List of Newsletters
To subscribe this Food Safety Newsletter,
Journal of Food Saety
for more information
decline in most foodborne illnesses
Source of Article: http://www.cidrap.umn.edu/
Apr 13, 2006 (CIDRAP News) ? The incidence of most major foodborne diseases
in 2005 changed little from the previous year and generally continued
a slow decline from levels measured in the late 1990s, according to the
Centers for Disease Control and Prevention (CDC).
As in past years, Salmonella
infections were the most common foodborne illness, followed by Campylobacter
cases. Shigella, Cryptosporidium, and Escherichia coli O157 infections
ranked third, fourth, and fifth.
The data come from the CDC's FoodNet surveillance system, which covers
all or parts of 10 states with about 15% of the US population. The agency
reported the data in the Apr 14 issue of Morbidity and Mortality Weekly
Report, published today.
The CDC assesses trends in foodborne illness by comparing each year's
figures with data from 1996 through 1998, the first 3 years of the FoodNet
active surveillance program. On that basis, the agency says the rates
of Campylobacter, Salmonella, Listeria, and several other infections were
lower in 2005 than in the baseline period, but most of the progress came
The surveillance program identified a total of 16,614 laboratory-confirmed
foodborne infections in 2005. Salmonella accounted for 6,471 cases, about
39% of the total. There were 5,655 Campylobacter cases, or about 34% of
the total. The CDC reports 2,078 Shigella cases, 1,313 Cryptosporidium
cases, and 473 cases of Shiga toxin?producing E coli (STEC) O157. The
remaining cases included Yersinia, STEC non-O157, Listeria, Vibrio, and
The report shows 44 cases of hemolytic uremic syndrome, a major complication
of E coli O157, among children in 2004, the latest data available. That
compares with 52 cases reported in 2003.
A comparison of the 2005 data with the CDC data for 2004 shows little
change in incidence for most of the pathogens. The rate of salmonellosis
cases in 2005 was 14.55 per 100,000 people, compared with 14.7 in 2004.
The 2005 and 2004 incidence rates for others are as follows: Campylobacter,
12.72 and 12.9; Shigella, 4.67 and 5.1; Cryptosporidium, 2.95 and 1.32
(13.2 per million); and E coli O157, 1.06 and 0.9. The CDC said the big
increase in incidence of Cryptosporidium cases in 2005 over 2004 was due
to a large outbreak at a water park in New York last year. Because the
FoodNet surveillance area has increased greatly since 1996, the CDC uses
a statistical model to estimate the changes in rates of foodborne infections
since the baseline period. Using that method, the agency cites the following
estimates of declines in foodborne infections: Yersinia, 49%; Shigella
43%; Listeria, 32%: Campylobacter, 30%; E coli O157, 29%; and Salmonella,
However, there are several caveats. One is that Vibrio cases have increased
an estimated 41% since the baseline period. Further, most of the progress
on the other illnesses occurred before 2005. For Campylobacter, most of
the decline came before 2001, and the rate of Listeria cases in 2005 was
higher than in 2002.
In addition, only one of the five most common Salmonella serotypes?Typhimurium?has
declined significantly, the CDC said.
CDC. Preliminary FoodNet data on the incidence of infection with pathogens
transmitted commonly through food?10 states, United States, 2005. MMWR
2006 Apr 14;55(14):392-5
outbreak of norovirus associated with a franchise restaurant --- Kent
April 14, 2006
Morbidity & Mortality Weekly Report
The majority of cases of foodborne gastroenteritis in the United States
are caused by noroviruses (1). This report summarizes an investigation
by the Kent County Health Department (KCHD) in Michigan into three norovirus
outbreaks and a cluster of community cases that were associated with a
national submarine sandwich franchise restaurant during May 3--9, 2005.
The investigation identified a potential source, a food handler who had
returned to work within a few hours of having symptoms of gastrointestinal
illness while he was still excreting norovirus in his stools. To prevent
norovirus outbreaks, food service workers should be educated regarding
norovirus transmission and control. In 2005, new guidelines for state
health departments regarding norovirus containment were published by the
Food and Drug Administration (FDA) (2); guidelines for local health departments
in Michigan were issued by the state's Department of Community Health
and Department of Agriculture (3). The new guidelines for Michigan recommend
that food service workers with suspected norovirus not return to work
until they are asymptomatic for 48--72 hours. more
Amendment to Safe Ingredients List
April 10, 2006
Source of article: http://www.meatami.com/
The Food Safety and Inspection
Service (FSIS) issued Directive 7120.1, Amendment 7, Safe and Suitable
Ingredients Used in the Production of Meat and Poultry Products.
