It is up to each and every food processor, handler, and warehouser to develop, document, and implement a policy regarding photography of their operations. This is a much greater challenge today compared to 20 years ago because nearly every cellphone has a high-quality camera with the ability to capture both pictures and video. Operations that are regulated by FDA must also factor the agency into their camera policy.
FSIS' assertion it has the authority to take photographs at regulated establishments is nothing new. But the recent revision has caused many establishments to again question whether the agency truly has the authority to take photographs and what actions can be taken when there is a demand to take them.
