new jersey department of health · 1 state of new jersey 2 department of health 3...

1 STATE OF NEW JERSEY

2 DEPARTMENT OF HEALTH

3 -------------------------------------x

4 IN RE: :

5 Special Public Health Council :

6 -------------------------------------x

7

8

9

10 Location: Department of Health

11 369 South Warren Street

12 Trenton, New Jersey 08625

13 Date: Monday, February 24, 2020

14 Commencing at: 10:36 a.m.

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19

20 RENZI LEGAL RESOURCES

21 Court Reporting, Videography & Legal Services

22 2277 STATE HIGHWAY #33, SUITE 410

23 HAMILTON SQUARE, NEW JERSEY 08690

24 TEL: (609) 989-9199 TOLL FREE: (800) 368-7652

25 www.RLResources.com No. 328206

2

www.renziassociates.comRenzi Legal Resources (609) 989-9199

1 HELD BEFORE:

2

3 MICKEY GROSS, Chairman

4 DENNIS SAN FILIPPO (Appearing Via Phone)

5 RICH CENSULLO (Appearing Via Phone)

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7

8 A L S O P R E S E N T:

9

10 KENYA PENNANT

11 KAITLYN WOOLFORD

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1 I N D E X

2 ITEM PAGE

3 Call to Order 4

4 Chairperson's Report 4

5 Memo to the Public Health Council

6 By: Mr. Manley 20

7 Public Comment 42

8 Adjournment 77

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10

11

12

13 E X H I B I T S

14

15 ID DESCRIPTION PAGE

16

17 (NO EXHIBITS WERE MARKED.)

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20 R E Q U E S T S

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22 (NO FORMAL REQUESTS WERE MADE.)

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1 MS. PENNANT: This is a formal

2 meeting of the Public Health Council. Notice of

3 this meeting has been published in accordance

4 with the provisions of Chapter 231, Public Law,

5 1975 c-10:4.10 of the state of New Jersey

6 entitled Open Public Meetings Act.

7 Notice was sent to the Secretary of

8 State who posted the notice in a public place.

9 We have three members of the council present

10 which does constitute a quorum. Mickey Gross?

11 MR. GROSS: Yes.

12 MS. PENNANT: Dennis San Filippo?

13 MR. SAN FILIPPO: Yes.

14 MS. PENNANT: And Rich Censullo?

15 MR. CENSULLO: Yes.

16 MS. PENNANT: We have a court

17 reporter in the room, so please announce yourself

18 before you make a statement.

19 MR. GROSS: Thank you, Madam Clerk.

20 The first thing we have on the agenda here is a

21 couple gentlemen from the state in regard to the

22 Food Cottage Industry Law. Okay. To be straight

23 with everybody, Dennis and Rich, there's going to

24 be some discussion today.

25 But I think in all fairness, hearing

5


1 from some health officers this weekend, some

2 directors of health, I would like to hold off on

3 any vote on this until next month because I think

4 there's a lot of people who want to be heard on

5 this.

6 And this thing, in all fairness,

7 came out Thursday, five o'clock I got a copy of

8 it. Mr. Manley, I think you got a copy around

9 the same time on Thursday?

10 MR. MANLEY: That's correct.

11 MR. GROSS: So in all fairness --

12 MR. SAN FILIPPO: I didn't receive

13 it until Friday at 5:30.

14 MR. GROSS: You got it a day later

15 than me. But the point is, I ended up postponing

16 any kind of voting on this with permission of the

17 other members of the council quite simply because

18 I think it's the fair thing.

19 I think there's a lot of people who

20 still want to be heard on this issue. Gentlemen,

21 are you in agreement? I don't think we need to

22 vote on it, but are you in agreement? Rich, that

23 would be you and Dennis.

24 MR. SAN FILIPPO: Yes, I agree. And

25 Mickey, can you tell us if there's any members of

6


1 the public there today?

2 MR. GROSS: Yes, there is members of

3 the public present today.

4 MS. PENNANT: Can we go around the

5 room and announce ourselves, please.

6 MS. MARICH: Jennifer Marich. I'm

7 here on behalf of the New Jersey Home Bakers

8 Association.

9 MS. JALINOS: Marin Jalinos from

10 Hasbrouck Heights, New Jersey. I'm a member of

11 the public.

12 MS. DRAGONE: Melanie Dragone. I'm

13 from Hawthorne, New Jersey, District 38, member

14 of the public.

15 MS. CUCUZZELLA: I'm Holly

16 Cucuzzella. I'm a health officer for Burlington

17 County Health Department.

18 MR. EUGENE: Tyrone Eugene,

19 principal registered environmental health

20 specialist from Burlington County Health

21 Department.

22 MS. PENNANT: Kenya Pennant,

23 secretary to the board.

24 MR. GROSS: We do have

25 representatives from the State Health Department

7


1 that are here. And so with that said, I'm going

2 to turn it over to Bill Manley and Gary, if

3 that's all right with you.

4 MR. SAN FILIPPO: Just one more

5 point, I'm going to request that comments from

6 the public, the people that are there, and any

7 other invested interest groups that come up

8 before we do a vote on this, we get to the

9 council members, with sufficient time to review

10 it and bring it back for a proper vote.

11 MR. GROSS: I think I made that

12 clear already that we wouldn't be voting today.

13 MR. CENSULLO: I want to be clear on

14 this. This is not considered to be the public

15 hearing. Am I correct?

16 MR. GROSS: That would be correct.

17 MR. CENSULLO: So then why are we --

18 I mean, that's an issue that I want to take up,

19 the fact that there was no public hearing. I

20 mean, there is public hearing. If there is a

21 public hearing, it should be with the council.

22 It should be announced and it should

23 be at a later date so that we can attend and we

24 can listen to the public and participate. If

25 it's not a public hearing, I think we should have

8


1 a public hearing before we vote.

2 I don't agree with what I heard

3 earlier is that it was a meeting with

4 stakeholders that we weren't aware of and we were

5 given some of the opinions of the stakeholders

6 but we weren't privileged to exactly what was

7 said. This is not right. I think this deserves

8 a public hearing and I think the public hearing

9 should be done with the council.

10 MR. GROSS: Agreed.

11 MR. SAN FILIPPO: I would just add

12 another comment. I don't know what the questions

13 were given to the other parties, but if I only

14 received this document on Friday night at 5:30

15 p.m., I'm sure this document that's before us

16 today has not been shared with those people

17 because it was just completed, as far as I know,

18 Friday. So I think we have to get comment from

19 these people on what presently has been proposed

20 in its present form.

21 MS. WOOLFORD: Dennis and Rich, this

22 is Kaitlyn. Any type of public hearing would

23 come during the public comment period which would

24 come once the rule proposal is published. So

25 it's not right to have a public hearing before

9


1 the rules are published in The Register.

2 MR. SAN FILIPPO: I'm not talking

3 about that. I'm talking about the comments from

4 the vested groups as they're received. Like the

5 people that are there, I would like to receive

6 their comments. That's what I'm saying.

7 MS. WOOLFORD: I totally understand.

8 There is also a 60 day public comment period for

9 any interested stakeholder on either side of the

10 issue to have themselves be heard. And all of

11 those responses would be in writing in any future

12 administrative regulatory action.

13 MR. CENSULLO: I'm sorry. I didn't

14 catch who was speaking.

15 MS. WOOLFORD: It was Kaitlyn from

16 DOH.

17 MR. CENSULLO: Kaitlyn, I tend to

18 disagree. I think we had public hearings before

19 the council in the past if my memory serves me

20 correctly. I know there's also the public

21 comment period which is separate from the public

22 hearing session.

23 I don't see any reason in statute or

24 regulation why we cannot have a hearing before

25 the council unless, you know, of a statute or

10


1 regulation that you could cite to me, I don't see

2 a reason in the world why this can't be done.

3 MS. WOOLFORD: Rich, I understand

4 your position. I think that you might be

5 conflating a couple things; that the Public

6 Health Council meetings are public and we do

7 discuss rule proposals during those before they

8 are published in The Register, but I'm not aware

9 of an instance where we would have a public

10 hearing before anything is ever published in The

11 Register.

12 And Genevieve Raganelli, who works

13 in our office of Legal and Regulatory Compliance

14 just came in, so she may be able to opine on

15 whether or not we would have a public hearing

16 before a rule proposed is published in The

17 Register.

18 MR. GROSS: Ma'am, if you would be

19 so kind to just state your name for the record.

20 MS. RAGANELLI: I thought she just

21 did.

22 MR. GROSS: I apologize.

23 MS. RAGANELLI: It's Genevieve

24 Raganelli and I'm a regulatory officer in the

25 Office of Legal and Regulatory Compliance.

11


1 MR. GROSS: Thank you, ma'am. I'm

2 sorry.

3 MS. RAGANELLI: Ordinarily, if a

4 statute requires us to have a public hearing, we

5 would have a public hearing, but in this case,

6 there's no requirement to have a public hearing.

7 Usually we don't have a public hearing unless a

8 sufficient public interest in response, in this

9 situation, where there's no statute.

10 We would generally not have a public

11 hearing unless, in response to comments on the

12 proposal, there was a sufficient number of

13 requests. So typically, that's around, I think

14 the Office of Administrative Law standard is

15 about 25 or 50 comments.

16 I would have to look it up, so if 25

17 commenters or 50 commenters were to say, we want

18 to have a public hearing on this, then we would

19 have a public hearing. But what happens in a

20 public hearing is people say their comments,

21 there's no back and forth. They're simply

22 submitting comments on the rule.

23 It's the equivalent of submitting

24 something in writing because in response to

25 comments at the public hearing we simply take

12


1 their comments. We don't respond to them then

2 and there.

3 We would respond to them in the

4 notice of adoption as if they had submitted a

5 written letter so it doesn't really serve a large

6 benefit to have people come and say what we're

7 simply going to take the transcript and treat it

8 like a letter. I'm gathering that there may be a

9 concern about this rule?