The transmittal issues updates to Attachment 1, which identifies the substances
approved for use in meat and poultry products as food additives, approved
in Generally Recognized as Safe (GRAS) notices and pre-market notifications
and approved in letters conveying acceptability determinations.
To read the entire notice, go to http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/7120.1_Amend_7.pdf.
to meet goal on Listeria as rate rises
Thu Apr 13, 6:14 PM ET
Source of Article: http://news.yahoo.com
WASHINGTON (Reuters) - The United States fell short of its 2005 goal to
reduce cases of the foodborne bacteria Listeria by 50 percent, according
to a government report released on Thursday. The Centers for Disease Control
and Prevention said the rate of Listeria food poisoning rose in 2005 to
3 cases per million people, an increase from 2.7 cases per million a year
Listeria is a potentially fatal disease for at-risk populations including
the very young and elderly. It can cause high fever, severe headache and
nausea. U.S. health officials say it triggers about 2,500 illnesses each
year and 500 deaths. As recently as 1998 the rate was near 5.0 cases per
million. A USDA spokesman said the department, which oversees regulations
designed to stop the spread of the bacteria, has rules in place that should
help lower future incidences.
The Consumer Federation of America said while the government made progress
lowering the rate between 1996 and 2002, Listeria has started to climb
because USDA hasn't established tighter controls for deli meats and hot
"There is no progress if you don't have the government pushing the
industry to improve," said Carol Tucker Foreman of the Consumer Federation
In response to a nationwide outbreak of Listeria, the Clinton administration
in May 2000 established a series of public health initiatives to reduce
the incidence of the bacteria to 2.5 cases per million people by 2005.
Critics said several of the measures, including enhanced labeling, have
not been put in place by USDA.
key for benzene in soft drinks
By Chris Mercer
Source of Article: http://www.nutraingredients.com/
11/04/2006 - Testing soft drinks to reflect the effects of storage and
transport conditions will be crucial to realistically monitor benzene
formation in different drinks, a former industry scientist told BeverageDaily.com.
Leaving soft drinks in warm conditions, such as a car boot or garage,
can significantly increase the chance of benzene forming in the drink,
said a scientist who tested the effects of heat and light on benzene in
soft drinks for the industry in 1990.
Recent tests by UK and US food safety watchdogs have found several soft
drinks containing benzene traces above the countries' respective limits
for drinking water. The suspected source was two common ingredients in
the drinks ? sodium benzoate and ascorbic acid (vitamin C).
Benzene is a listed carcinogen, although both authorities said the levels
found in drinks to date should not pose an immediate health risk.
One scientist who helped the soft drinks industry sort out the same problem
in 1990, however, said testing drinks after exposure to heat and light
was now crucial.
¡°When those 38 drinks that [the UK Food Standards Agency] tested positive
for benzene are subjected to even short periods of heat and light, they
could dramatically increase to beyond the WHO 10 parts per billion water
He and New York-based lawyer
Ross Getman, who have pioneered the re-emergence of the benzene in soft
drinks issue, said food safety watchdogs should make sure they expose
drinks containing sodium benzoate and ascorbic acid to heat. Britain's
Food Standards Agency has not tested soft drinks for benzene after heat
exposure; although a European Commission spokesperson said new guidelines
on benzene testing, now being drawn up by the soft drinks industry, were
likely to include ¡°predictive testing to simulate storage¡±. Industry testing
on soft drinks 15 years ago is thought to have found that temperatures
of 30¡ÆC and exposure to UV light for several hours were enough to more
than triple benzene residues in some drinks. The tests were designed to
simulate the worst case scenario, and ¡°were not necessarily representative
of what the consumer was receiving¡±, according to Greg Diachenko, a scientist
with the US Food and Drug Administration, who also took part in negotiations
with soft drinks makers over benzene in 1990 and 1991. Data reported by
America's soft drinks industry association in the 1980s, however, showed
that soft drinks could be exposed to between 32¡ÆC and 49¡ÆC in US summer
months. The association said hot warehouses and cars parked in direct
sunlight were examples of when soft drinks would be exposed to higher
¡°Heat is a major factor¡± in
the formation of benzene in drinks, according to Mike Redman, a scientist
with the American Beverage Association and who also represented the industry
in meetings with the FDA over benzene in 1990. Redman told BeverageDaily.com
that soft drinks firms reformulated drinks in 1990, mainly by adjusting
the levels of sodium benzoate and ascorbic acid, to reduce and control
the potential for benzene traces to form. Still, the continuing presence
of soft drinks containing benzene above drinking water standards has led
to calls for sodium benzoate to be taken out of drinks formulas. ¡°What
are we to tell consumers? ¡®Product contains cancer-causing substance,
drink immediately, do not store in a warm environment or near sunlight?'
