Meunerie Sawyerville, Inc.; Denial of Hearing; Final Debarment Order, 8877-8880 [2018-04195]
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Federal Register / Vol. 83, No. 41 / Thursday, March 1, 2018 / Notices
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[FR Doc. 2018–04131 Filed 2–28–18; 8:45 am]
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DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA–2017–N–0901]
Meunerie Sawyerville, Inc.; Denial of
Hearing; Final Debarment Order
AGENCY:
Food and Drug Administration,
HHS.
ACTION:
Notice.
The Food and Drug
Administration (FDA or the Agency) is
denying a request for a hearing
submitted by Meunerie Sawyerville, Inc.
(Meunerie Sawyerville) and is issuing
an order under the Federal Food, Drug,
and Cosmetic Act (FD&C Act) debarring
Meunerie Sawyerville for 5 years from
importing articles of food or offering
such articles for import into the United
States. FDA bases this order on a finding
that Meunerie Sawyerville was
convicted of felony offenses for conduct
relating to the importation of food into
the United States. In determining the
appropriateness and period of Meunerie
Sawyerville’s debarment, FDA has
considered the relevant factors listed in
the FD&C Act. Meunerie Sawyerville
has failed to file with the Agency
information and analyses sufficient to
create a basis for a hearing concerning
this action.
DATES: The order is applicable March 1,
2018.
ADDRESSES: Any application by
Meunerie Sawyerville for special
SUMMARY:
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termination of debarment under section
306(d) of the FD&C Act (application)
may be submitted as follows:
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that if you include your name, contact
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• If you want to submit an
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(see ‘‘Written/Paper Submissions’’ and
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Submit written/paper submissions as
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Nathan R. Sabel, Office of Scientific
Integrity, Food and Drug
Administration, 10903 New Hampshire
Ave., Bldg. 1, Rm. 4206, Silver Spring,
MD 20993, 301–796–8588.
SUPPLEMENTARY INFORMATION:
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I. Background
On November 9, 2015, in the U.S.
District Court for the District of
Vermont, Meunerie Sawyerville pled
guilty to two felony counts related to the
importation of food into the United
States. Both offenses occurred from on
or about September 12, 2012, to on or
about January 15, 2013. With respect to
Count One, Meunerie Sawyerville
admitted to knowingly and intentionally
making and using a false writing that
contained a materially fictitious
statement in a matter within the
jurisdiction of the executive branch of
the United States government in
violation of 18 U.S.C. 1001(a)(3) ‘‘by
submitting a false Automated
Commercial Environment Manifest
listing a fictitious importer, namely, Ted
Taft, and presenting such documents to
Customs and Border Protection
[Customs] officials . . . knowing and
believing that Ted Taft was not the true
importer of the goods’’ described in the
manifest. With respect to Count Two,
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Meunerie Sawyerville admitted to
causing the introduction of an
adulterated drug (i.e., cattle feed
containing monensin) into interstate
commerce with the intent to defraud
and mislead in violation of sections
301(a), 303(a)(2), and 501(a)(6) of the
FD&C Act (21 U.S.C. 331(a), 333(a)(2),
and 351(a)(6)). Under section 501(a)(6),
a drug is adulterated if it is an animal
feed bearing or containing a new animal
drug that is unsafe within the meaning
of the FD&C Act.
Under section 306(b)(1)(C) of the
FD&C Act (21 U.S.C. 335a(b)(1)(C)), FDA
is authorized to debar Meunerie
Sawyerville from importing articles of
food or offering food for import into the
United States based on a finding, under
section 306(b)(3)(A) of the FD&C Act,
that Meunerie Sawyerville was
convicted of a felony for conduct
relating to the importation of food into
the United States. By letter dated July
21, 2017, the Office of Regulatory
Affairs (ORA) notified Meunerie
Sawyerville of a proposal to debar it for
5 years from importing articles of food
or offering such articles for import into
the United States and provided an
opportunity for Meunerie Sawyerville to
request a hearing. In proposing a
debarment period, ORA weighed the
considerations in section 306(c)(3) it
considered applicable to Meunerie
Sawyerville’s offenses, concluded that
each of these felony offenses
independently warranted a 5-year
period of debarment, and proposed that
these debarment periods be served
concurrently under section 306(c)(2)(A).
By letter dated August 14, 2017,
Meunerie Sawyerville requested a
hearing on the proposal.
The Director of the Office of Scientific
Integrity (OSI) has reviewed Meunerie
Sawyerville’s request for a hearing, as
well as the materials offered in support,
and finds that Meunerie Sawyerville has
not established a basis for a hearing
because hearings will be granted only if
there is a genuine and substantial issue
of fact for resolution at a hearing.
