The CALIFORNIA RETAIL FOOD SAFETY COALITION Formerly known as the CURFFL Review Committee

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1 The CALIFORNIA RETAIL FOOD SAFETY COALITION Formerly known as the CURFFL Review Committee CURFFL vs. Cal Code Comparison Chart JANUARY 2007 The following chart is intended to provide a general side-by-side comparison of current law, the California Uniform Retail Food Facilities Law (CURFFL), and the California Retail Food Code (Cal Code) introduced during the month of February 2005 as Senate Bill 144. Please note the following when reviewing the document: The section numbers used in CURFFL are not always identical to those used in Cal Code. Major modifications in Cal Code are noted using bulleted points and yellow highlighting. Blank fields indicate no corresponding reference section. The comparison chart was prepared for discussion purposes only and not intended to serve as a regulatory reference for legal enforcement. California Uniform Retail Food Facilities Law (CURFFL) Code Article 1. General Provisions Chapter 1. General Provisions Chapter Title Chapter Title Intent to Preempt Local Standards Intent to Preempt Local Standards Authority to Adopt Regulations Authority to Adopt Regulations Page 1 of 22

2 Code Authority to Establish Local Requirements Authority to Establish Local Requirements Minimum Standards of Knowledge in Food Safety Section , , Minimum Standards of Knowledge in Food Safety Expands certification requirements to operators of mobile food facilities that handle unpackaged potentially hazardous foods. Requires demonstration of knowledge by operators of temporary food facilities and by operators of food facilities that handle unpackaged nonpotentially hazardous foods. Certification expires five years from the date of issuance References to Previous Laws References to Previous Laws Primary Responsibility for Enforcement Primary Responsibility for Enforcement Compliance with Building Codes Compliance with Building Codes Expands requirements by adding local, state and federal statues, regulations and ordinances Department of Health Services Cost Recovery & Department of Health Services Cost Recovery Structural and Sanitation Requirements Specifies that requirements for food facilities be based on the type of food service activity conducted Enforcement of Potable Water Standards Enforcement of Potable Water Standards Transportation of Animal Byproducts Transportation of Animal Byproducts Article 2. Definitions Chapter 2. Definitions Applicability and Terms Defined Food Additive Adulteration Adulterated Acute Gastrointestinal Illness (a) Approved Approved (b) Approved source Approved Source Page 2 of 22

3 Code aw (water activity) Beverage CCR (California Code of Regulations) Certified Farmers Market Certified Farmers Market CFR (Code of Federal Regulations) CIP (Clean in Place) Comingle Comminuted Comminuted Commissary Commissary Community Event Community Event Consumer Control Point Control Point Critical Control Point Critical Control Point Critical Limit Critical Limit Department Easily Cleanable Easily Movable Egg Employee Employee Enforcement Agency Enforcement Agency Enforcement Officer Enforcement Officer Equipment Equipment Exclude FDA (US Food and Drug Administration) Fish Fish Food Food Food Compartment Food Condiment Condiment Food Contact Surface Food Contact Surface Page 3 of 22

4 Code Food Employee Food Establishment Permanent Food Facility Food Facility Food Facility Modifies the CURFFL definition and includes new terms defined in Chapter 2. Includes the substantive concepts for CURFFL definitions food establishment and food facility in the new definition Food Preparation Food Preparation Game Animal Grade A Standards Frozen Food Frozen Food HACCP HACCP HACCP Plan HACCP Plan HACCP Principles HACCP Plan Contents Hazard Hazard Hearing Officer Hearing Officer Hermetically Sealed Container Hermetically Sealed Container Imminent health hazard Impound Impound Injected Injected Mobile Food Preparation Unit Mobile Food Facility Consolidates CURFFL definitions Mobile Food Preparation Units, Stationary Mobile Food Preparation Units, and Mobile Food Facilities into a new definition of Mobile Food Facility Juice Law Limited Food Preparation Linens Major Violation Page 4 of 22

5 Code Meat Menu Change Minor Violation Mobile Support Unit Mobile Support Unit Molluscan Shellfish Multi-service Utensil Multiservice Utensil Nonpermanent Food Facility Nonprofit Charitable Organization Nonprofit Charitable Temporary Food Facilities Nonprofit Charitable Temporary Food Facilities Occasional Event Open-air Barbecue Facility Open-air Barbecue Facility Outdoor Beverage Bars Outdoor Wood-Burning Oven Permanent food facility Equivalent to the CURFFL definition of Food Establishment Permit Permit Permit Holder Person Person Customer Access Customer Access Person In Charge Personal Care Items ph Plumbing fixture Plumbing system Poisonous or toxic materials Portable Potable Water Potable water Potable Water Potable water Page 5 of 22

6 Code Potentially Hazardous Food Potentially Hazardous Food Expands the definition and includes the most current food safety science Premises Premises Poultry Prepackaged food Prepackaged Food Produce Produce Produce Stand Produce Stand Producer Ready-to-eat Food Ready-to-eat Food Reduced Oxygen Packaging Refrigeration Unit Refrigeration Unit Refuse Remodel Remodel Restricted Food Service Transient Occupancy Establishment, Agriculture Home Stay Page 6 of Restricted Food Service Facility Restrict Retail Retail Sanitization Sanitization Satellite Food Distribution Facility Satellite Food Service Sealed Service Animal Shellfish Certification Number Shellfish Control Authority Shellstock Shucked Shellfish Single Service Utensil Single Service Articles Stationary Mobile Food Preparation Unit Mobile Food Facility Consolidates CURFFL definitions Mobile Food