Preferably benzoate should not be used in combination with vitamin C (ascorbic
acid) or added juice,¡± said the scientist involved in industry testing
for benzene 15 years ago.
BeverageDaily.com broke the current story on benzene in soft drinks, after
it uncovered in February that recent FDA testing had found some drinks
containing benzene above America's limit tap water.
BSE in six-year-old
dairy cow "highly probable," Canadian Cattlemen Association
by Pete Hisey on 4/13/2006 for Meatingplace.com
A six-year-old dairy cow from British Columbia is believed to be Canada's
fifth case of bovine spongiform encephalopathy. Final test results will
not be available until this weekend, but Dennis Laycroft, executive vice
president, Canadian Cattlemen's Association, told Bloomberg that a confirmation
was "highly probable." Canadian veterinary authorities said
that the infection may have resulted from cross-contamination from poultry
feed or other feed that may have contained protein from cattle. If confirmed,
the case would be significant because the animal was born at least two
years after the imposition of a ban on cattle parts in feed meant for
cattle, the suspected source of BSE infection. The animal was discovered
on a farm in Fraser Valley in British Columbia as part of the nation's
BSE surveillance program, which has tested more than 100,000 high-risk
cattle since 2003. The test was deemed inconclusive, and samples were
sent to the National Centre for Foreign Animal Disease in Winnipeg, Manitoba.
CCA's Laycroft told Bloomberg that even if this younger animal tests positive,
that result would be consistent with results in Europe, where cases were
discovered well after feed bans were enacted, most due to contamination
or improper cleaning of feed containers, as well as cross-contamination
from feed meant for other animals or feed imported from countries with
no feed bans.
LEARN TO SURVIVE STRESS IN PLANTS
Source of Article: http://www.meatnews.com/index.cfm?fuseaction=Article&artNum=11409
UNITED STATES: Irradiation must be used in sufficient doses to kill pathogens.
Irradiation is effective at eliminating pathogenic bacteria from meat
in a processing plant before it¡¯s shipped out. But irradiation can be
less effective if plant personnel don¡¯t use it in sufficient doses--and
if they don¡¯t account for the strength of the bacteria they¡¯re trying
to kill, according to an article in a recent Food Safety Symposium newsletter.
Some bacteria may be stronger than meat processors realized, and bacteria
left for dead may rise up and haunt the processors.
¡°Many processors do not use the maximum level of irradiation because of
quality reasons,¡± said Aubrey Mendonca, an Iowa State University food
science researcher, who is researching the problem for the Food Safety
Consortium. ¡°A maximum level of irradiation may detract from the desirable
sensory qualities of the meat. What they try to do is find a dose that
would still give them good food safety protection against pathogens.¡±
When food processors determine
at what level they will irradiate meat, they often look for the most effective
minimum dose--a level that will kill the pathogens without detracting
from the meat¡¯s taste, aroma, appearance or other sensory qualities. That
determination is usually made by relying on studies that show how much
irradiation is needed to kill pathogens such as E. coli O157:H7, Salmonella
Typhimurium, or Listeria monocytogenes.
Mendonca said the flaw in that approach occurs when processors use studies
of pathogens that are cultured under optimal growth conditions in a laboratory.
The conditions that those microorganisms face in the laboratory are not
as stressful as the situations encountered by the bacteria seeking to
survive in a processing plant¡¯s environment. In fact, growth conditions
in laboratory media rarely produce stress-hardened bacteria.