Hearings will not be granted on issues
of policy or law, on mere allegations,
denials, or general descriptions of
positions and contentions, or on data
and information insufficient to justify
the factual determination urged (see 21
CFR 12.24(b)). OSI has considered
Meunerie Sawyerville’s arguments and
concludes that they are unpersuasive
and fail to raise a genuine and
substantial issue of fact requiring a
hearing.
II. Arguments
Meunerie Sawyerville does not
dispute that it is subject to debarment
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under section 306(b)(1)(C) of the FD&C
Act because it committed two felony
offenses related to the importation of
food. Nor does Meunerie Sawyerville
dispute any of ORA’s factual findings
contained in the proposal to debar.
Further, Meunerie Sawyerville does not
dispute ORA’s conclusion based on
these findings that both the nature and
seriousness of the offenses and the
nature and extent of Meunerie
Sawyerville management’s participation
in the offenses are both considerations
favoring debarment.
Against this backdrop, Meunerie
Sawyerville argues only: (1) That ORA
failed to consider as an applicable
factor, under section 306(c)(3)(D) of the
FD&C Act, the operational changes
Meunerie Sawyerville contends it has
made that would prevent it from
shipping adulterated animal feed again
in the future, specifically, discontinuing
the use of monensin in its animal feed,
(2) that voluntary mitigation of the
offenses should not count as an
unfavorable consideration under section
306(c)(3)(C) because Meunerie
Sawyerville pled guilty and no specific
harm occurred that Meunerie
Sawyerville could mitigate, and (3) that
debarment is not an appropriate remedy
when customers are not defrauded and
when debarment would hurt Meunerie
Sawyerville’s business.
Section 306(c)(3) requires FDA to
consider, ‘‘where applicable,’’ certain
factors ‘‘[i]n determining the
appropriateness and the period of
debarment’’ for debarment under
section 306(b)(3) of the FD&C Act. The
proposal to debar Meunerie Sawyerville
set forth five potentially applicable
considerations for debarment actions
related to food importation imposed
under section 306(b)(1)(C): (1) The
nature and seriousness of the offense
under section 306(c)(3)(A); (2) the
nature and extent of management
participation in the offense under
section 306(c)(3)(B); (3) the nature and
extent of voluntary steps taken to
mitigate the impact on the public under
section 306(c)(3)(C); (4) the extent that
ownership, management, or operations
changes have corrected the causes of the
offense and provide reasonable
assurances that the offense will not
recur under 306(c)(3)(D); and (5) prior
convictions involving matters within
the jurisdiction of FDA under section
306(c)(3)(F). In its proposal, ORA found
that the first three considerations weigh
in favor of debarring Meunerie
Sawyerville and noted that the fifth
consideration weighs against debarment
because the Agency was unaware of any
prior convictions involving matters
within the jurisdiction of FDA. ORA
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found the fourth consideration
inapplicable.
Meunerie Sawyerville’s now
represents that it no longer ships animal
feed containing monensin and argues
that changes in its operations should be
counted as a consideration weighing
against debarment under section
306(c)(3)(D). Beyond removing
monensin from its production process,
Meunerie Sawyerville points to no other
changes in ownership, management, or
operations that would address the
causes of the offenses and provides no
other reasonable assurance that the
criminal conduct underlying the
offenses will not recur. As ORA’s
proposal finds and Meunerie
Sawyerville concedes, the same
management remains in charge at
Meunerie Sawyerville, including
president and owner Yves Bolduc, who
Meunerie Sawyerville admits devised
and executed the fraudulent scheme
forming the basis for the offenses:
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[A]fter the medicated feed at issue was
sampled at the border, found to contain
monensin at a concentration above that
allowed by FDA, and the driver was ordered
to warehouse the feed pending further testing
from FDA, Mr. Bolduc instructed the driver
to deliver the feed to a Vermont farmer as
planned, without informing the farmer that
the feed had been sampled and ordered held
by FDA. Mr. Bolduc then engineered a plan
that a sham shipment of similar-looking
cattle feed cross the border under false
Customs documentation to be stored on an
unrelated piece of land in Vermont until
requested for redelivery by Customs and
Border Protection. Upon request by Customs
and Border Protection, Mr. Bolduc ordered
that the sham shipment be presented for
redelivery, accompanied by the fictitious
documentation, offering up the sham
shipment feed to the U.S. government as the
held tainted feed.
