What the FDA has in store for the food industry in 2017

by Thompson Coburn LLP

Thompson Coburn LLP

As Life Sciences Decoded looks forward in 2017, it is clear that FDA-regulated industries have a great deal of change confronting them. Last year, 2016, was a landmark year for the FDA and food regulations, as the agency finalized and began enforcing four of the major Rules promulgated under the 2011 Food Safety Modernization Act (FSMA). These include Hazard Analysis and Risk-based Preventive Controls (HARPC), the Produce Safety Rule, the Sanitary Transport Rule, and the Foreign Supplier Verification Program (FSVP). These Rules, along with several others and in-progress Guidance documents, represent the practical application of the FSMA, what is expected of the food industry and the first major overhaul of the U.S. food safety system in more than 70 years.

These programs have been discussed at length by Life Sciences Decoded and represent a new vision for how a food facility must implement a food safety plan to prevent the adulteration of food for both humans and animals. These four Rules all have triggers for compliance in 2017 which will affect how the food industry does business going forward.

The following is a brief description of these Rules with their respective compliance dates and the impending 2017 implications. It is worth noting that some of these Rules have already been extended (see those with an *) and may be extended again. Those dates that have already past or appear in 2017 are in bold.

Current Good Manufacturing Practices (GMPs) and Hazard Analysis and Risk-based Preventive Controls (HARPC) for Human Foods

This is the core of the FSMA’s impact for most members of the food industry that are involved with processing foods. HARPC requires a food facility to have in place a Food Safety Plan that addresses, in detail, the hazards present in the facility, its processes and equipment that could result in the adulteration of the foods handled in the facility. A HARPC-compliant food safety plan requires facilities to perform a full analysis of every component of their manufacturing, packaging, labelling, holding and other processing activities, identify the hazards these activities pose, create preventive controls to minimize the risks these hazards pose, and create corrective actions in the case that these hazards impact the food (including recalls, market withdrawals and reprocessing). HARPC requires this entire process to be documented, and employees must be thoroughly trained on the new food safety plan when it is implemented. Finally, the GMPs that have applied to human food for decades have been updated with a new emphasis on hygiene, training and allergen cross-contact prevention.

  • Location: 21 C.F.R. § 117
  • Rule Date: September 30, 2015
  • Compliance date for most businesses:
    • September 19, 2016
    • Supply Chain Program - March 17, 2017
  • Compliance date for small businesses: September 18, 2019*

Impact in 2017: The Supply Chain Program will have the greatest impact on food businesses and the evaluation of the industry’s intra-company manufacturing processes, as well as its relationship with its suppliers and customers in 2017. To implement this supply chain requirement, not only will the industry need to better track both inbound and outbound product, but it is intended to create better communication and a continuous vigilance on food safety.  These supply chain programs should be written and must be integrated into the food safety plan and should be consistent with the inbound and outbound providers of products plans as well. The regulatory requirements are detailed in its requirements and those requirements must be accounted for including, but not limited to audits, records keeping and other verification activities.

Current Good Manufacturing Practices (GMPs) and Hazard Analysis and Risk-based Preventive Controls (HARPC) for Animal Foods

This is essentially HARPC for facilities that process animal feeds. However, new to animal feed production are GMPs that also govern product handling and production. Historically, animal feed manufacturing has not been subject to GMP regulation, and now with the passing of this Rule, animal feeds are subject to nearly the same amount of safety regulation that human foods are.

  • Location: 21 C.F.R. § 507
  • Rule Date: September 30, 2015
  • Compliance date for most businesses:
    • September 18, 2017
  • Compliance date for small businesses:
    • September 17, 2018*

Impact in 2017:  All animal food/feed will have to be manufactured in accordance with GMPs and are now required to have in place a HARPC plan. Animal food/feed companies are now being held to a much higher level of compliance than ever before. These new regulations will change the way animal food/feed companies process/manufacture and generally do business. These companies must develop written food safety plans and in so doing must evaluate the manufacturing process it utilizes to ensure not only that the manufactured product meets GMPs but must account for hazards and hazard controls.

Produce Safety Rule

Whereas HARPC does not apply to farms, the new Produce Safety Rule does apply to many farming facilities throughout the U.S., particularly those involved in the growing and harvesting of raw agricultural commodities that are consumed raw such as sprouts. The new Rule is expansive, and covers everything from the buildings, storage facilities, employee restrooms, worker training, wildlife and even a farm’s water source. Do note that there are many crops that are exempt from the rule because they are rarely consumed raw (such as coffee beans).

  • Location: 21 C.F.R. § 112
  • Rule Date: October 31, 2015
  • Compliance date for most businesses:
    • January 27, 2020*
    • Compliance dates for small businesses and very small businesses: January 26, 2021 and January 26, 2022.*
  • Compliance date for businesses involving sprouts:
    • January 28, 2019*
  • Compliance dates for small and very small businesses involving sprouts:
    • January 27, 2020 and January 26, 2021.*

Impact for 2017: In spite of the fact that the compliance dates are after 2017, the produce industry as defined under this rule, has never been subject to this level of regulation. Therefore, 2017 is a year in which the produce industry needs to begin to prepare itself to comply with the lengthy and detailed regulatory requirements. These new regulations include sanitary measures, equipment safety, facilities and grounds, as well as an increased focus on managing biological sources of contamination. For an industry experiencing these FDA regulations for the first time, 2017 is the time to begin conforming business practices.