Mendonca¡¯s studies have shown
that these starved bacteria that must compete within the more rugged environment
of a processing plant develop greater abilities to resist adversity simply
because they must adapt to their living conditions or die. So when they
are the targets of irradiation, these starved bacteria may not die but
may merely be injured unless a higher dose of irradiation is administered.
The solution would be for processors to base their irradiation levels
on what it takes to kill stress-adapted organisms instead of laboratory-grown
organisms, he said.
die of infectious diseases, food poisoning in March
April 11, 2006
Source of Article: http://english.people.com.cn/200604/11/eng20060411_257426.html
The number of Chinese dying of infectious diseases rose to 704 in March,
while 12 died of food poisoning, the Ministry of Health announced Monday.
The top five killer diseases in March were tuberculosis (TB), hydrophobia,
AIDS, hepatitis B and epidemic cerebrospinal meningitis, accounting for
86.45 percent of the total fatalities, says the ministry's monthly epidemic
report. TB, hepatitis B, bacterial and amebic dysentery, syphilis and
gonorrhea accounted for 87.21 percent of the total incidents of infectious
diseases, the report says. The ministry reported in March that 536 people
were killed by infectious diseases in February with TB the main killer.
The ministry said 29 incidents of food poisoning occurred in March, affecting
666 people, 277 fewer than the same period last year. Source: Xinhua
New Proactive Solution for Listeria Risk Control
bioMerieux¡¯s new VIDAS¢ç LDUO test now enables the simultaneous detection
and differentiation of Listeria spp and Listeria monocytogenesin a single
test for food products and environmental samples.bioMerieux¡¯s know-how
in immunoassays allows synthesis of antibody fragments which reduce non-specific
interactions with food matrices for increased specificity. The use of
these highly specific antibody fragments also improves sensitivity by
more rapid diffusion in the sample. The combined use of VIDAS¢ç LDUO with
LX broth enables faster growth of bacteria for enhanced detection, outperforming
the ISO standard 11290-1.
A proactive approach
By working in routine with the simultaneous detection of Listeria spp
andListeria monocytogenes, laboratories can improve their efficiency and
better anticipate the risk of Listeria contamination. The use of Listeria
spp as an early alert indicator reinforces the control of this pathogen.
The immediate result for Listeria monocytogenes optimizes the confirmation
VIDAS¢ç LDUO: officially validated
by AFNOR/ISO 16140
VIDAS¢ç, the world¡¯s leading automated system for food-borne pathogen detection
has recently obtained official validation by AFNOR in compliance with
ISO 16140 (BIO-12/18- 03/06) for its new and innovative solution for controlling
the risk of Listeria : VIDAS¢ç Listeria DUO. This marks the 30th official
validation of the VIDAS¢ç system.
Through its expertise in food testing and its knowledge of immunoassay
development, bioMerieux is achieving new standards in industrial microbiological
control. Our R&D teams are working on new high performance solutions
for quality control laboratories in the food industry, using state-of-the-art
technologies available in bioMerieux¡¯s portfolio.
in Food and Agriculture 2006
April 12, 2006
Food Chemical News
Agra Informa Inc.
Assessing the commercial potential of nanotech, generating investment
and examining the prospects for future regulation
June 6-7, 2006, The Marriott Washington Hotel, Washington DC
Nanotechnology in Food and Agriculture, an event organized by Food Chemical
News, is the first conference of its kind to explore the opportunities
and challenges relating to the application of nanotech within food, giving
you the chance to capitalize on new developments within this field to
ensure your company is ready to take full advantage of range of opportunities
Reserve your place at Nanotechnology in Food and Agriculture and be the
Hear from industry experts about the most realistic and profitable innovations
of nanotechnology research and development unique to food and agriculture.
Gain first hand information from the government agencies involved in future
regulatory decisions that could have a direct impact on your own initiatives
Examine the opportunities on offer to potential investors in nanofood
and how to secure financial support for your own research and development
Understand the legal requirements involved in nanotech initiatives to
protect your own innovations.
Nanotechnology in Food and Agriculture will bring together a number of
leading experts with direct influence in this field of technological development,
Dr. Mihail C. Roco, National Science Foundation, National Nanotechnology
Dr. Hongda Chen, USDA, CSREES
Dr. John Turner, USDA, APHIS
Dr. Celia Merzbacher, The White House Office of Science and Technology
Dr. Philippe Martin, Directorate-General for Health and Consumer Protection,
Join us in Washington for the first ever conference on Nanotechnology
in Food and Agriculture to ensure your organization gains competitive
advantage in this dynamic new sector! Can you afford to miss this opportunity?