Meunerie Sawyerville has admitted to
knowingly and intentionally
orchestrating this presentation of false
documents to Customs as part of a larger
scheme to defraud government
regulators about the nature of a
shipment offered for import and to
introducing adulterated product into
interstate commerce with the intent to
defraud and mislead. Meunerie
Sawyerville does not dispute this
conduct.
Meunerie Sawyerville also argues in
its hearing request that the majority of
its business going forward, if Meunerie
Sawyerville is not debarred, would
involve offering animal feed for import
into the United States from Canada,
necessarily requiring Meunerie
Sawyerville to provide Customs with an
ongoing stream of information about its
products in the future. As an FDAregulated product, animal feed can
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become adulterated in numerous ways,
not merely through the addition of too
much monensin (see, generally, section
402 of the FD&C Act (21 U.S.C. 342)).
In addition to adulteration, there are
also many other reasons an
unscrupulous importer might attempt to
deceive Customs. Any regular importer
of food will be required to submit
import documents to Customs
repeatedly that detail the nature, value,
quantity, and condition of product
offered for import. As a result, simply
removing monensin from Meunerie
Sawyerville’s process does not
sufficiently address the causes of the
offenses and provides little assurance
that Meunerie Sawyerville would
handle future food import matters
without resorting to the knowing and
intentional deception of government
regulators and the introduction of
adulterated product that forms the basis
of these offenses. Therefore, even
assuming as true that Meunerie
Sawyerville has stopped adding
monensin to its animal feed, Meunerie
Sawyerville has not sufficiently
corrected the causes that resulted in the
offenses and has not provided
reasonable assurances that these
offenses will not recur. As a result, the
Director of OSI finds that the
consideration in section 306(C)(3)(D)
should not be considered as weighing
against debarment for these offenses.
Next, Meunerie Sawyerville argues
that the nature and extent of steps taken
to mitigate the impact of its offenses on
the public under section 306(c)(3)(C) of
the FD&C Act should be a consideration
weighing against debarment. Meunerie
Sawyerville argues that there was no
evidence that specific members of the
public were harmed such that
mitigation of that harm was possible
and that it pled guilty as the only
possible mitigation step. OSI disagrees
that Meunerie Sawyerville’s actions
suggest significant voluntary mitigation
of the harm related to the offenses at
issue. Although the government
exposed Meunerie Sawyerville’s
offenses in progress and thereby
prevented harm to any specific victims
for the offenses at issue, other voluntary
mitigation efforts were available to
Meunerie Sawyerville beyond simply
pleading guilty when apprehended.
Indeed, with respect to voluntary
mitigation for the offense in Count Two,
Meunerie Sawyerville devised the
fraudulent scheme underlying the
offense in Count One to compound,
rather than mitigate, its earlier criminal
conduct of shipping an adulterated
product to its customer in Vermont.
Rather than admitting the earlier
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misconduct to Customs and FDA to
mitigate any harm from its earlier
tainted shipment and avoid continuing
to undermine the government’s ability
to regulate imports, Meunerie
Sawyerville engaged in additional
criminal conduct and devised the sham
shipment and fictitious documents that
formed the basis for the offense in Count
One. Further, with respect to Count One
itself, because this offense was devised
to conceal other criminal conduct, the
primary opportunity to mitigate the
associated harm to the government’s
regulatory authority occurred
throughout Meunerie Sawyerville’s
efforts to devise and execute the scheme
described in Count One. Rather than
take steps to mitigate the harm from the
earlier criminal offense, Meunerie
Sawyerville chose to take affirmative
steps to compound that harm. In this
context, Meunerie Sawyerville deserves
no credit for a guilty plea when its
scheme was uncovered. Therefore,
considering the facts and the context of
these offenses, the Director of OSI finds
that the extent of voluntary efforts to
mitigate the impact of these offenses
should not be considered in favor of
Meunerie Sawyerville under section
306(c)(3)(C).
Lastly, Meunerie Sawyerville argues
that debarment is inappropriate as a
matter of policy because it would harm
Meunerie Sawyerville’s business and
force its customers to consider other
suppliers for their animal feed. As
already noted, a hearing will not be
granted on issues of policy such as these
(see 21 CFR 12.24(b)). Also, the
considerations Meunerie Sawyerville
raises, such as the impact of debarment
on Meunerie Sawyerville’s business, are
not appropriate considerations under
section 306(c)(3) for determining the
length of a period of debarment. Finally,
the remedial purpose of the debarment
statute is designed to accomplish
exactly the result to which Meunerie
Sawyerville objects by protecting the
public from food from importers whose
criminal conduct demonstrates, based
on the applicable considerations, that
they warrant debarment. As such, these
arguments do not support Meunerie
Sawyerville’s request for a hearing on
this matter.
