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Alternatively, the USDA asserts that if the statement is a regulation then the agency had good cause to by-pass the notice and comment requirements because the upcoming school year starts in 45 days and schools need time to develop menus and purchase the necessary food items for vegetarian meals.
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The agency also alternatively asserts that it complied with the notice and comment requirements of the Administrative Procedure Act when it published the "Notice of Vegetarian Meal Requirements" in the Federal Register and the Beef Producers Association provided comments on the issue. This is direct contrast to the BPA claim that the USDA adopted a new regulation without going through the required notice and comment process for new regulations...
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A Days Time
Beef Producers Vs. Usda
Fast food versus Home-cooked meals
School Days
The Good Old Days
the first days of school
Vegetarian Food
Food producers
The Benefits of Year Round Education and Extended School Days
Statement of Requirements
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