For further information please contact:
Sophie Stevens, Agra Informa, 80 Calverley Road, Tunbridge Wells, Kent
TN1 2UN, UK
Phone: +44 (0)20 7017 7500 Fax: +44 (0)20 7017 7599
E-mail: firstname.lastname@example.org www.agra-net.com/nanotechfood
is your kitchen?
April 12, 2006
The Sudbury Star
Michael Cullen, who operates YUM Culinary Academy and teaches cooking
at Kitchen Bits and Dumas Your Independent Grocer, writes in this column
that there is an overwhelming interest in food preparation these days.
Television networks provide viewers with glamorous cooking shows that
entertain and educate. Cookbook sections in bookstores are quite voluminous.
Food preparation magazines, kitchen stores and recipe websites have never
been more popular.
Unfortunately, the most important part of cooking is often overlooked.
I was quite surprised after viewing a number of cooking shows lately that
few -- and in some cases no -- cooking safety tips were offered, observed
Safe food handling and kitchen sanitation is the most important aspect
of planning a meal.
Safe food-handling techniques and accurate knowledge of sanitation practices
are imperative in order to avoid food-borne illnesses.
Do we take for granted that our food and kitchen are safe? We thoroughly
wash and sanitize our kitchen tools after every use. We wash our hands
before, during and after cooking and we certainly are aware of proper
temperatures with regards to the food we serve, consume or store.
Or are we? Whether you are a chef-du-jour or a domestic diva, it's a good
idea to learn a little more on this subject. Your best bet for information
on this topic is the Sudbury and District Health Unit.
of Being Allergic to Food
By KAREN JOHNSON Medical Nutritionist
Sunday, 9 April 2006
Source of Article: http://www.redorbit.com/
FOOD allergies and intolerance are very common, with more and more people
developing them. Over the past few years I have seen more people in my
clinics with symptoms of food allergies and intolerances than any other
There are many different symptoms of allergies - bowel disorders, skin
conditions, migraine headaches, sinusitis, blocked nose, heartburn, asthma,
recurrent infections, extreme tiredness and many more.
The tricky part is identifying the offending food, because the sufferer
may not have symptoms immediately. Food is inside you for quite a few
days - when you eat the culprit, your symptoms may not develop for several
This is why people find it
difficult to link what they have eaten to the onset of their symptoms.
Many people tell me that they have been experimenting by taking foods
away from their diet for many years without success.
There is no accurate diagnostic test, which is why GP and hospital doctors
are unable to tell people what's causing their symptoms. more
40% of state's
fish high in mercury, study says: Data cited in report cover 2 decades
April 11, 2006
Michael Hawthorne, Chicago Tribune
Tests found that 40 percent of the fish sampled in Illinois during the
past two decades had mercury levels above the federal exposure limit for
an average-size woman, according to a new report to be released by the
Illinois Public Interest Research Group that is intended to pressure utilities
to curb emissions of the toxic metal.
A largemouth bass caught in the Sherman Park lagoon on Chicago's Southwest
Side was found to be the most contaminated. Mercury levels in the fish
were eight times higher than the government's exposure limit.
The story says that high mercury levels found in waterways throughout
Illinois led Gov. Rod Blagojevich earlier this year to make an election-year
push to dramatically reduce mercury pollution from coal-fired power plants,
the top source of the metal.
Attempting to bolster the governor's case before a state board, environmental
advocates and state officials will release a report Tuesday that documents
why Illinois cautions people to limit eating fish caught in the state.
'Milk at risk' say Experts
By Francis Gachuiri ( Friday, April 07, 2006)
Source of Article: http://www.kbc.co.ke/story.asp?ID=36075
Veteneray experts are alleging fears that some milk products in Kenya
may contain cancerous aflatoxin fungus obtained through animal feeds.
The Principal of the College of Agriculture and Veterinary services at
the University of Nairobi Prof. Agnes Mwang¡¯ombe said the aflatoxin germ
found in milk is a silent killer that cannot be destroyed by heating.