III. Findings and Order
Because OSI has assumed as true that
Meunerie Sawyerville has discontinued
using monensin in its process and
Meunerie Sawyerville raises no other
arguments that would present genuine
and substantial issues of fact that would
require resolution at an evidentiary
hearing, Meunerie Sawyerville’s request
for an evidentiary hearing is denied.
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Considering all applicable factors
under 306(c)(3) of the FD&C Act, OSI
concurs with ORA’s proposal that a 5year period of debarment for each
offense is warranted. On this record,
OSI finds that the nature and
seriousness of the offenses and the
nature and extent of Meunerie
Sawyerville management’s participation
in the offenses are factors weighing
heavily in favor of debarment. For the
reasons already discussed, even
assuming Meunerie Sawyerville has
discontinued using monensin in its
operations, OSI finds that operational
change insufficient under section
306(c)(3)(D) to demonstrate correction of
the causes of these offenses and to
provide reasonable assurances that the
offenses will not recur. Further, even
after taking into account Meunerie
Sawyerville’s guilty plea under section
306(c)(3)(C), OSI finds that Meunerie
Sawyerville’s conduct related to this
consideration weighs in favor of
debarment. Although Meunerie
Sawyerville’s lack of a prior conviction
under 306(c)(3)(F) is a factor weighing
against debarment, this consideration is
substantially outweighed by the nature
and seriousness of the offenses, the
nature and extent of management’s
participation in the offenses, and the
nature and extent of voluntary steps to
mitigate the impact of the offenses on
the public. Therefore, considering all of
these factors together and the record as
a whole, OSI finds that a 5-year period
of debarment is warranted for each
offense.
Therefore, the Director of OSI, under
section 306(b)(3)(A) of the FD&C Act
and under authority delegated to him by
the Commissioner of Food and Drugs,
finds that Meunerie Sawyerville has
been convicted of a felony for conduct
relating to the importation of food into
the United States. FDA has considered
the relevant factors listed in section
306(c)(3) of the FD&C Act and
determined that a debarment of 5 years
is appropriate for each of these felony
offenses. These periods will run
concurrently under section 306(c)(2)(A).
As a result of the foregoing findings,
Meunerie Sawyerville is debarred for a
period of 5 years from importing articles
of food or offering such articles for
import into the United States,
applicable (see DATES). Under section
301(cc) of the FD&C Act, the importing
or offering for import into the United
States of an article of food by, with the
assistance of, or at the direction of
Meunerie Sawyerville is a prohibited
act.
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Dated: February 26, 2018.
George M. Warren,
Director, Office of Scientific Integrity.
[FR Doc. 2018–04195 Filed 2–28–18; 8:45 am]
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DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA–2014–D–0313]
Agency Information Collection
Activities; Submission for Office of
Management and Budget Review;
Comment Request; Guidance for
Industry, Researchers, Patient Groups,
and Food and Drug Administration
Staff on Meetings With the Office of
Orphan Products Development
AGENCY:
Food and Drug Administration,
HHS.
ACTION:
Notice.
The Food and Drug
Administration (FDA) is announcing
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Food and Drug Administration, Three
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In
compliance with 44 U.S.C. 3507, FDA
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Guidance for Industry, Researchers,
Patient Groups, and Food and Drug
Administration Staff on Meetings With
the Office of Orphan Products
Development
OMB Control Number 0910–0787—
Extension
This information collection supports
Agency guidance regarding staff
meetings with the Office of Orphan
Products Development (OOPD). Each
year, the OOPD staff participates in
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guidance or clarification relating to
orphan drug or humanitarian use device
(HUD) designation requests, OOPD grant
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These meetings can be ‘‘informal’’ or
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Topics addressed in this guidance
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requested with OOPD in fiscal year (FY)
2016 regarding orphan drug designation
requests, HUD designation requests, rare
pediatric disease designation requests,
funding opportunities through the
Orphan Products Grants Program and
the Pediatric Device Consortia Grants
Program, and orphan product patientrelated issues. FDA anticipates that the
number of meeting requests and
stakeholders will remain the same or
will slightly increase and therefore
estimates the total number of meeting
E:\FR\FM\01MRN1.SGM
01MRN1
Agencies
[Federal Register Volume 83, Number 41 (Thursday, March 1, 2018)]
[Notices]
[Pages 8877-8880]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-04195]
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA-2017-N-0901]
Meunerie Sawyerville, Inc.; Denial of Hearing; Final Debarment
Order
AGENCY: Food and Drug Administration, HHS.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Food and Drug Administration (FDA or the Agency) is
denying a request for a hearing submitted by Meunerie Sawyerville, Inc.