10 MR. GROSS: Yes.

11 MS. RAGANELLI: And what we were

12 thinking was that by proposing it, we would be

13 soliciting public comment and that would be the

14 opportunity for the department to receive input

15 from the regulated community from people who

16 might be in opposition to it and people who might

17 be for it.

18 Proposing it doesn't mean it's going

19 to be adopted necessarily, but that is how we

20 would treat it, so we consider the proposal

21 process an opportunity to solicit comments on a

22 proposal and to solicit public opinion. So if

23 you're concerned about simply allowing this to go

24 forward as a proposal, I would say it would be

25 premature because by letting it go forward for

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1 proposal, it doesn't mean you approve it.

2 It simply means you are exposing it

3 to public comment, so I would suggest you let it

4 go forward in that it is an issue of concern.

5 And considering the fact that New Jersey

6 apparently is the last state in the union that

7 doesn't permit this activity to go forward.

8 We are aware of most recently the

9 state of Wisconsin was the last state and they

10 had a lower court ruling finding that this was

11 unconstitutional. And not only in that case, did

12 they declare it unconstitutional, but they

13 declared the cap of $50,000 unconstitutional as

14 well.

15 So we considered this an opportunity

16 to regulate a business that may be going on

17 underground anyway, but at least we could have

18 minimum health and safety standards applicable to

19 it. So we encourage you to recommend the

20 proposals go forward and then we would look at

21 the comments and you would have the opportunity

22 to look at the comments at that point. Thank

23 you.

24 MS. WOOLFORD: Just to circle back

25 and clarify one thing that you mentioned in the

14


1 beginning, Genevieve. The public hearing

2 scenario that you laid out would not be triggered

3 until the proposal has been published in the New

4 Jersey Register, correct?

5 MS. RAGANELLI: Right. If there's

6 no statute requiring, generally you don't have a

7 public hearing. It's not our practice because it

8 serves no purpose than more than simply taking

9 comments on a proposal.

10 MR. GROSS: I don't think anyone

11 would object to the fact that we have some people

12 that want to be heard today that I think, in all

13 fairness, we should be allowing them to be heard.

14 MS. RAGANELLI: I wasn't aware that

15 there were people to be heard today.

16 MR. GROSS: There is.

17 MS. RAGANELLI: That is within the

18 board's prerogative to listen to people.

19 MR. GROSS: And to be very fair and

20 be straight with you. Again, I think it was

21 Thursday at five o'clock, I got a copy of this.

22 I can tell you, there's numerous -- we have a

23 county health officer present in the room.

24 There is different county health

25 officers who do want to be heard on this issue in

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1 front of the council. That's why we're going to

2 postpone the vote to next month.

3 MR. CENSULLO: Mickey, if I can

4 still continue. I'm not at all impressed by the

5 state's position. This is an issue that is, not

6 only relevant for this particular consideration

7 of the commenters, but also going ahead and for

8 future votes of the council, I think that the

9 council absolutely should have the right, when it

10 deems appropriate and necessary to allow a rule

11 for public hearing before, so that we can

12 intelligently consider what the public feels

13 before we vote.

14 I personally would like to know what

15 the health officers, the local people, I would

16 love to know what their feelings are on this

17 particular matter before our vote. And I think

18 as the president going forward, I think the

19 council has every right to at any point request

20 the public to come participate and be heard at

21 any hearing that we have before we vote.

22 MR. SAN FILIPPO: I would like to

23 make another comment. I just want to reiterate.

24 I know there is going to be public comment, from

25 what Kaitlyn just said, but I'm only saying that

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1 the council members need, and I particularly

2 need, comments.

3 I need to know who they're going to

4 be sent out for comments and when they're

5 received to the Public Health Council as soon as

6 they have it so we have enough time to review it

7 before we even sit down at a public hearing, if

8 one should be necessary. But we need more time

9 with the information that's sent out.

10 And I would like to know who it is

11 being sent out to, mainly New Jersey Health

12 Association and New Jersey Environmental Health

13 Association, or whether it's going to the

14 Restaurant Association or any other players. But

15 I'd like to know who the players are that you're

16 going to be reaching out for comment that's going

17 to be sent to us hopefully.

18 MR. CENSULLO: I think that when the

19 request for public comment goes out, I think

20 there is a staff concern or requirement that it

21 be published and in the local newspapers as well

22 as the same publication that publishes our

23 meetings. Correct me if I'm wrong.

24 MS. RAGANELLI: If I may, we will

25 distribute the notice of proposal upon

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1 publication to anybody other than, anybody that

2 you indicate, but we already do a form secondary

3 notice. I believe we would send it to, through

4 the New Jersey Links.

5 New Jersey Links so we can post

6 notice of the -- we can distribute it through the

7 New Jersey Links which means all the health

8 officers could get it. I just don't know if

9 you're aware there's litigation pending on this,

10 so we could have, by not going forward with the

11 proposal, we could risk an adverse ruling being

12 imposed on us, wherein, the standard simply goes

13 away completely.

14 It doesn't make the proposal law by

15 simply proposing it, but before you have people

16 come in and submit comment to you without having

17 it being dually published through the Office of

18 Administrative Law, I don't see what the harm is.

19 MR. GROSS: Ma'am, I'm going to tell

20 you, if I may. There's certainly a lot of people

21 who want to be heard on this. Okay? And I'm

22 just going to be straight with you, okay?

23 Somebody help me out. I find out about this at

24 10 after five on Thursday, just going through my

25 emails. Okay?

18


1 I don't think that's enough time. I

2 know for a fact there's some health officers out

3 there, some inspectors that want to be heard on

4 this issue. Certainly out of respect at everyone

5 here in the room. Certainly I want to hear from

6 Mr. Manley and his staff on this issue, but in

7 all fairness, the people are here. I don't see

8 the reason why they shouldn't be heard

9 MS. RAGANELLI: They're physically

10 here now?

11 MR. GROSS: Yeah.

12 MS. RAGANELLI: There's nothing to

13 prevent them from speaking now. I though you

14 meant holding up the proposal going forward.

15 MR. GROSS: We're going to hold it

16 up to the next meeting because I know there is

17 more people who want to speak on this issue.

18 Right now, not that it would matter, I would vote

19 against it right now. I'm going to tell you

20 right now.

21 MR. RAGANELLI: I understand. I do

22 wanted to mention that Mr. Centifonti and Mr.

23 Manley did hold a meeting with their public

24 health officers advisory groups so they did have

25 an opportunity to weigh on the --

19


1 MR. GROSS: Mr. Manley had a meeting

2 with, I guess, the County Health Officers

3 Association?

4 MS. RAGANELLI: An ad hock group of

5 people that advise him on matters.

6 MR. GROSS: Two things I can tell

7 you. There was not a member of the Public Health

8 Council even made aware of the meeting. And I'm

9 not knocking Bill Manley. He's a great guy.

10 Number two, the Health Officers Association, one

11 gentleman who I think is the president right now

12 was not aware is Chris (inaudible) is who I'm

13 talking about. He was not aware of it. So I

14 mean, in all fairness, let's everybody have a

15 chance to discuss it and the whole bit.

16 MR. SAN FILIPPO: I just want to say

17 that this document was just finalized last

18 Friday, this past Friday. I spoke to Bill, and

19 he indicated that to me. And I don't think that

20 document was shared with anyone so far.

21 MS. RAGANELLI: You are the first to

22 see it.

23 MR. SAN FILIPPO: This document has

24 to be shared in its proposed form.

25 MR. GROSS: Let's move forward

20


1 today. And obviously we'll ask for a vote be put

2 off for a different time, but I know Mr. Manley

3 is here and Gary Centifonti. These two

4 gentlemen, just for the record, state your name

5 and your title and then that way our court

6 reporter will pick up what you have to say.

7 MR. MANLEY: William Manley,

8 environmental scientist, retail food project

9 coordinator, New Jersey Department of Health.

10 MR. CENTIFONTI: Gary Centifonti,

11 Department of Health. I'm the director for

12 Consumer and Environmental Occupational Health

13 Service. And this service is where the program

14 was located within the department.

15 MR. GROSS: Mr. Manley, I think you

16 said you wanted to explain this law to everyone.

17 If you would be kind enough to go at it a little.

18 MR. MANLEY: First off, it's not a

19 law. This is not the proposed legislation

20 regarding cottage foods. This is an independent

21 rule revision. It's part of Chapter 24, the

22 Chapter 24 Rules are Sanitation and Retail Food

23 Establishments and Food and Beverage Vending

24 Machines.

25 The rules currently prohibit any

21


1 type of private home kitchen being used for foods

2 that are going to be used for retail sale. The

3 current rule prohibits private home kitchens for

4 that purpose.

5 This proposal has to do with

6 introducing a new subchapter to Chapter 24 that

7 would permit cottage food operations in New

8 Jersey. That would be our proposal is very

9 briefly that its foods that are prepared in a

10 private home kitchen. We have specified the

11 types of foods that would be permitted.

12 These are non-TCS foods that do not

13 require refrigeration or temperature control at

14 any point. There would be a state permit that

15 would be issued by the department upon

16 application review from the applicants. The

17 application would be reviewed from the state. If

18 everything checks out, there's a self-inspection

19 check sheet on there.

20 There is a specification for the

21 foods that they're going to serve. And with

22 that, the local health department inspection

23 would not be required of that private resident's

24 kitchen.

25 MS. RAGANELLI: Mr. Manley, is there

22


1 an exception to the prohibition?

2 MR. MANLEY: An exception to?

3 MS. RAGANELLI: In other words,

4 nobody is allowed to sell anything that they make

5 in a home?

6 MR. MANLEY: Currently right now,

7 for charitable bake sales, they would be

8 permitted.

9 MS. RAGANELLI: So people who are

10 selling food that they make at home right now.

11 MR. MANLEY: They are under limited

12 circumstances. If it's for charity, charitable

13 bake sales have been exempted from the private

14 kitchen requirement.

15 MR. CENSULLO: For the sake of us

16 here, could we have Mr. Manley make a

17 presentation?

