJ, the need for clarification was brought about by a large number…

I was honored to join colleagues and clients at the 2020 Aviation Symposium the Firm sponsored in Tysons Corner from February 4 through February 6, 2020. Symposium topics included: What about the Lion Air and Ethiopian Airlines accidents should concern you? An update on emotional support and service animals Structuring and conducting an effective emergency drill Working with first responders A decade of evolution in the Federal Family Assistance Plan The changing faces of the…

Last month, I listened to a podcast interviewing the owner of Straight Arrow, the parent company that produces Mane and Tail and Cowboy Magic products. As a lifelong horse owner (including several grey horses that love mud), I cannot remember a time when I did not have a Mane and Tail and/or Cowboy Magic product in my tack room. The interview took place after the podcasters toured the Cowboy Magic manufacturing facility, which, according to…