(Meunerie Sawyerville) and is issuing an order under the Federal Food,
Drug, and Cosmetic Act (FD&C Act) debarring Meunerie Sawyerville for 5
years from importing articles of food or offering such articles for
import into the United States. FDA bases this order on a finding that
Meunerie Sawyerville was convicted of felony offenses for conduct
relating to the importation of food into the United States. In
determining the appropriateness and period of Meunerie Sawyerville's
debarment, FDA has considered the relevant factors listed in the FD&C
Act. Meunerie Sawyerville has failed to file with the Agency
information and analyses sufficient to create a basis for a hearing
concerning this action.
DATES: The order is applicable March 1, 2018.
ADDRESSES: Any application by Meunerie Sawyerville for special
termination of debarment under section 306(d) of the FD&C Act
(application) may be submitted as follows:
Electronic Submissions
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments. An application
submitted electronically, including attachments, to https://www.regulations.gov will be posted to the docket unchanged. Because
your application will be made public, you are solely responsible for
ensuring that your application does not include any confidential
information that you or a third party may not wish to be posted, such
as medical information, your or anyone else's Social Security number,
or confidential business information, such as a manufacturing process.
Please note that if you include your name, contact information, or
other information that identifies you in the body of your application,
that information will be posted on https://www.regulations.gov.
If you want to submit an application with confidential
information that you do not wish to be made available to the public,
submit the application as a written/paper submission and in the manner
detailed (see ``Written/Paper Submissions'' and ``Instructions'').
Written/Paper Submissions
Submit written/paper submissions as follows:
Mail/Hand delivery/Courier (for written/paper
submissions): Dockets Management Staff (HFA-305), Food and Drug
Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852.
For a written/paper application submitted to the Dockets
Management Staff, FDA will post your application, as well as any
attachments, except for information submitted, marked and identified,
as confidential, if submitted as detailed in ``Instructions.''
Instructions: Your application must include the Docket No. FDA-
2017-N-0901. An application will be placed in the docket and, unless
submitted as ``Confidential Submissions,'' publicly viewable at https://www.regulations.gov or at the Dockets Management Staff between 9 a.m.
and 4 p.m., Monday through Friday.
Confidential Submissions--To submit an application with
confidential information that you do not wish to be made publicly
available, submit your application only as a written/paper submission.
You should submit two copies total. One copy will include the
information you claim to be confidential with a heading or cover note
that states ``THIS DOCUMENT CONTAINS
[[Page 8878]]
CONFIDENTIAL INFORMATION.'' The Agency will review this copy, including
the claimed confidential information, in its consideration of your
application. The second copy, which will have the claimed confidential
information redacted/blacked out, will be available for public viewing
and posted on https://www.regulations.gov. Submit both copies to the
Dockets Management Staff. If you do not wish your name and contact
information to be made publicly available, you can provide this
information on the cover sheet and not in the body of your application
and you must identify this information as ``confidential.'' Any
information marked as ``confidential'' will not be disclosed except in
accordance with 21 CFR 10.20 and other applicable disclosure law. For
more information about FDA's posting of comments to public dockets, see
80 FR 56469, September 18, 2015, or access the information at: https://www.gpo.gov/fdsys/pkg/FR-2015-09-18/pdf/2015-23389.pdf.
Docket: For access to the docket, go to https://www.regulations.gov
and insert the docket number, found in brackets in the heading of this
document, into the ``Search'' box and follow the prompts and/or go to
the Dockets Management Staff, 5630 Fishers Lane, Rm. 1061, Rockville,
MD 20852.
FOR FURTHER INFORMATION CONTACT: Nathan R. Sabel, Office of Scientific
Integrity, Food and Drug Administration, 10903 New Hampshire Ave.,
Bldg. 1, Rm. 4206, Silver Spring, MD 20993, 301-796-8588.