18 MR. GROSS: He's doing just that.

19 MR. CENSULLO: And wait for the

20 questions until after he's finished?

21 MS. RAGANELLI: I apologize. Sorry.

22 MR. MANLEY: You have the proposal

23 in front of you of what the proposed regulations

24 would be. It would be a new subchapter in the

25 Chapter 24 regulations, Subchapter 11. Again, we

23


1 define what a cottage food product is.

2 It's a non-TCS food and we include

3 examples of the foods, the types of foods that

4 would be permitted. We have a definition for

5 cottage food operator. And that's anyone who

6 holds a New Jersey cottage food operator permit.

7 We are looking to define major food allergen,

8 okay.

9 We referred to, that's not currently

10 defined in Chapter 24 rules. We would be looking

11 to change the definition of retail food

12 establishment that exists to allow this type of

13 activity to occur in private cottage food

14 operator home.

15 MS. RAGANELLI: Are there any

16 training requirements, Mr. Manley?

17 MR. MANLEY: I'm not finished yet.

18 MS. RAGANELLI: Okay. Sorry.

19 MR. MANLEY: On the application, we

20 were requiring the cottage food operator to be,

21 have passed an accredited food safety training

22 food certification program. Meaning, ServSafe or

23 National Registry or any other food manager

24 certification program.

25 On the self-inspection check sheet,

24


1 they would identify that they are preparing the

2 foods under certain circumstances and that

3 unnecessary persons, pets, et cetera, would be

4 excluded from the kitchen during any hours of

5 preparation.

6 Does everyone have that application?

7 Were you provided for that application?

8 AUDIENCE: No.

9 MS. PENNANT: It's not in the

10 packet. I can post it to the web after the

11 meeting if anybody wants to see it.

12 MR. GROSS: Thank you.

13 MR. MANLEY: That would be submitted

14 to the State Health Department for review. If

15 there are any deviations or questions on that,

16 the application would be returned or rejected.

17 If it's found to be acceptable, then a cottage

18 food operator permit would be issued.

19 On that permit, we would identify

20 the types of foods that the operator has been

21 approved to sell. They would have a permit

22 number and that cottage food operator permit

23 number would be displayed wherever they sale

24 there wares, whether it be at a temporary food

25 establishment, temporary food event, a farmers

25


1 market, that type of event that would be

2 typically used for this type of activity that

3 we're seeing throughout the state. And that's

4 what we're looking to propose.

5 MR. SAN FILIPPO: I know we're going

6 to hold comments. The initial reference is that

7 this is for charitable organizations, for the

8 benefit of charitable organizations. But in

9 8:24-11.3, you point out --

10 MR. MANLEY: Dennis, let me

11 interrupt you for a moment. This is not for --

12 currently right now, the Chapter 24 rules exempt

13 charitable bake sales. This is not what we're

14 talking about. This is foods for retail sale.

15 It has nothing to do with the charitable

16 organization.

17 MR. SAN FILIPPO: I'm just going

18 through the ones that they are and that's the

19 homeowner consumer, a farmers market or farm

20 stand, temporary retail food establishment, so I

21 just don't want it to sound like it's for the

22 benefit of just categorization. It does go

23 beyond doing a bake sale.

24 MR. MANLEY: The current rules allow

25 you to do that for a bake sale. We're proposing

26


1 a rule change that would permit this other

2 activity independent of charitable bake sales.

3 MR. SAN FILIPPO: Right. I wanted

4 to make sure I understood it.

5 MR. GROSS: Mr. Manley, you want to

6 keep going there, please?

7 MR. MANLEY: Did we leave anything

8 out? I think that's the overview.

9 MR. GROSS: Do you have any problem

10 with answering some questions?

11 MR. MANLEY: No. We are limiting

12 the income to putting a cap of $50,000. No

13 internet sales. Everything, all of the sales

14 need to be direct to the consumer and we do

15 specify the locations where those goods could be

16 sold.

17 MR. GROSS: Mr. Manley, are you okay

18 if some people have some questions? Are you okay

19 with that? Answering some questions?

20 MR. MANLEY: Sure.

21 MR. GROSS: Counsel?

22 MR. CENSULLO: Mr. Manley, just a

23 few quick questions. Will the local health

24 departments be notified of the places within

25 their jurisdictions?

27


1 MR. MANLEY: Part of the application

2 was that the operator would have to get local

3 zoning approval and any local requirements to

4 operate a business from their home, so that would

5 be part of it.

6 MR. GROSS: That would be in writing

7 from the zone office, Bill?

8 MR. MANLEY: Yeah. On the

9 application form, we have that they certify that

10 they have local approvals.

11 MR. CENSULLO: What about the local

12 health officer?

13 MR. MANLEY: The local health

14 officer? No, not necessarily. We are proposing

15 to create a database for all the permit holders

16 and that database would be available, I believe,

17 on our web page.

18 MR. CENSULLO: Okay. Now, if there

19 is a full blown outbreak that might be linked to

20 the sale, I know you would think it's unlikely

21 because of the type of food that they're

22 producing. However, if there was, who would be

23 responsible for the investigation of the food

24 borne illness that might be tracked to one of the

25 products that are being sold? Would that be

28


1 local or the state?

2 MR. MANLEY: Our proposal, because

3 we are the State Health Department is the

4 permitting agency, we would probably take the

5 lead on complaint investigations or food borne

6 illness investigations, but I think we would

7 always do that with the cooperation of the local

8 health departments for that activity.

9 MR. CENSULLO: The local health

10 departments don't know that these places exist

11 within their community, it might be a little

12 difficult, but anyway, that's something that

13 we --

14 MR. MANLEY: In that case, what I

15 foresee, if there was a complaint about a product

16 that required investigation, that would go

17 through our office. We would make an assignment

18 to investigate and we would probably ask the

19 local health department to accompany us on the

20 investigation.

21 MR. CENSULLO: Now, you indicate

22 that these homes would not be subject to local

23 jurisdiction or inspections. However, would the

24 locals be able to, if it received a complaint or

25 are they prohibited?

29


1 MR. MANLEY: No, I don't think

2 anyone in this would preempt or prevent the local

3 health department from investigating a residence.

4 I don't believe that the local health departments

5 want to be in the business of routinely

6 inspecting private home kitchens, so that's why

7 we are proposing that this be done without

8 requirement of the local health inspection.

9 Like I said before, in the case of a

10 complaint, I think the complaints, we would, our

11 directive would be for the complaints, if

12 received by a local health department, that they

13 be run through our office because we hold the

14 permits and then we would coordinate some type of

15 response.

16 MR. SAN FILIPPO: This question is

17 directed to Bill specifically because we're on

18 this topic. 8:24.2.1, it says specifically that

19 the local health is excluded from local

20 inspecting by a local health authority.

21 Yet, 8:24-1.5, it gives the health

22 authority the right and authorizes them to enter,

23 examine and survey the premises including the

24 cottage food operator. Can you tell me how those

25 two things that seem to be contradictory right

30


1 now came into play?

2 MS. RAGANELLI: What was the first

3 citation you gave, sir?

4 MR. SAN FILIPPO: The first citation

5 was 8:24-2.1. It mentions that the foods

6 prepared in the kitchen that is not subject to

7 regulation, any inspection by the local health

8 authority. But yet on page 23, 8:24-11.5, under

9 the health authority's right to access.

10 It specifically says a health

11 authority is authorized to enter upon, examine

12 and survey any premises, including home kitchen

13 of a cottage food operator and things thereat

14 including materials, equipment, books and

15 records. So I'm just trying to find out why one

16 contradicts the other or how that comes into play

17 in your mind, Bill.

18 MS. RAGANELLI: What page is 2.1?

19 MR. SAN FILIPPO: It's on page 23 of

20 the document that was sent to us.

21 MS. RAGANELLI: Where is the first

22 citation? On what page does that appear?

23 MS. SAN FILIPPO: The first citation

24 is on page two of the document. Does that help?

25 The first section.

31


1 MR. MANLEY: Well, let me add,

2 that's why we're doing this. That's why we're

3 doing this.

4 MS. RAGANELLI: That's the existing

5 rule?

6 MR. MANLEY: That's the existing

7 8:2.1C currently prohibits this activity.

8 MR. SAN FILIPPO: As proposed.

9 MR. MANLEY: No, not as proposed.

10 The existing rule, current rule in Chapter 24,

11 prohibits the operation of a retail food

12 establishment in a private home. The intent of

13 this is to allow that activity instead of

14 prohibiting it.

15 MR. SAN FILIPPO: But that

16 contradicts what you're saying before that it's

17 being proposed that the health authority is not

18 subject to regulating the cottage food.

19 MS. RAGANELLI: May I respond?

20 MR. GROSS: Yeah, sure.

21 MS. RAGANELLI: If you go to page

22 17, sir. Also, could you turn your microphone

23 down a little bit, sir, because it's hard to

24 understand you. So it's a little double

25 negative, but the way the rule is laid out, if

32


1 you're acting like a retail food establishment,

2 you have to comply with these standards

3 applicable to retail food establishments.

4 You're not a retail food

5 establishment under current law, if you prepare

6 food in your kitchen and sell it for charitable

7 purposes. So if you see at the top of the page

8 it says excludes. It refers to a retail food

9 establishment excludes.

10 And then if you go down to the

11 paragraph sort of in the middle of the page that

12 says, (2), a retail food establishment excludes a

13 kitchen in a private home that produces food that

14 is non-TCS and is prepared or sold or otherwise

15 relinquished to the consumer in accordance with a

16 cottage food operator permit.

17 So basically we're saying that's not

18 retail food activity. That is a separate

19 activity, and that's why we would not routinely

20 require you to do the local inspection as a local

21 health officer if it's for one of these purposes.

22 It doesn't mean you lose the right

23 to enter into any premises pursuant to the

24 commissioner's statutes at Section 11.5 which

25 lists the right of a health officer, a health

33


1 authority which includes a local and state health

2 authority to enter onto any premises as long as

3 it's for the purpose of enforcing a health law

4 under the officials jurisdiction.