Speaking on Thursday at a seminar on Aflatoxin content in animal feeds,
Pro. Mwang'ombe urged dairy product consumers to exercise extreme caution
on the sources of those products before consuming.
She however said the University of Nairobi in collaboration with stakeholders
especially animal feeds manufacturers was conducting a research to ascertain
the levels of aflatoxin fungi in animal feeds before they are released
for livestock consumption.
Meanwhile, the government has said it is putting in place measures to
ensure the safety of dairy products that are sold to consumers.
Livestock and Fisheries Development PS Dr Jacob Ole Miaron says monitoring
of hygienic standards in the dairy industry is crucial.
Speaking at a meeting of the Kenya National Dairy Producers The PS noted
that some milk processors were using substandard equipment and endangering
the lives of consumers, he said the safety of dairy products was a global
concern and should be addressed locally in order to increase chances of
market access in the region.
Journal of Food Safety (Current Issue)
Vol 8. 23-29
Development of Process for Preparation of Pure & Blended Kinnow Wine
without Debittering Kinnow Mandarin Juice
Vol 8. 19-23
Aspergillus, Health Implication & Recommendations for Public Health
Vol 8. 14-18
An Observational Study of The Awareness of Food Safety Practices in Households
Vol 8. 7-13
Antibacterial activity of oregano tea and a commercial oregano water against
Escherichia coli O157:H7, Listeria monocytogenes 4b, Staphylococcus aureus
and Yersinia enterocolitica 03.
Vol 8. 3-6
Safety and quality practices in closed-house poultry production in Thailand:
2004-avian influenza outbreak
Vol 8. 1-2
The introduction of the Japanese Carpet Shell in coastal lagoon systems
of the Algarve (south Portugal):
a food safety concern
Protection of Food from Adulterants/Proper Labeling, Storage- VIDEO
Dr. Lori Pivarnik
University of Rhode Island
Click here for Windows Media Streaming Versions
Prevention of Cross-Contamination
Dr. Thomas Rippen
Seafood Technology Specialist with the Maryland Sea Grant Program
the University of Maryland Eastern Shore
Click here for Windows Media Streaming Versions (Recommended)
or click here for HTTP Server
04/14. QA Lab Technician - MO-Bridgeton
04/14. QC Technician - CA-Encino
04/14. Quality Assurance Supervisors - FL-Orlando
04/14. Materials Supervisor, QA, GMP, HACCP - H-burg, Lebanon, PA
04/14. Quality Assurance Supervisor - Food Industry - Chicago, IL
04/14. Quality Control Supervisor - CA-Los Angeles
04/14. Quality Assurance Supervisor - Chicago, IL
04/13. Quality Assurance Auditor - IL-Chicago Northwest
04/13. QA Specialist / CAPA Specialist - TN-Memphis
04/13. Quality Assurance Supervisor - IN-Indianapolis
04/13. Quality Systems & Food Safety Manager - Corona, CA
04/13. Quality Assurance Supervisor - York, PA
04/13. QA Manager, Food and Nutr Mfg - Evansville, IN; Louisville, KY
Constituent Update: Apr 14, 2006
Benzene in Soft Drinks
Availability of Revised Versions of Guidance Materials
JOHANNS SIGNS AGREEMENT WITH CHINA ON FOOD SAFETY AND PLANT AND ANIMAL
Interstate shellfish dealers certificate
Safe and Suitable Ingredients Used in the Production of Meat and Poultry
FSIS Reminds Consumers to Properly Handle and Cook Ground Beef Products
FSIS Issues Amendment to Safe Ingredients List
CFSAN 2005 Program Priorities Report Card
USDA's Meat and Poultry Hotline Offers Food Safety Recommendation for
Spring Religious Holidays
Guidance for Industry: Q&A Regarding Food Allergens, including the
Food Allergen Labeling
FSIS to Hold Public Meeting to Discuss Proposed Rule on Availability Of
Retail Lists During Recalls
Single Minimum Internal Temperature Established For Cooked Poultry
SALMONELLA VERIFICATION SAMPLING OF TURKEY CARCASSES
FDA's Accomplishments in 2005
Food Defense Acronyms, Abbreviations and Definitions
Letter Regarding Benzene Levels in Soft Drinks
Ike Scenario 04D-06: Clarification of the Appeal Process