There is a document at USDA to help inspectors, and it might be useful for retailers to look at because it lists the noncompliance issues. Retailers could see exactly what the inspector is looking for. You can find that document here. Around page 5 you’ll see the table if you’re interested. We’ve also got a variety of resources on this issue at our COOL page.
So all in all, this is nothing unexpected. It’s a continual evolution of the COOL system – on the part of USDA and inspectors as well as on the part of retailers. We urge all retailers to use the resources available and comply with COOL by training store-level employees, particularly in produce. It appears USDA will be stepping up its timelines and its enforcement.
TK: Yes, "a continual evolution of the COOL system" is taking place. But hearing that the USDA is putting in place a rule to enforce fines on retailers for "willful" violations of COOL should ramp up the "buzz" about this controversial law once again.