5 MR. GROSS: Dennis?

6 MR. SAN FILIPPO: I think it's still

7 cloudy. I think that should be cleaned up to be

8 a little more specific than what it is.

9 MS. RAGANELLI: I believe Mr. Manley

10 is in the process of revising the chapter, so if

11 there's any unclarity, we might be able to

12 address it then. But right now, we've looked at

13 it and it eliminates the prohibition on sales

14 from your private kitchen if you have a cottage

15 food operator permit.

16 It doesn't prohibit a health officer

17 from going on the premises if they're enforcing

18 another health law under their jurisdiction. For

19 example, if you were doing an epidemiological

20 investigation following an outbreak.

21 MR. GROSS: So we cannot go out and

22 do a regular inspection like we do twice a year.

23 MS. RAGANELLI: We're not requiring

24 you to.

25 MR. GROSS: We could not even do it

34


1 at that point, correct?

2 MS. RAGANELLI: We're not requiring

3 it as a prerequisite to obtain the permit. If

4 there was some reason, you would ask Mr. Manley.

5 And if it was imperative, Mr. Manley --

6 MR. GROSS: Mr. Manley, correct me

7 if I'm wrong, a local health inspector would not

8 have the legal right to inspect this kitchen; is

9 that correct? Or yes or no?

10 MR. MANLEY: What we're doing in the

11 Chapter 24 rule is we're exempting a private

12 resident kitchen from inspection from the Chapter

13 24 regulations. The question would be what would

14 you be inspecting under.

15 We've kept in the your ability to go

16 into and investigate and examine, et cetera, in

17 Subchapter 11 to allow you to go in there, in the

18 case of a complaint or a food borne illness

19 investigation.

20 MR. GROSS: They couldn't do a

21 routine inspection?

22 MR. MANLEY: I wouldn't think so,

23 no. I don't think you would want to do a routine

24 inspection of these facilities.

25 MS. WOOLFORD: Mr. Manley, just for

35


1 point of clarification, is the intent of this to

2 preclude health officers from doing it, or just

3 making it optional for them to do it?

4 MR. MANLEY: It's an option. I

5 would think it's more optional.

6 MS. WOOLFORD: So it's more that

7 this section allows for these inspections to

8 happen, but is not required by the health

9 authority to do them?

10 MR. MANLEY: That's correct.

11 MS. WOOLFORD: Thank you.

12 MR. CENSULLO: My last question,

13 Bill, is the regulation that we're talking about

14 is based on Title 24, which is the statute

15 created by legislators. We have the ability

16 administratively to amend that which is what

17 you're doing by the administrative code.

18 Now, there is two pieces of

19 legislation. One is Senate Bill on the 73 and

20 Senate Bill 2315. Can you tell me how that

21 interacts with what you're doing?

22 MR. MANLEY: I'll turn that over to

23 Genevieve.

24 MS. RAGANELLI: We did mention the

25 fact that there is legislation proposed by the

36


1 legislature, which has been around for some time

2 now, and it's at various stages of review.

3 However, the note regulation, note rule can amend

4 a statute. We are not amending Title 24 of the

5 New Jersey statutes.

6 We are acting within the statutory

7 authority of the department to regulate food. If

8 the bill that are pending were to become law, we

9 say right in here that we would act accordingly

10 in revising the proposal to address -- we say

11 that at page three.

12 At the bottom of page three, we note

13 that several bills are pending before the

14 legislature that would authorize the prohibited

15 activity, and they're in various stages of

16 legislative action.

17 The department will monitor the

18 progress of these bills to ensure consistency and

19 the proposed amendment and new rules with any of

20 these bills that might become law following

21 publication of the notice of proposal.

22 MR. CENSULLO: You understand that

23 we all are on the same page that should this

24 legislation become law, it would supercede

25 anything we're proposing at this point.

37


1 MS. RAGANELLI: It might be

2 consistent with it. You don't know that it would

3 supercede it. It might be consistent because I

4 believe Mr. Manley attempted to track the bill to

5 a certain degree.

6 MR. CENSULLO: Okay. Okay. I don't

7 have any other questions at this point.

8 MS. WOOLFORD: Just for a point of

9 clarity, any time that there is legislation that

10 becomes enacted into law, and to the extent it

11 conflicts with regulations, it would supercede.

12 But that would have to depend on the

13 form and format it takes once it is passed, if it

14 is passed. And then an analysis would be

15 conducted by the program and by our law office.

16 MS. RAGANELLI: If necessary, we

17 might have to repropose the proposal to

18 correspond to the bill if it became law and if

19 there was anything in conflict.

20 MR. CENSULLO: Okay.

21 MR. GROSS: Counsel, you wanted to

22 speak on this whole issue?

23 MS. RAGANELLI: I just had a couple

24 of questions for Mr. Manley. Mr. Manley, if I

25 were to go to a charitable bake sale right now

38


1 and purchase food that was prepared in a home

2 kitchen, will the person that baked that have

3 received training in how to make sure the food is

4 treated safely?

5 MR. MANLEY: No.

6 MS. RAGANELLI: If I was to purchase

7 food at that bake sale, would it bear label

8 telling me what exactly the ingredients are and

9 whether or not there was major food allergens in

10 the food?

11 MR. MANLEY: No.

12 MS. RAGANELLI: Would it have the

13 address of the baker?

14 MR. MANLEY: No.

15 MS. RAGANELLI: So people are buying

16 this food now without having this information

17 provided to them?

18 MR. MANLEY: Yes.

19 MS. RAGANELLI: And under the

20 current proposal, we would require home bakers to

21 have training in food safety. Yes?

22 MR. MANLEY: Yes.

23 MS. RAGANELLI: And would we require

24 them to adhere to a list of standards that make

25 sure they treat the kitchen in a clean way such

39


1 as in the check list?

2 MR. MANLEY: Yes, there is a

3 self-inspection check sheet where they would

4 attest to doing those things.

5 MS. RAGANELLI: Would they have to

6 disclose to you every ingredient in every food

7 product they plan to make in their notice of

8 application?

9 MR. MANLEY: They won't have to --

10 MS. RAGANELLI: The list of

11 ingredients?

12 MR. MANLEY: In our application, we

13 are listing -- we are asking for a list of every

14 food product that they're going to make with a

15 list of all the ingredients that would be in that

16 product.


18 identify any of the major food allergens that

19 were going to be in the food?

20 MR. MANLEY: That would be on the

21 label, if it's prepackaged food.


23 list the address of where the food was made in

24 case there was any problem they could contact --

25 MR. MANLEY: Yes, and their permit

40


1 number.

2 MS. RAGANELLI: I think that's it.

3 Thank you very much.

4 MR. GROSS: Mr. Manley, I have a

5 couple questions. Number one, you did state you

6 would have to have something in writing from the

7 zoning office?

8 MR. MANLEY: Not necessarily

9 something in writing. They would have to agree

10 they checked with zoning and they were allowed to

11 do that in their town.

12 MR. GROSS: Is there any component

13 in there about the fire department or fire

14 inspector being made aware of it?

15 MR. MANLEY: No, nothing for that.

16 There is a question on the application regarding

17 their well water, if they're on a private well or

18 if they're on city. If they're on private well,

19 then they need to provide testing of that, but no

20 code enforcement inspections.

21 MR. GROSS: So the local fire

22 department doesn't need to be notified or even be

23 made aware of this?

24 MR. MANLEY: I don't believe so.

25 MR. GROSS: The other thing is, I

41


1 guess you had a hearing or a meeting on this.

2 Was anybody from the Restaurant Association at

3 that meeting and did they chime in?

4 MR. MANLEY: We have been holding

5 Chapter 24 revisions meetings for the last year

6 and-a-half with our Chapter 24 Committee. The

7 committee is made up of representation from the

8 New Jersey Food Council, the New Jersey

9 Restaurant Association, the New Jersey

10 Environmental Health Association, New Jersey

11 Association of City and County Health Officers,

12 the FDA, Rutgers University.

13 So we've got a lot of different

14 parties that have been involved with our

15 meetings. Related to cottage foods, we held a

16 meeting last month with our Chapter 24 Revisions

17 Committee members. Also at that meeting was

18 representation from the New Jersey Bakers Board

19 of Trade.

20 We've identified them as possibly an

21 interested party in this. And at that point, we

22 discussed our proposal with our group and we got

23 feedback from everyone. We got a lot of good

24 questions and a lot of good feedback from that.

25 But at no point during that, or afterwards, was

42


1 anyone opposed to what we were proposing to do.

2 MR. GROSS: You're saying that the

3 Restaurant Association was in favor of this?

4 MR. MANLEY: Restaurant Association

5 had no objections.

6 MR. GROSS: They had no objections?

7 MR. MANLEY: No objections. If I

8 recall, they had one comment during the meeting.

9 They were concerned that, and we put it in the

10 rule. We included it in the proposal. They were

11 concerned that someone doing this could have on

12 site consumption of the food and then that would

13 make them like a cafe or something.

14 So they wanted to make it clear that

15 there was no on site consumption of the food. If

16 you went to the cottage food operator's house and

17 purchased your product there and got it handed to

18 you, that would be an acceptable, but we don't

19 want on site consumption of the food.

20 MR. GROSS: Does anyone else have

21 any questions for Mr. Manley? Just state your

22 name for the record before you ask a question so

23 that our stenographer can pick right up on it.

24 MS. JALINOS: I just wanted to

25 confirm. You did say that the address of the

43


1 person making the food would have to be on the

2 label. That would be their home address.

3 MR. MANLEY: Yes. That would be on

4 the label. I believe, they would have to meet

5 the requirements of the general labeling

6 regulations. Now there may be an exception to

7 that.

8 If their business is listed in the

9 phonebook, then they may not have to be the

10 street address, but they would have to put the

11 town. But I think in most cases it would come

12 down to them putting their actual address on the

13 label.