SUPPLEMENTARY INFORMATION:
I. Background
On November 9, 2015, in the U.S. District Court for the District of
Vermont, Meunerie Sawyerville pled guilty to two felony counts related
to the importation of food into the United States. Both offenses
occurred from on or about September 12, 2012, to on or about January
15, 2013. With respect to Count One, Meunerie Sawyerville admitted to
knowingly and intentionally making and using a false writing that
contained a materially fictitious statement in a matter within the
jurisdiction of the executive branch of the United States government in
violation of 18 U.S.C. 1001(a)(3) ``by submitting a false Automated
Commercial Environment Manifest listing a fictitious importer, namely,
Ted Taft, and presenting such documents to Customs and Border
Protection [Customs] officials . . . knowing and believing that Ted
Taft was not the true importer of the goods'' described in the
manifest. With respect to Count Two, Meunerie Sawyerville admitted to
causing the introduction of an adulterated drug (i.e., cattle feed
containing monensin) into interstate commerce with the intent to
defraud and mislead in violation of sections 301(a), 303(a)(2), and
501(a)(6) of the FD&C Act (21 U.S.C. 331(a), 333(a)(2), and 351(a)(6)).
Under section 501(a)(6), a drug is adulterated if it is an animal feed
bearing or containing a new animal drug that is unsafe within the
meaning of the FD&C Act.
Under section 306(b)(1)(C) of the FD&C Act (21 U.S.C.
335a(b)(1)(C)), FDA is authorized to debar Meunerie Sawyerville from
importing articles of food or offering food for import into the United
States based on a finding, under section 306(b)(3)(A) of the FD&C Act,
that Meunerie Sawyerville was convicted of a felony for conduct
relating to the importation of food into the United States. By letter
dated July 21, 2017, the Office of Regulatory Affairs (ORA) notified
Meunerie Sawyerville of a proposal to debar it for 5 years from
importing articles of food or offering such articles for import into
the United States and provided an opportunity for Meunerie Sawyerville
to request a hearing. In proposing a debarment period, ORA weighed the
considerations in section 306(c)(3) it considered applicable to
Meunerie Sawyerville's offenses, concluded that each of these felony
offenses independently warranted a 5-year period of debarment, and
proposed that these debarment periods be served concurrently under
section 306(c)(2)(A). By letter dated August 14, 2017, Meunerie
Sawyerville requested a hearing on the proposal.
The Director of the Office of Scientific Integrity (OSI) has
reviewed Meunerie Sawyerville's request for a hearing, as well as the
materials offered in support, and finds that Meunerie Sawyerville has
not established a basis for a hearing because hearings will be granted
only if there is a genuine and substantial issue of fact for resolution
at a hearing. Hearings will not be granted on issues of policy or law,
on mere allegations, denials, or general descriptions of positions and
contentions, or on data and information insufficient to justify the
factual determination urged (see 21 CFR 12.24(b)). OSI has considered
Meunerie Sawyerville's arguments and concludes that they are
unpersuasive and fail to raise a genuine and substantial issue of fact
requiring a hearing.
II. Arguments
Meunerie Sawyerville does not dispute that it is subject to
debarment under section 306(b)(1)(C) of the FD&C Act because it
committed two felony offenses related to the importation of food. Nor
does Meunerie Sawyerville dispute any of ORA's factual findings
contained in the proposal to debar. Further, Meunerie Sawyerville does
not dispute ORA's conclusion based on these findings that both the
nature and seriousness of the offenses and the nature and extent of
Meunerie Sawyerville management's participation in the offenses are
both considerations favoring debarment.
Against this backdrop, Meunerie Sawyerville argues only: (1) That
ORA failed to consider as an applicable factor, under section
306(c)(3)(D) of the FD&C Act, the operational changes Meunerie
Sawyerville contends it has made that would prevent it from shipping
adulterated animal feed again in the future, specifically,
discontinuing the use of monensin in its animal feed, (2) that
voluntary mitigation of the offenses should not count as an unfavorable
consideration under section 306(c)(3)(C) because Meunerie Sawyerville
pled guilty and no specific harm occurred that Meunerie Sawyerville
could mitigate, and (3) that debarment is not an appropriate remedy
when customers are not defrauded and when debarment would hurt Meunerie
Sawyerville's business.
Section 306(c)(3) requires FDA to consider, ``where applicable,''
certain factors ``[i]n determining the appropriateness and the period
of debarment'' for debarment under section 306(b)(3) of the FD&C Act.
The proposal to debar Meunerie Sawyerville set forth five potentially
applicable considerations for debarment actions related to food
importation imposed under section 306(b)(1)(C): (1) The nature and
seriousness of the offense under section 306(c)(3)(A); (2) the nature
and extent of management participation in the offense under section
306(c)(3)(B); (3) the nature and extent of voluntary steps taken to
mitigate the impact on the public under section 306(c)(3)(C); (4) the
extent that ownership, management, or operations changes have corrected
the causes of the offense and provide reasonable assurances that the
offense will not recur under 306(c)(3)(D); and (5) prior convictions
involving matters within the jurisdiction of FDA under section
306(c)(3)(F). In its proposal, ORA found that the first three
considerations weigh in favor of debarring Meunerie Sawyerville and
noted that the fifth consideration weighs against debarment because the
Agency was unaware of any prior convictions involving matters within
the jurisdiction of FDA. ORA
[[Page 8879]]
found the fourth consideration inapplicable.
