TL;DR
Food safety attorney Bill Marler says he is filing seven petitions with the FDA and USDA’s Food Safety and Inspection Service. The requests address infant formula testing, warnings for raw milk cheese and sprouts, poultry contamination, outbreak sampling and disclosure of implicated companies. The source describes the petitions’ proposals, but does not establish that agencies have accepted or acted on them.
Food safety attorney Bill Marler says he is filing seven petitions with the FDA and the USDA’s Food Safety and Inspection Service, seeking changes that range from infant formula testing and consumer warnings to outbreak investigations and disclosure of implicated food businesses. The proposals could affect what agencies test, what information shoppers see and how investigators reach potential contamination sources, but the petitions are requests, not adopted rules.
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Marler’s account, published by Food Safety News, says the petitions were prepared with his law firm’s staff, outside scientists and physicians, families affected by outbreaks, and other food safety advocates. The source says the requests concern steps the agencies previously promised, already apply to some products, or have discussed without putting into binding written standards. It does not provide a complete filing record or response from either agency.
Among the proposals, a petition to the FDA would add botulinum neurotoxin-producing clostridia to the organisms powdered infant formula makers must test for in finished product and would also require testing of dairy-based ingredients. Marler says 52 infants have been hospitalized with botulism in the ByHeart and Nara Organics outbreaks since 2023, and that the organism was found in a dairy ingredient. He says 46 parents of 24 affected infants are co-petitioners. Those figures and outbreak details are reported in the source; the petition’s requested testing requirements are not current policy.
Two other FDA petitions seek prescribed package warnings for raw-milk cheese and for raw or lightly cooked sprouts, including sprouts in salads, sandwiches and wraps. The cheese proposal also asks the agency to complete its review of the 60-day aging rule and require producers relying on aging to validate that it controls pathogens. The sprouts request would put on packaging advice the FDA has issued through other channels for children, older adults, pregnant people and people with weakened immune systems.
The remaining petitions would ask FSIS to treat Salmonella at or above 1 CFU per gram as an adulterant in raw ground chicken, ground turkey and chicken parts—or, alternatively, to apply the standard to three named serotypes—and to begin verification sampling. FDA would be asked to take time-limited environmental and animal samples at an animal feeding operation after making a written finding that it is implicated in a multistate outbreak. Another petition seeks disclosure of firms implicated by evidence in investigations. The source’s account of that final request ends mid-sentence, so its full proposed scope is not available.
Changes to Testing and Warnings
The petitions address points where federal food safety decisions can shape both prevention and public information. Testing requirements may affect whether contamination is detected before a product reaches consumers, while package warnings could give shoppers information at the point of purchase or consumption. Neither effect is guaranteed: agencies would have to review the requests and decide whether to act.
The proposals also raise questions about how quickly outbreak investigators can collect evidence and when they should identify companies to the public. Marler argues for access limited to operations linked in writing to multistate outbreaks and for disclosure where evidence implicates a firm. Those are the petitioners’ requested standards, not descriptions of existing agency commitments or settled legal conclusions.
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Existing Rules Behind the Requests
The petitions seek to build on or change specific federal practices rather than establish a single new food safety program. For example, Marler says current finished-product testing rules for powdered infant formula cover Cronobacter and Salmonella, but not the organism targeted by the formula petition. He also points to an FDA 1998 warning for juice as a model for proposed raw-food labels.
For poultry, the source cites an FSIS determination in May 2024 that Salmonella at or above 1 CFU per gram is an adulterant in breaded stuffed raw chicken products. It says a broader proceeding concerning other raw poultry was withdrawn in April 2025, and that verification sampling announced in 2024 was postponed indefinitely in December 2025. The petitions seek further action; those dates do not mean the requested wider standard is already in force.
On outbreak access, Marler refers to FDA’s 1975 rule concerning Salmonella in pet turtles and the 2018 Yuma romaine outbreak. He says FDA found an outbreak strain in an irrigation canal beside a large cattle feedlot, took six samples inside the operation and left. The proposed petition would use a narrow, triggered authority for sampling at an operation identified in writing as implicated in a multistate outbreak.
““This year I have spent a fair amount of time trying to put myself out of business.””
— Bill Marler, in the Food Safety News publisher’s platform
Agency Responses Remain Pending
The source describes the petitions and their requested remedies, but does not establish that all seven have been formally filed, docketed or accepted for review. It includes no FDA or FSIS response, timetable, proposed rule or decision on any request. It is also unclear whether the agencies will agree with the petitioners’ interpretation of their authority or the evidence they cite.
The source text cuts off during its description of the petition on naming firms implicated in outbreaks. As a result, the precise wording and full scope of that request cannot be confirmed from the material provided. Claims about outbreak counts, agency actions and prior practices are attributed here to Marler’s account rather than independently verified.
Petition Review and Agency Decisions
The next steps depend on the agencies’ handling of each filing. FDA and FSIS would need to review the requested actions and determine whether to respond, seek more information, begin rulemaking or take another course. The source provides no deadlines or scheduled agency milestones.
Readers should distinguish any future agency response from the petitions themselves: filing a request does not change testing or labeling rules. Updates to watch for include confirmation of filing, agency docket entries, formal responses and any proposed or final regulations. Until those appear, the seven measures remain requests described by their proponents.
Key Questions
What are the seven petitions asking federal agencies to do?
They seek expanded testing for powdered infant formula, warnings for raw-milk cheese and sprouts, broader Salmonella standards and sampling for raw poultry, outbreak-related access to animal feeding operations, and disclosure of firms implicated in investigations. The source’s description of the final petition is incomplete.
Have the FDA or FSIS adopted these proposals?
No adoption is reported. The measures are petition requests; the source does not include agency decisions or responses.
Who is behind the petitions?
Attorney Bill Marler says his staff, lawyers, scientific and medical reviewers, affected families and other food safety advocates contributed. He says 46 parents are co-petitioners on the infant formula request.
What remains unknown?
The source does not give complete filing or docket information, agency response dates, or a decision timetable. Its account also ends before fully describing the proposal on naming firms implicated in outbreaks.
Source: rss