14 MS. JALINOS: And I just saw the

15 costs associated with this would be $100 permit

16 fee. And what about costs associated with their

17 training and certification that they have to go

18 through?

19 MR. MANLEY: Well, they would have

20 to pass an accredited food safety program,

21 whatever the costs are, and some of those are

22 available on-line. There's on-line testing or,

23 you know, where you go to a training class. But

24 meeting the parameters of the accredited exam and

25 currently there are five in the state that are

44


1 accepted.

2 MS. JALINOS: As the health people

3 from the health department, were they going to

4 speak to their opinions on this?

5 MR. GROSS: I'm sorry, ma'am?

6 MS. JALINOS: I was curious if the

7 people from the health department were going to

8 speak to their opinions on this.

9 MR. GROSS: I think there's a few

10 members here today.

11 MS. CUCUZZELLA: We're here to ask

12 questions and get clarification. It's Holly

13 Cucuzzella, the health officer for Burlington

14 County. I do have some of the notes from that

15 Chapter 24 subcommittee meeting and I know that

16 they left a lot of questions unanswered, so they

17 might not have the full picture as that meeting

18 probably went back and revised the bill based on

19 their feedback.

20 So it was a discussion they didn't

21 have a copy of the regulations at the time when

22 they saw that. But I guess my first question is,

23 is you said the bill gives us or the regulations

24 give us the right to enter, but then once we're

25 in the home, then what?

45


1 Because we don't have regulations to

2 say we see a cat on the counter, we see this, we

3 see that. How do we then proceed in regulating a

4 home because you can't use Chapter 24?

5 MR. MANLEY: And this came up in our

6 meeting and this was a really positive piece from

7 that meeting that we were able to get from the

8 health departments. Actually, somebody from the

9 industry chimed in on it and that's why we are

10 introducing a self-inspection check sheet where

11 the operator will attest, confirm and sign at the

12 bottom that they agree to this, this and this.

13 And that would be the basis of the investigation.

14 MS. CUCUZZELLA: Will that be in the

15 regulation?

16 MR. MANLEY: Yes, the appendix

17 right?

18 MS. RAGANELLI: Yes. The form is

19 part of the rule.

20 MS. CUCUZZELLA: Right. So where it

21 says that the department may impose monetary

22 penalty, failure to comply, will it specifically

23 say the check list? When staff goes out, they

24 need a very clear guideline as to what they're

25 inspecting because the way it is right now, there

46


1 could be a lot of subjective review of what's

2 going on in somebody's home.

3 MR. MANLEY: Agreed. Again, as I

4 see this happening because we are the permitting

5 agency, I don't foresee the departmental calling

6 up to the local health department saying we got a

7 complaint about this permitting.

8 I think we would take the lead in

9 the investigation, so we would be the ones who

10 would be looking at this inspection check sheet

11 that they've attested to and that's what we would

12 be using as our guide.

13 MS. CUCUZZELLA: So I guess, does

14 your department have enough staff to handle this?

15 And how do you anticipate the number of

16 complaints? Just our county gets hundreds of

17 complaints a year. Not all of them directly

18 related to people operating home and food

19 businesses, but a lot of them are.

20 And I know a lot of health officers,

21 our fundamental concern is there's a history and

22 pattern of the state health department saying,

23 we're going to do this, a year later you realize

24 it's too much work and then it comes to us and we

25 don't get any of the money of the permitting

47


1 fees, and now we're stuck doing additional

2 inspections with no money when we already

3 struggle to complete our inspections a year.

4 So our concern is that after a year,

5 when you realize we have thousands of home bakers

6 and there's complaints coming in because this

7 home baker considers that one competition, so

8 they're calling complaints on each other, which

9 is what happens now, then the state health

10 department can't handle the case load and it's

11 going to come back to the local health

12 departments.

13 MR. CENTIFONTI: We did make that

14 argument to our senior folks about staffing and

15 having a number of staff on board. Not only for

16 the field component, but also to handling the

17 issue of the actual permit issuance itself, so we

18 are working on that for additional staffing.

19 MS. CUCUZZELLA: And then in terms

20 of notifying the local health departments, it

21 would be very beneficial because a lot of times

22 we're out at community events, farmers markets

23 and if we come upon somebody selling their items,

24 and let's just say they don't have the sign out,

25 how do we confirm that they're actually a

48


1 registered home baker without having that list or

2 having access to a database to ascertain that

3 they have achieved all of the appropriate steps?

4 MR. MANLEY: I think that's

5 important that we have that on our web page. But

6 the regulation would require them to present

7 their permit to you. And that's one of the

8 benefits that we see with this provision is that

9 there's a lot of confusion right now with farmers

10 markets and temporary food events where you may

11 have operators that are on the borderline,

12 whether or not they are legitimate businesses or

13 they prepare from home.

14 And it's from a regulatory

15 enforcement standpoint, I believe it's very

16 difficult for the health inspector on the point

17 of sale to make determinations and then they're

18 looking for show me their license for the

19 municipality that your base of operations is

20 from, show me your inspection from there. Oh,

21 well, I use Sal's Pizza and he gives me a letter.

22 So there's a lot of confusion out

23 there about the legitimate source of these foods

24 that are being sold at farmers markets and

25 temporary food events. This, with a state

49


1 permit, would clarify that where the operator

2 would be permitted to sell what they say is on a

3 permit.

4 And the local health department

5 official would just look at that permit, look at

6 the product, make sure that it's properly

7 packaged, properly labeled, et cetera and then

8 move on.

9 MR. SAN FILIPPO: In relation to

10 this matter, we talked about the cottage food

11 operator and that operator's residence. Is this

12 to be a standing residence, single family home or

13 is this an apartment complex or any other thing?

14 MR. MANLEY: We're not making the

15 distinction in our rule.

16 MR. SAN FILIPPO: I think you have

17 to, Bill, because if it's an apartment, you're

18 going to get people cooking all day long. When

19 you look at this, Bill, it looks like an

20 opportunity for someone to make up the $50,000

21 selling baked goods out of their house.

22 And I think that this could really

23 result in a lot of complaints, or potential

24 complaints, at the local level. We have to know

25 that this is a single family dwelling where it

50


1 doesn't impact any other neighbors or residents

2 residing, that happen to reside in the same

3 building, and I think that that should be pointed

4 out.

5 MR. MANLEY: So are you suggesting

6 that it be an owner operated residence?

7 MR. SAN FILIPPO: Owner operated

8 single family dwelling, yeah, not being allowed

9 to be run in an apartment house or condo.

10 MR. MANLEY: So we believe we've

11 covered that with the local zoning approval for

12 that activity.

13 MR. SAN FILIPPO: Yeah, but it

14 should be clear here. If you just define

15 residence, single family dwelling, it would have

16 no impact on anyone else but themselves. You

17 could definitely get a complaint if it's not

18 specified and people are cooking all night and

19 the odors are going through the --

20 MR. MANLEY: I agree with that.

21 MS. RAGANELLI: If there were rules

22 in a multi family dwelling, such as an apartment

23 complex prohibiting this activity, then the

24 proposed new rules would not override them. Just

25 because one can get a permit from us doesn't mean

51


1 that they can engage in that activity in their

2 apartment.

3 If the apartment complex or the

4 condominium association had a prohibition in

5 their facility rules, then those would apply.

6 This doesn't override those rights. That's why

7 we said the zoning rule will call this zoning any

8 local rules.

9 MR. GROSS: And hopefully fire, if

10 you want to know the truth.

11 MS. RAGANELLI: Facility rules. And

12 in response to the lady from Burlington County,

13 you mentioned how would you know if this person

14 is operating pursuant to the food operator permit

15 if they don't have a sign up.

16 The food product itself will have

17 the permit number on it. So if you see the food

18 is not properly labeled, then you'd have to say

19 what gives you the right to be here.

20 MS. CUCUZZELLA: Right. So then it

21 goes to -- let's just say they're not a permitted

22 home baker. At that point in time our staff

23 would have to shut them down, right?

24 MS. RAGANELLI: Well, I think that

25 would be a violation of the Retail Food Code that

52


1 they're engaging in the retail sale of food.

2 MS. CUCUZZELLA: Right. And then we

3 turn that over to you?

4 MR. GROSS: But how do you shut them

5 down? That's my question.

6 MS. CUCUZZELLA: Right.

7 MS. RAGANELLI: How would you shut

8 down any business that is operating without

9 complying with local retail food?

10 MS. CUCUZZELLA: Chapter 24.

11 MS. RAGANELLI: Then you would apply

12 Chapter 24. If the person doesn't have a cottage

13 food operator permit, then they're not allowed to

14 sell food unless they comply with the retail food

15 code.

16 MS. CUCUZZELLA: Right. So the next

17 step, we shut them down, we send them home from

18 the farmers market or whatever. According to

19 this, the department handles the monetary phase,

20 so then we turn it over --

21 MS. RAGANELLI: No, we would be

22 responsible --

23 MR. MANLEY: They're not a cottage

24 food operator.

25 MS. CUCUZZELLA: I get it now. Just

53


1 to play devil's advocate because we had this

2 problem with a regular retail food establishment.

3 We had somebody that was refusing to shut. They

4 didn't have any hot water. They were refusing to

5 shut. We thought we were going to have to go get

6 a court injunction.

7 So this person, if they don't want

8 to leave, they're still selling their stuff.

9 They show up every week, wherever this location

10 is, that is time and money for the health

11 department. Going to court is a labor intensive,

12 time consuming, staff eating process that takes

13 months.

14 So when you did your financial

15 assessment, the local health department was not

16 included when you did your financial assessment.

17 So if we're going to accompany on some

18 complaints, if we're going to have to shut down,

19 if we're going to end up in court, none of that

20 was accounted for.

21 MS. RAGANELLI: Are you saying in

22 this situation where a person does not have a

23 cottage food operator permit?