Meunerie Sawyerville's now represents that it no longer ships
animal feed containing monensin and argues that changes in its
operations should be counted as a consideration weighing against
debarment under section 306(c)(3)(D). Beyond removing monensin from its
production process, Meunerie Sawyerville points to no other changes in
ownership, management, or operations that would address the causes of
the offenses and provides no other reasonable assurance that the
criminal conduct underlying the offenses will not recur. As ORA's
proposal finds and Meunerie Sawyerville concedes, the same management
remains in charge at Meunerie Sawyerville, including president and
owner Yves Bolduc, who Meunerie Sawyerville admits devised and executed
the fraudulent scheme forming the basis for the offenses:
[A]fter the medicated feed at issue was sampled at the border,
found to contain monensin at a concentration above that allowed by
FDA, and the driver was ordered to warehouse the feed pending
further testing from FDA, Mr. Bolduc instructed the driver to
deliver the feed to a Vermont farmer as planned, without informing
the farmer that the feed had been sampled and ordered held by FDA.
Mr. Bolduc then engineered a plan that a sham shipment of similar-
looking cattle feed cross the border under false Customs
documentation to be stored on an unrelated piece of land in Vermont
until requested for redelivery by Customs and Border Protection.
Upon request by Customs and Border Protection, Mr. Bolduc ordered
that the sham shipment be presented for redelivery, accompanied by
the fictitious documentation, offering up the sham shipment feed to
the U.S. government as the held tainted feed.
Meunerie Sawyerville has admitted to knowingly and intentionally
orchestrating this presentation of false documents to Customs as part
of a larger scheme to defraud government regulators about the nature of
a shipment offered for import and to introducing adulterated product
into interstate commerce with the intent to defraud and mislead.
Meunerie Sawyerville does not dispute this conduct.
Meunerie Sawyerville also argues in its hearing request that the
majority of its business going forward, if Meunerie Sawyerville is not
debarred, would involve offering animal feed for import into the United
States from Canada, necessarily requiring Meunerie Sawyerville to
provide Customs with an ongoing stream of information about its
products in the future. As an FDA-regulated product, animal feed can
become adulterated in numerous ways, not merely through the addition of
too much monensin (see, generally, section 402 of the FD&C Act (21
U.S.C. 342)). In addition to adulteration, there are also many other
reasons an unscrupulous importer might attempt to deceive Customs. Any
regular importer of food will be required to submit import documents to
Customs repeatedly that detail the nature, value, quantity, and
condition of product offered for import. As a result, simply removing
monensin from Meunerie Sawyerville's process does not sufficiently
address the causes of the offenses and provides little assurance that
Meunerie Sawyerville would handle future food import matters without
resorting to the knowing and intentional deception of government
regulators and the introduction of adulterated product that forms the
basis of these offenses. Therefore, even assuming as true that Meunerie
Sawyerville has stopped adding monensin to its animal feed, Meunerie
Sawyerville has not sufficiently corrected the causes that resulted in
the offenses and has not provided reasonable assurances that these
offenses will not recur. As a result, the Director of OSI finds that
the consideration in section 306(C)(3)(D) should not be considered as
weighing against debarment for these offenses.