Foreign Supplier Verification Program

The new Foreign Supplier Verification Program is designed to ensure that not only is food manufactured and processed in the US safe, under HARPC and the Produce Safety Rule, but also those food products made overseas and brought into the U.S. This program in part recruits U.S. entities to work on behalf of the FDA to police foreign suppliers of food products to make sure that HARPC’s new more stringent requirements are not just followed domestically.

  • Location: 21 C.F.R. § 1.500 et seq.
  • Rule Date: October 31, 2015
  • Compliance Date: May 28, 2019*

Impact for 2017: The compliance date for the FSVP is somewhat misleading as domestic food companies are currently required to have a safe food supply. For those companies sourcing from outside the U.S., once the product is in the U.S., the domestic importer is solely at risk without the benefit of ensuring that the foreign supplier has been inspected and has an appropriate food safety plan until such time as this rule becomes effective. Therefore, verifying a foreign supplier’s practices now makes a great deal of sense for all domestic food businesses.

Sanitary Transport Rule

The Sanitary Transport Rule dictates a new set of procedures for documenting the movement of food through the U.S. via rail or motor vehicle. Anyone who participates in a “transportation operation,” including anything that impacts the sanitary condition of food in transportation such as cleaning, inspection, loading, unloading, receiving, etc. Note, this rule does not apply to transportation via air or water.

  • Location: 21 C.F.R. § 1.900 et seq
  • Rule Date: April 6, 2016
  • Compliance date for most businesses: April 6, 2017
  • Compliance date for small businesses: April 6, 2018

Impact for 2017: This rule brings the transport industry into the safe food equation. The domestic food industry will be responsible (unless delegated through a transport agreement) to ensure that the food it is having transported is transported under the same safety standards in which it was manufactured. Records will need to be kept on cleaning transport by vehicles, inspections of those vehicles and preventing cross contamination, particularly with known allergens. Trucking and rail industries are not familiar with FDA and its regulations, and therefore educating these transport industries is likely to fall on the food industry itself.

The FSMA’s regulations are not the only ones which will be impacting the food industry this year. In addition to the Rules described above, the FDA will also be enforcing the following.

Vending Machine Nutrition Labeling

The new rule requires operators of vending machines to enable the disclosure of caloric content information for products sold in vending machines. Derived from the Patient Protection and Affordable Care Act, this rule’s compliance date in 2017 requires significant amount of coordination between snack and food manufacturers and vending machine companies to ensure compliance. The FDA has not required labeling for vending machines previously, and many aging vending machines lack the technology or shelf space to accommodate the new rule. Additionally, vending machine operators will need to re-think machine-stocking procedures and retrain employees.

  • Location: 21 C.F.R. § 101.8
  • Rule Date: December 1, 2014

While the original compliance date for the Rule was December 1, 2016, the FDA has stated that, consistent with a clause entered into the 2016 Omnibus Bill passed by Congress, the FDA will not be enforcing the rule until May 5, 2017. Glass-front vending machines with foods that have labelling on the front of their packages, which is visible from the outside of the machine, have a compliance date of July 26, 2018. However, Life Sciences Decoded encourages members of the industry to ensure compliance as quickly as possible, as this may change.

Nutrition Labeling of Menu Items in Restaurants

Restaurants that are part of a chain of 20 or more locations, doing business under the same name, offering for sale substantially the same menu items and offering for sale restaurant-type foods: This new Rule will require the disclosure of calorie information for menu items on menus, but restaurants subject to the rule will also need to have available to the customer, upon request, additional nutrition information similar to that found on the Nutrition Facts panel of packaged foods.

  • Location: 21 C.F.R. § 101.11
  • Rule Date: May 5, 2016
  • Compliance Date: December 1, 2016 was the original compliance date. However, on December 2, 2016, the FDA announced that it would extend this compliance date to May 5, 2017.

Compliance dates that have either already passed or are soon approaching, enforcement can be expected.  This means more inspections. Additionally, inspectors will be expecting to see ongoing evidence of efforts toward compliance before final compliance dates arrive for those rules with future compliance dates.

While rules with compliance dates that have already passed should be a priority for all involved, small businesses with dates that are farther out should take the opportunity in 2017 to begin the process of building their compliance programs to not only address these issues before the required date, but also to reflect how these regulations are enforced on larger companies subject to earlier compliance dates. As usual, getting an early start on these programs, particularly for companies with limited resources, will be key to ensuring that they are ready when the FDA first appears at their door for inspections aimed at the new food safety plans.


The FDA also continues to ramp up and support its training programs. Through the Produce Safety Alliance, the Foods Safety Preventive Controls Alliance, and the Sprout Safety Alliance, the FDA has created FDA-funded industry organizations that are in charge of “training the trainers” for food industry members. In other words, these alliances provide the training that can be used to train employees on food safety regulations and compliance under the FSMA as well. While these are not the only training options available, they will be the industry standard for the foreseeable future. With the approach of so many FSMA and other food safety deadlines quickly approaching, all members of the food industry will be looking to these, and similar FDA-recognized training organizations, for education in 2017.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thompson Coburn LLP | Attorney Advertising

Written by:

Thompson Coburn LLP

Thompson Coburn LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.