24 MS. CUCUZZELLA: Mm-mm.

25 MS. RAGANELLI: Then that would

54


1 already be under your jurisdiction under the

2 Retail Food Code. If they have a cottage food

3 operator permit, it falls under the jurisdiction

4 of the department, so unless -- if Mr. Manley

5 involved you, what we're saying is, if they don't

6 have the permit at all, then you treat them as an

7 improperly operating retail food code

8 establishment, so you already have that

9 jurisdiction.

10 MS. CUCUZZELLA: But that's still

11 time and money.

12 MS. RAGANELLI: Right. But that's

13 not because of this rule. You already have that

14 jurisdiction and that obligation. If this rule

15 didn't exist, you would still be shutting her

16 down and going to court.

17 MS. JENKINS: We could also do the

18 enforcement against them because we would issue a

19 cease and desist order, failure to comply. I

20 would think we would take over. We're

21 responsible for permitting.

22 MR. GROSS: Here is the question I

23 know is going to come up. You're going to have

24 one neighbor complaining or possibly even an

25 apartment complex. I can see this happening now.

55


1 Somebody is going to be complaining about the

2 odors and the smoke, the whole thing. That

3 person is going to get on the phone and call the

4 local health inspector.

5 Are you expecting at that point, the

6 local inspector to go out on it because it's

7 technically maybe an odor complaint or a smoke

8 compliant, or is that something that should be

9 sent right to the state? Because I know it's

10 going to happen.

11 There is no one in this room who

12 doesn't know that that's not going to happen.

13 You're going to get somebody who is going to

14 complain about the odors or the noise. Who is

15 going to handle it? Because I'm going to tell

16 you what, the people within City of South Amboy,

17 which I'm the council president of, the first

18 phone call they're going to make is to my local

19 health inspector.

20 No disrespect to Bill, I think the

21 world of you. They're not going to call the

22 state. They're going to call the local health

23 department. So we need to give -- I'm not saying

24 this thing is a good thing, but you need to give

25 clearly, clearly, the authority to the local

56


1 health departments to handle this type of

2 situation.

3 You can't say we're going to send it

4 to the state because, I mean, you send somebody

5 from the state. They might be coming from

6 Trenton to South Amboy. You're talking about an

7 hour each way. By this time, the problem is over

8 or it could be over, hopefully it's over. Or if

9 it's in the City of South Amboy, four blocks away

10 or five blocks away, the inspector shows up and

11 say, hey, you know, cool it.

12 What are they going to do now?

13 Well, I got no authority to tell anybody to do

14 anything. That's going to be the inspector's

15 thing. The inspector is going to say, if the

16 state is going to handle it, the state needs to

17 handle it. You can't have it both ways. Health

18 Office, am I right or wrong?

19 MS. CUCUZZELLA: I agree. I think

20 it's going to get tricky. Most people call us.

21 They'll fill out our on-line complaint form. And

22 then when, you know, they don't get a timely

23 response they're going to be back to us saying

24 why didn't you do this, why didn't you do this?

25 MR. GROSS: Right. And the next

57


1 call is going to be from the mayor, why have a

2 local inspector for if you can't do this?

3 MR. EUGENE: When we get that

4 initial complaint, we're going to respond because

5 we don't know whether they are cottage food or

6 just some person cooking out of their home, so we

7 respond because we don't know. We're going to

8 respond almost 100 percent of the time. And when

9 we get there, that's when we find out.

10 MR. MANLEY: If I were to chime in,

11 I would say that's your job. If there was a

12 complaint about a nuisance complaint about odors,

13 et cetera, in a multiple dwelling, that would

14 fall under you anyway.

15 So our involvement would be with

16 food product itself, the safety of the food. If

17 they apply for a permit, if they were provided

18 with a permit, however they prepared the food and

19 sell the food, that would be our charge. If

20 there's complaints regarding odors and nuisance

21 noise, whatever it may be, that would fall under

22 you as the local health.

23 MR. EUGENE: Once we go out and they

24 show us a permit that they have from you, then we

25 walk away and give you a call again.

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1 MS. RAGANELLI: If I may. If a

2 person has a cottage food operator permit, it

3 doesn't give them permission to violate nuisance

4 rules and code. Nobody is saying you can walk

5 away if they're having something that would

6 violate your local nuisance code and you show up

7 and they say, but I have a food operator permit.

8 Well, good, that gives you an

9 authority to bake. It doesn't give you authority

10 to cause a nuisance in the form of an odor. So

11 you might be handling these now and you don't

12 know it because this was probably an underground

13 activity. Am I correct, Mr. Manley?

14 MR. MANLEY: And the other part of

15 that would be, if there was a follow up on your

16 part to investigate this, that may be a violation

17 of the application if they said that they've

18 gotten zoning for that purpose. That would be

19 something that we would, you know, you would

20 communicate to us that this is not properly zoned

21 and didn't meet the requirements that they signed

22 to on their application and that would be cause

23 for us to get involved somehow as the permitting.

24 MR. GROSS: I got a real simple

25 question. You guys from the state call and say,

59


1 hey, Mickey, do me a favor, we got a problem with

2 this guy and we can't get somebody there, can you

3 go there, knock on this person's door? What am I

4 looking for?

5 I mean, I got state code for

6 restaurants in my pocket. What am I looking for

7 in this person's house? And the second thing is,

8 if somebody is going to be preparing food, and

9 okay, they're making fudge or something, are they

10 allowed to have pets in their house?

11 MS. RAGANELLI: No. They're allowed

12 to have pets but not in the kitchen.

13 MR. GROSS: But no disrespect,

14 ma'am, but my dog had -- passed away, but my dog

15 had access to every point in my house. I

16 certainly didn't keep my dog out of my kitchen,

17 especially the kitchen.

18 Or how do you permit, and no

19 disrespect, how do you permit an infant who is

20 walking around this and that, and all of a sudden

21 how do you prevent them from going in the kitchen

22 when you're preparing food?

23 MS. RAGANELLI: Baby gates.

24 MR. GROSS: I mean, and again, I'm

25 walking in and I'm saying, all right, you got a

60


1 nice house here, you got a beautiful house and

2 the whole bit, what am I looking for? Am I

3 looking for apartments -- probably not.

4 Obviously, temperature is not really an issue

5 here, but I mean, there is too many variables for

6 us to investigate.

7 I mean, it's either got to be done

8 by the state or done by the locals or the whole

9 bit. I think that's why a lot of health officers

10 want to be heard on this issue. I know some of

11 them were at a conference in Atlantic City today

12 and that's why they're not here. At least that's

13 what I was told.

14 MS. WOOLFORD: It sounds like the

15 check list that is going to be part of the

16 proposal will lay out a lot of those options.

17 And I think in terms of just going through the

18 variables of a rule, you can do that with any

19 rule.

20 We could do that with any public

21 health or sanitation rule that there are so many

22 variables that you could go down many rabbit

23 holes of scenarios. And I think part of the

24 public comment period is to find the ones that

25 create inconsistencies or require more charity

61


1 for the health authority and that's what the

2 process is intended to do.

3 MR. SAN FILIPPO: I don't think this

4 process really does that. I think it just brings

5 out more potential problems. We talked about the

6 impact statement you discussed. The impact

7 statement doesn't say anything about the impact

8 on the local level.

9 It doesn't say anything about the

10 impact on zoning as to whether they would allow

11 food prep in a residential home or in an

12 apartment complex. I'm sure under zoning, the

13 fire code is going to come in and someone has a

14 state permit for baking.

15 And if there's a fire because of

16 that baking operation, the liabilities. There's

17 a lot of question marks here that have to be

18 thought out. You have to think about the impact

19 on the local level. I think you're going to have

20 more operations like this popping up where people

21 don't have to do anything to make $50,000.

22 You have the small people out here,

23 the small grocery selling the same kind of goods

24 that pay a license, get inspected and make sure

25 they follow a code that we can follow up. So I

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1 think there's a lot of gray areas here, a lot of

2 ambiguities, and I think they have to be touched

3 up and addressed.

4 Because I foresee potentially, as I

5 mentioned before, it should be a single family

6 home, but some zonings might not allow any kind

7 of operation, whether it's a private business,

8 whether it's the county. Those regulations are

9 going to come into play all over the state of New

10 Jersey.

11 And I see some of our local people

12 that were stationary stores doing similar

13 things -- instead of your house. And then the

14 revenue, you don't make revenue to the state

15 because you're going to be issued at 100 dollars

16 a pop.

17 But the locals are going to wind up

18 doing all the grunt work for nothing. And this

19 is going to cause a lot of grunt work in my

20 opinion as it is. I'm done.

21 MS. MARICH: If I can comment on

22 that.

23 MR. GROSS: I'm just going to use

24 the men's room for a minute, but go ahead.

25 MS. MARICH: No worries. I'm here

63


1 on behalf of the Home Bakers Association. You

2 mentioned there's going to be several pop ups

3 trying to reach that 50K threshold. In my

4 opinion, can you explain how, I guess, do you

5 know how many cupcakes I would have to bake daily

6 to reach 50,000 annually?

7 MS. RAGANELLI: And that's before

8 costs.

9 MS. MARICH: And that's before costs

10 and my inspections and taxes. Do you know how

11 many cookies I would have to bake? I would have

12 to have my oven running 24 hours a day. And even

13 then, I still wouldn't be able to achieve that

14 goal. Most of the bakers that we represent are

15 single mothers, are working mothers, are families

16 that are looking for an additional income.

17 And I just feel we don't want you to

18 hold up the thought on the 50K. We want you to

19 look at everything. And I'm sitting here and I'm

20 listening to everyone's concerns. And I agree, a

21 lot of these concerns are appropriate, but to

22 suggest that the 50K is why everyone is going to

23 push for it.

24 Most of the people that apply for

25 these permits, most of the people that are going

64


1 to be doing this, aren't going to be able to

2 achieve 50,000 no matter what we do. There's no

3 way we can compete with an actual brick and

4 mortar with a home size oven. Our operation is

5 completely different from a restaurant. I just

6 want you guys to consider that fact.

7 MS. DRAGONE: I just have a

8 question.