Next, Meunerie Sawyerville argues that the nature and extent of
steps taken to mitigate the impact of its offenses on the public under
section 306(c)(3)(C) of the FD&C Act should be a consideration weighing
against debarment. Meunerie Sawyerville argues that there was no
evidence that specific members of the public were harmed such that
mitigation of that harm was possible and that it pled guilty as the
only possible mitigation step. OSI disagrees that Meunerie
Sawyerville's actions suggest significant voluntary mitigation of the
harm related to the offenses at issue. Although the government exposed
Meunerie Sawyerville's offenses in progress and thereby prevented harm
to any specific victims for the offenses at issue, other voluntary
mitigation efforts were available to Meunerie Sawyerville beyond simply
pleading guilty when apprehended. Indeed, with respect to voluntary
mitigation for the offense in Count Two, Meunerie Sawyerville devised
the fraudulent scheme underlying the offense in Count One to compound,
rather than mitigate, its earlier criminal conduct of shipping an
adulterated product to its customer in Vermont. Rather than admitting
the earlier misconduct to Customs and FDA to mitigate any harm from its
earlier tainted shipment and avoid continuing to undermine the
government's ability to regulate imports, Meunerie Sawyerville engaged
in additional criminal conduct and devised the sham shipment and
fictitious documents that formed the basis for the offense in Count
One. Further, with respect to Count One itself, because this offense
was devised to conceal other criminal conduct, the primary opportunity
to mitigate the associated harm to the government's regulatory
authority occurred throughout Meunerie Sawyerville's efforts to devise
and execute the scheme described in Count One. Rather than take steps
to mitigate the harm from the earlier criminal offense, Meunerie
Sawyerville chose to take affirmative steps to compound that harm. In
this context, Meunerie Sawyerville deserves no credit for a guilty plea
when its scheme was uncovered. Therefore, considering the facts and the
context of these offenses, the Director of OSI finds that the extent of
voluntary efforts to mitigate the impact of these offenses should not
be considered in favor of Meunerie Sawyerville under section
306(c)(3)(C).
Lastly, Meunerie Sawyerville argues that debarment is inappropriate
as a matter of policy because it would harm Meunerie Sawyerville's
business and force its customers to consider other suppliers for their
animal feed. As already noted, a hearing will not be granted on issues
of policy such as these (see 21 CFR 12.24(b)). Also, the considerations
Meunerie Sawyerville raises, such as the impact of debarment on
Meunerie Sawyerville's business, are not appropriate considerations
under section 306(c)(3) for determining the length of a period of
debarment. Finally, the remedial purpose of the debarment statute is
designed to accomplish exactly the result to which Meunerie Sawyerville
objects by protecting the public from food from importers whose
criminal conduct demonstrates, based on the applicable considerations,
that they warrant debarment. As such, these arguments do not support
Meunerie Sawyerville's request for a hearing on this matter.
III. Findings and Order
Because OSI has assumed as true that Meunerie Sawyerville has
discontinued using monensin in its process and Meunerie Sawyerville
raises no other arguments that would present genuine and substantial
issues of fact that would require resolution at an evidentiary hearing,
Meunerie Sawyerville's request for an evidentiary hearing is denied.
[[Page 8880]]
Considering all applicable factors under 306(c)(3) of the FD&C Act,
OSI concurs with ORA's proposal that a 5-year period of debarment for
each offense is warranted. On this record, OSI finds that the nature
and seriousness of the offenses and the nature and extent of Meunerie
Sawyerville management's participation in the offenses are factors
weighing heavily in favor of debarment. For the reasons already
discussed, even assuming Meunerie Sawyerville has discontinued using
monensin in its operations, OSI finds that operational change
insufficient under section 306(c)(3)(D) to demonstrate correction of
the causes of these offenses and to provide reasonable assurances that
the offenses will not recur. Further, even after taking into account
Meunerie Sawyerville's guilty plea under section 306(c)(3)(C), OSI
finds that Meunerie Sawyerville's conduct related to this consideration
weighs in favor of debarment. Although Meunerie Sawyerville's lack of a
prior conviction under 306(c)(3)(F) is a factor weighing against
debarment, this consideration is substantially outweighed by the nature
and seriousness of the offenses, the nature and extent of management's
participation in the offenses, and the nature and extent of voluntary
steps to mitigate the impact of the offenses on the public. Therefore,
considering all of these factors together and the record as a whole,
OSI finds that a 5-year period of debarment is warranted for each
offense.
Therefore, the Director of OSI, under section 306(b)(3)(A) of the
FD&C Act and under authority delegated to him by the Commissioner of
Food and Drugs, finds that Meunerie Sawyerville has been convicted of a
felony for conduct relating to the importation of food into the United
States. FDA has considered the relevant factors listed in section
306(c)(3) of the FD&C Act and determined that a debarment of 5 years is
appropriate for each of these felony offenses. These periods will run
concurrently under section 306(c)(2)(A). As a result of the foregoing
findings, Meunerie Sawyerville is debarred for a period of 5 years from
importing articles of food or offering such articles for import into
the United States, applicable (see DATES). Under section 301(cc) of the
FD&C Act, the importing or offering for import into the United States
of an article of food by, with the assistance of, or at the direction
of Meunerie Sawyerville is a prohibited act.
Dated: February 26, 2018.
George M. Warren,
Director, Office of Scientific Integrity.
[FR Doc. 2018-04195 Filed 2-28-18; 8:45 am]
BILLING CODE 4164-01-P