9 MS. MARICH: Absolutely.

10 MS. DRAGONE: Just as a member of

11 the public here in New Jersey, what is the

12 impetus of this?

13 MS. JENKINS: Well, there was a

14 lawsuit filed against us regarding home bakers.

15 However, based on additional research, we find

16 that it is appropriate to move forward at this

17 time. We are the only state in the country

18 that -- this.

19 MS. DRAGONE: What was the lawsuit

20 in New Jersey that prompted this?

21 MS. JENKINS: The ban that it was

22 unconstitutional.

23 MS. RAGANELLI: There was a lawsuit

24 brought by the law firm on behalf of these home

25 bakers who want to make cake pops and sell them,

65


1 maybe for a bridal shower as a favor, as a party

2 favor.

3 So the concern I have is, I agree,

4 you know, that this does raise issues of local

5 health, but you also have to bear in mind that,

6 number one, you did mention that there is a bill

7 pending that might mandate we do this anyway.

8 MR. GROSS: Right.

9 MS. RAGANELLI: Number two, as there

10 is litigation, and the last state in the union to

11 allow to prohibit this, again, the lawsuit may

12 not go in the department's favor and we would

13 have to do this anyway. So in this circumstance,

14 we're doing it in under terms that are acceptable

15 to the department and consider public health

16 issues.

17 MS. CUCUZZELLA: I won't speak for

18 all my home health officers, but I know many of

19 us see the writing on the wall and know that

20 eventually a version of this bill, whether it's

21 legislatively or through regulation is going to

22 happen.

23 MR. GROSS: Correct.

24 MS. CUCUZZELLA: Our concern is

25 minimizing the impact to our health departments

66


1 while ensuring the public health of our

2 residents, so making sure we walk that line

3 between keeping everybody healthy, but then

4 spending time on complaints that are just going

5 to assume staff time and, you know, and I go back

6 to, Genevieve and Mr. Manley where he said it is

7 your duty.

8 Absolutely it's our duty to

9 investigate any complaints. And I think that's

10 where we're concerned. When a complaint comes

11 in, we respond to every complaint we get. So

12 until we get on that complaint, we won't know

13 whether it's something that's in the code that

14 then needs to be handled by the State Health

15 Department.

16 So we get a complaint that somebody

17 is operating a business that they don't have a

18 cottage food bill or a cottage food handler

19 permit, whatever you want to call it. That

20 complaint, we'll send right to the State Health

21 Department because that will be under their

22 purview to investigate.

23 Rarely do the complaints ever come

24 in like that. It's going to come in, yes, they

25 have this, but they're doing this and they're

67


1 doing this. And until we actually go out and

2 investigate what's going on at that house, we

3 won't know whether that's something we can turn

4 over to the State Health Department to handle, or

5 is it just a nuisance complaint which we would

6 handle anyway.

7 So it's going to generate a lot of

8 complaints and it's going to generate complaints

9 that we will go out on because that's what we do

10 as a health department. And would some of them

11 be ones that we would get regardless of the

12 cottage food bill? Absolutely.

13 But many of them will be because of

14 the cottage food bill that we go out because

15 people like to complain, you know, and we deal

16 with it every day. So I don't want to minimize,

17 you know, that this state's handling it because

18 it is going to impact the local health

19 departments and it is going to impact us a lot.

20 And we are already constantly being

21 mandated and asked to do additional services with

22 no funding or very limiting funding to be able to

23 do it.

24 MR. GROSS: Here's what I see also,

25 spending 38 years being an inspector, I tell

68


1 restaurants that they got to spend, you know, X

2 and X amount of dollars put a new floor in, a new

3 refrigeration, all kinds of things, and they went

4 for $50,000 to fix their bakery up and now all of

5 a sudden, and no disrespect to the Bakers

6 Association, now all of a sudden, I have somebody

7 on the other side of town who is working out of

8 their house.

9 And that baker isn't going to say,

10 well, yeah, it was the State Health Department.

11 They're going to say it's the local health

12 department, look what they're doing. They're

13 making me spend $50,000, but this person on the

14 other side of town can bake right in their

15 kitchen.

16 So what that does is that takes away

17 some of the credibility that a local health

18 department has quite simply because now I'm

19 telling you to put a three compartment sink in,

20 but this person doesn't necessarily need to have

21 all those things.

22 So that's an issue that I think any

23 inspector who has been out in the field will tell

24 you. They're going to run into that credibility

25 issue of why are you allowing them to do that?

69


1 And not only is that baker going to be

2 complaining about it, it's everyone that the

3 baker knows about is going to be complaining

4 about it.

5 Then you're going to have, well, how

6 come they can pull up to their house and buy this

7 and do that, whatever. There's going to be a lot

8 of -- listen, you're right, cottage industry

9 thing is going to happen down the road. I'd be a

10 fool to tell you it's not. But I think we need

11 to really, really look at this a lot better.

12 I think we need -- there's some good

13 things in this, but I think it really has to be

14 looked at. And I think if you had some

15 inspectors, Bill, I know you had inspectors on

16 your committee and certainly I have all the

17 respect in the world for you. I don't ever want

18 you to think I don't.

19 But I really think if we have some

20 more people come down here and talk to us about

21 this and the whole bit, would be the right

22 answer. It's going to happen. I know it. It's

23 going to happen with or without the Public Health

24 Council.

25 Let's be straight, but I really

70


1 think that there's some issues that really need

2 to be kind of worked out here before we -- and

3 this is no disrespect to the Bakers Association.

4 I want to make that very clear. I have nothing

5 against your organization or you folks, okay. I

6 wish you the best of luck, but we're the guys in

7 the trenches that are going to get the

8 complaints.

9 And I guarantee, I'm sure your home

10 is clean and you're playing by the rules. Nobody

11 is saying you're not. But it's that credibility

12 issue that we're going to have with the public of

13 when they say, well, how come this young lady who

14 now all of a sudden bakes a cake out of her

15 house, and I'm sure the cake is delicious, but I

16 just made this man spend $200,000 on new

17 walk-ins, on a new floor and new refrigerator.

18 MS. MARICH: If I could add a

19 comment onto your statement. You currently

20 already allow a non profit. I can make a million

21 cakes a month for no profit. I can drop off to

22 my son's bake sale, I can drop off to my church,

23 I can bring you all cupcakes for free. No one is

24 worried about it being a safety issue then. It's

25 only when it becomes profitable to me it becomes

71


1 a health issue.

2 MS. RAGANELLI: I just wanted to

3 mention. You missed some of what the council for

4 the home bakers stated when you stepped out of

5 the room. If she could reiterate. You mentioned

6 the 50,000, but it's $50,000 before costs and

7 expenses and taxes and she had a point on that.

8 MS. MARICH: I just want you all to

9 know, I legally operate in New Jersey, I'm a

10 registered business. I pay my taxes, I rent a

11 space, so I know the costs associated with

12 running a business legally and I know the amount

13 of money I could save if I could do it from my

14 home.

15 I'm the mother of five. The amount

16 of time I spend out of my home and for daycare

17 eats my profit, so just that alone. The amount

18 of cupcakes I would have to bake and the amount

19 of cookies that I would have to bake in a home

20 based oven, compared to what a brick and mortar

21 could do, that 50K really isn't achievable.

22 It would require me to work 24 hours

23 a day. It would require me to stop everything

24 that I'm normally doing to be able to reach

25 anywhere near that type of money. Again, like I

72


1 mentioned earlier when you stepped out, we

2 completely understand all the health concerns and

3 issues.

4 I think that's why we have been so

5 active in these types of meetings and I do

6 appreciate you letting me here today.

7 MR. GROSS: And thank you.

8 MS. MARICH: Because we want to make

9 sure that whatever we propose to the public is

10 something that's respected and something that we

11 can all agree upon. But we just wanted to be

12 seen for what it is. And things that are already

13 being allowed and things that, the issues that

14 are being presented are currently being done.

15 Like she mentioned earlier, there is

16 a lot of underground business in this industry.

17 We're not going to deny that. There's a lot of

18 complaints already being made. We're not going

19 to deny that. And most of them are from bakers

20 to bakers. This is the truth. This is what it

21 is.

22 But that's the same thing that be

23 set for a restaurant business. There are

24 restaurant businesses calling against each other.

25 There are restaurants that can walk in, they're

73


1 disgusting. Bakeries have been shut down for the

2 same reasons. I just want it to be a fair game

3 across the board.

4 What's being presented for home

5 bakers should be the same respect that we're

6 giving to brick and mortars. It can't just be

7 worried about the money and the health concerns

8 because every time someone says, well, am I going

9 to get sick from your cupcake? You already had

10 my cupcake at your bake sale. Icing Smiles takes

11 our cakes annually and those are for terminally

12 ill children. Where is the health concern there?

13 MR. GROSS: Thank you. Well said.

14 Thank you, ma'am.

15 MS. PENNANT: Are we voting on the

16 rule?

17 MR. GROSS: I think we're agreeing

18 that we're going to put this off for the next

19 meeting.

20 MR. SAN FILIPPO: Mickey, I have one

21 more comment for Bill. Bill, are you still

22 there?

23 MR. MANLEY: Yes, I'm still here,

24 Dennis.

25 MR. SAN FILIPPO: Bill, was there

74


1 any inclination for having a product liability

2 coverage on the products that are going to be

3 made, whether should anything happen in the

4 kitchen from a contamination standpoint, it would

5 be a full number that we've heard about that

6 would cause a product to be from one thing to

7 another. And I don't know if that would reduce

8 any liability, you know, if that would be

9 considered at all.

10 MR. MANLEY: To put that into the

11 regulations?

12 MR. SAN FILIPPO: Yeah. I don't

13 know if that would help because certainly I was a

14 teacher for two years and we had bake sales and

15 there was glass in one of them. And I'm sure it

16 was innocent and I'm sure glass broke into

17 fragments and landed in this one particular

18 batter.

19 That happens, so things happen as

20 you know, cross contamination. There's a lot of

21 things that can happen with these products, but I

22 didn't know if it would help the operator to have

23 that kind of coverage just in case something like

24 that would occur and potentially moving liability

25 on the other parts or persons.

75


1 MR. MANLEY: It wasn't discussed.

2 We had no discussions on liability insurance.

3 MR. GROSS: I don't honestly

4 think -- I've never enforced that as an

5 inspector. I'm going to very honest with you. I

6 don't really see it as that pertinent. I'm being

7 straight with you. I've never went up to

8 somebody and said here is your insurance. I

9 never have.

10 MR. SAN FILIPPO: I have in my 37

11 years when we run these, a number of, whether it

12 be a 4th of July parade, Italian festival, these

13 are temporary food vendors and they're all

14 required to have a certificate of insurance.

15 MS. MARICH: I have been required to

16 show my certificate of insurance for vendor

17 events and for catering halls. At that time, I

18 present them with my insurance.

19 MR. MANLEY: But you're not

20 currently a cottage food operator?

21 MS. MARICH: No. I'm legally

22 operating in New Jersey as a business.

23 MR. GROSS: Again, if you're asking

24 for a vote, I'm not going to put the vote up on

25 the floor until I know the some of the health

76


1 officers want to come down at the next meeting

2 and talk.

3 What I would suggest is that maybe

4 reach out to some people and see -- you heard

5 some concerns here today and see what possibly

6 could be worked out. Again, it's going to

7 happen. Sooner or later this is going to happen.

8 MR. CENSULLO: Since we've called

9 the meeting as advertised. We published, I think

10 at minimal, we should vote to postpone and take

11 this up at a further time.

12 At which time, we should have

13 invitation to the general public or stakeholders

14 to attend that meeting and have it be a

15 continuation of this meeting because I think we

16 do need to vote even if it's just to postpone.

17 MR. GROSS: I make a motion the vote

18 be postponed to the next meeting.

19 MR. SAN FILIPPO: I'll second that.

20 MR. GROSS: Roll call.

21 MS. PENNANT: Mickey Gross?

22 MR. GROSS: Yes.

23 MS. PENNANT: Dennis San Filippo?

24 MR. SAN FILIPPO: Yes.

25 MS. PENNANT: And Rich Censullo?

77


1 MR. CENSULLO: Yes.

2 MR. GROSS: At this point, if

3 there's no other business before the Public

4 Health Council, I'll ask for an adjournment?

5 MR. SAN FILIPPO: So moved.

6 MR. GROSS: All in favor, say aye.

7 BOARD MEMBERS: Aye.

8 (Hearing Concluded at 12:05 p.m.)

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78


1 C E R T I F I C A T E

2

3 I, LAUREN ETIER, a Certified Court

4 Reporter, License No. XI 02211, and Notary Public

5 of the State of New Jersey, that the foregoing is

6 a true and accurate transcript of the testimony

7 as taken stenographically by and before me at the

8 time, place and on the date hereinbefore set

9 forth.

10 I DO FURTHER CERTIFY that I am neither a

11 relative nor employee nor attorney nor council of

12 any of the parties to this action, and that I am

13 neither a relative nor employee of such attorney

14 or council, and that I am not financially

15 interested in the action.

16

17

18

19

20

21

22 ________________________________

23 Notary Public of the State of New Jersey

24 My Commission Expires June 30, 2020

25 Dated: March 5, 2020



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load47:10local 15:1516:21 21:2226:23 27:2,327:10,11,1328:1,7,9,1928:22 29:2,429:8,12,1929:19,2030:7 32:2032:20 33:134:7 40:2146:6 47:1147:20 49:449:24 50:1151:8 52:953:15 55:4,655:18,22,2557:2,22 58:661:8,1962:11 65:467:18 68:1168:17

locals 28:2460:8 62:17

located 20:14location 1:1053:9

locations26:15

long33:249:18

look11:1613:20,2249:5,5,1963:19 68:1269:11

looked 33:1269:14

looking 23:723:10 25:446:10 48:1859:4,6 60:260:3 63:16

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Machines 20:24Madam 4:19major 23:7


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March 78:25

Marich 6:6,662:21,2563:9 64:970:18 71:872:8 75:1575:21

Marin 6:9MARKED 3:17market 25:1,1952:18

markets 47:2248:10,24

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matters 19:5mayor 57:1mean7:18,2012:18 13:119:14 32:2250:25 56:459:5,24 60:560:7

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meetings 4:610:6 16:2341:5,15 72:5

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microphone31:22

middle 32:11million 70:20mind30:1765:5

minimal 76:10minimize 67:16minimizing65:25

minimum 13:18minute 62:24missed 71:3Mm-mm 53:24moment 25:11Monday 1:13monetary 45:2152:19

money 46:2547:2 53:1054:11 71:1371:25 73:7

monitor 36:17month 5:3 15:241:16 70:21

months 53:13mortar 64:471:20

mortars 73:6mother 71:15mothers 63:1563:15

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notified 26:2440:22

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number 11:1219:10 24:2224:23 40:1,546:15 47:1551:17 65:6,974:5 75:11

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permits 29:1463:25

permitted21:11 22:823:4 49:251:21

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playing 70:10please 4:176:5 26:6

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presented72:14 73:4

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profit 70:2070:21 71:17

profitable70:25

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time5:9 7:916:6,8 18:120:2 36:137:9 44:2151:22 53:1053:12 54:1156:7 57:864:17 66:4,571:16 73:875:17 76:1176:12 78:8

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today 4:24 6:16:3 7:128:16 14:1214:15 20:144:10 60:1172:6 76:5

told60:13TOLL1:24top32:7topic 29:18totally 9:7touched 62:2town40:1143:11 68:768:14

track 37:4tracked 27:24Trade 41:19training 23:1623:21 38:338:21 43:1743:23

transcript12:7 78:6

treat 12:7,2038:25 54:6

treated 38:4trenches 70:7Trenton 1:1256:6

tricky 56:20triggered 14:2true78:6truth 51:1072:20

trying 30:1563:3

turn7:2 31:2235:22 52:352:20 67:3

twice 33:22two19:6,1020:3 29:2530:24 35:18


65:9 74:14type8:22 21:123:12 25:1,227:21 29:1456:1 71:25

types 21:1123:3 24:2072:5

typically11:13 25:2

Tyrone 6:18

UU3:20unanswered44:16

unclarity33:11

unconstitu...13:11,12,1364:22

underground13:17 58:1272:16

understand 9:710:3 18:2131:24 36:2272:2

understood26:4

union 13:665:10

University41:12

unnecessary24:3

ups63:2use45:4 48:2162:23

Usually 11:7

Vvariables 60:560:18,22

various 36:236:15

Vending 20:23vendor 75:16vendors 75:13version 65:20vested 9:4Videography1:21

violate 58:3,6violation51:25 58:16

vote5:3,227:8,10 8:115:2,13,1715:21 18:1820:1 75:2475:24 76:1076:16,17

votes 15:8voting 5:167:12 73:15

Wwait22:19walk57:2558:4 66:272:25

walk-ins 70:17walking 59:2059:25

wall65:19want5:4,207:13,1811:17 14:1214:25 15:2317:21 18:3,518:17 19:1625:21 26:529:5 34:2342:19 51:1053:7 60:1063:17,1864:6,2566:19 67:1669:17 70:471:8 72:873:2 76:1

wanted 18:2220:16 26:337:21 42:1442:24 71:272:11

wants 24:11wares 24:24Warren 1:11wasn't 14:1475:1

water 40:1753:4

way20:5 31:2538:25 45:2556:7 64:3

ways56:17we'll 20:166:20

we're 12:615:1 18:1525:3,4,5,1325:25 29:1731:2,2 32:1733:23 34:234:10,1135:13 36:2544:11,2446:23 47:147:22 49:1453:17,18,1954:5,20 56:357:4,7 65:1466:10 70:670:12 72:1772:18 73:573:17,18

we've 33:1234:15 41:1341:20 50:1074:5 76:8

web24:1027:17 48:5

week53:9weekend 5:1weigh 18:25went42:16

44:18 68:375:7

weren't 8:4,6William 20:7wind62:17Wisconsin 13:9wish70:6WOOLFORD 2:118:21 9:7,1510:3 13:2434:25 35:635:11 37:860:14

words 22:3work46:2462:18,1971:22

worked 70:276:6

working 47:1863:15 68:7

works 10:12world 10:255:21 69:17

worried 70:2473:7

worries 62:25wouldn't 7:1234:22 63:13

writing 9:1111:24 27:640:6,9 65:19

written 12:5wrong 16:2334:7 56:18

www.RLReso...1:25

Xx1:3,6 3:1,1368:1,2

XI78:4

Yyeah18:1127:8 31:20


50:8,1368:10 74:12

year33:2241:5 46:1746:23 47:3,4

years 67:2574:14 75:11

young 70:13

Zzone27:7zoned 58:20zoning 27:340:7,1050:11 51:7,758:18 61:1061:12

zonings 62:6

002211 78:408625 1:1208690 1:23

11017:2410:36 1:1410043:15 57:862:15

1122:25 34:1711.532:2412:05 77:81731:2219754:5

2232:122.130:18203:6200,000 70:1620201:1378:24,25

22771:222330:8,192314:4231535:20

241:13 20:2120:22 21:622:25 23:1025:12 31:1034:11,1335:14 36:441:5,6,1644:15 45:452:10,1263:12 71:22

2511:15,16

33078:24328206 1:25331:22368-7652 1:243691:113775:10386:13 67:25

443:3,44101:22423:74th75:12

5578:255:305:13 8:145011:15,1750,000 13:1326:12 49:2061:21 63:664:2 68:4,1371:6,6

50K63:3,18,2271:21

6609:86091:24

77335:19773:8

88:2.1C 31:78:24-1.5 29:218:24-11.3 25:98:24-11.5 30:88:24-2.1 30:58:24.2.1 29:188001:24

9989-9199 1:24

new jersey department of health · 1 state of new jersey 2 department of health 3...

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