7 Code Preparation Units, Stationary Mobile Food Preparation Units, and Mobile Food Facilities into a new definition of Mobile Food Facility Slacking Smooth Table Mounted Equipment Tableware Temperature Measuring Device Temporary Food Facility Temporary Food Facility Removes the time restriction from the definition Tight-fitting Transporter USDA Utensil Utensil Mobile Food Facility Mobile Food Facility Consolidates CURFFL definitions Mobile Food Preparation Units, Stationary Mobile Food Preparation Units, and Mobile Food Facilities into a new definition of Mobile Food Facility Variance Variances may be reviewed and approved for certain specialized processes or alternate procedures Vending Machine Vending machine Vermin Vermin Infestation Swap Meet Prepackaged Food Stand (a) Swap Meet Prepackaged Food Prepackaged Food Prepackaged food Swap Meet Swap meet Warewashing Warm water Page 7 of 22

8 Code Article 3. Plan Review and Permits Chapter 13. Article 1 Plan Review and Permits Submission of Plans Submission of plans Expands requirements for plan submissions pertaining to construction of schools and when there are significant changes to a food facility s method of operation or menu. (Menu Change is defined in ) Permit Requirements Permit Requirements Penalties for Operating without Permits Penalties for Operating without Permits Article 4. Enforcement and Inspection Chapter 13. Article 2 Enforcement Authority of Enforcement Officers , Authority of Enforcement Officers Discarding unsafe, adulterated, or contaminated food Establishes standards for determining when food should be discarded Impound Authority Impound Authority Misdemeanor Penalties Misdemeanor Penalties Responsibility of Management Responsibility of Management Shared Responsibility Shared Responsibility Criteria on Food Facility Inspections (CH 1) Criteria on Food Facility Inspections Expands the section by adding improper cooling to criteria for standardized inspection report format Department to Establish Standardization Procedures Reporting Procedures Article 5. Permit Suspension or Revocation Chapter 13. Article 3 Permit Suspension or Revocation Permit Suspension or Revocation Permit Suspension or Revocation Written Notice of Decision Written Notice of Decision Immediate Closure of a Food Facility Immediate Closure of a Food Facility Grounds for Suspension or Revocation Grounds for Suspension or Revocation Reinstatement of Permit Reinstatement of Permit Article 6. General Sanitation Requirements Chapter 4. General Food Safety Requirements Scope Page 8 of 22

9 Code Protection from Contamination Protection from Contamination Approved Source (a), Food From Approved Sources Expands criteria for approved food sources Food transportation requirements Establishes requirements for sanitary transportation of food Protection from Cross Contamination Expands requirements for protecting food from contamination during storage and preparation Ice used for cooling Prohibits use of ice for cooling from food service Washing Produce Requires washing of whole produce before service Written Notice for Connections Containing Alcohol Written Notice for Connections Containing Alcohol Article 7. Sanitation Requirements for Food Facilities Expands and groups CURFFL Article 7 by category in the following chapters: Ch. 3 Management and Personnel Ch. 4 General Food Safety Requirements Ch. 5 Cleaning and Sanitizing of Equipment and Utensils Ch. 6 Equipment, Utensils and Linens Ch. 7 Water, Plumbing & Waste Ch. 8 Physical Facilities Scope Holding Potentially Hazardous Foods , , , , Holding Potentially Hazardous Foods Expands requirements by adding whole roasts and restricting service of raw eggs to highly susceptible populations. Expands requirements for thermometer type, usage, and placement. Page 9 of 22

10 Code Expands requirements for holding time/temperature during food preparation Korean Rice Cakes Korean Rice Cakes Lauren Beth Rudolph Food Safety Act of , , Lauren Beth Rudolph Food Safety Act of Cooking and Hot Holding Fruits and Vegetables Establishes new requirements for cooking (for hot holding) fruits and vegetables Pasteurized Eggs or Egg Products Requires use of pasteurized eggs or pasteurized egg products for preparation of foods containing raw or undercooked eggs, unless a consumer advisory is provided Food Honestly Presented Labeling Other forms of Information Prohibits altering/concealing voluntary manufacturer applied code dates Highly Susceptible populations-pasteurized foods, prohibited reservice, and prohibited food Requires that only pasteurized juice, milk, and eggs (in specified foods) be served at food facilities that provide food service to highly susceptible populations Holding of Raw Shell Eggs (Ch 12 Certified Farmers Markets) Holding of Raw Shell Eggs Reheating of Foods Reheating of Foods Exemption for Commercially Processed Foods , Exemption for Commercially Processed Foods Exemption for Chinese-style Roast Duck Exemption for Chinese-style Roast Duck Cooling of Potentially Hazardous Food , Cooling of Potentially Hazardous Food Cooling, heating, and holding capacities Requires equipment to be sufficient in number and Page 10 of 22

11 Code capacity for food temperature control Inspection upon Receipt , Inspection upon Receipt Significantly expands requirements for receipt of food , Molluscan shellfish tanks Adds requirements for molluscan shellfish tanks Use of Donated Fish and Game Use of Donated Fish and Game Food Must Be Protected Food Must Be Protected Ice for cooling made from potable water Fish must be Commercially Caught Returned Food - Food Prepared in Private Homes (b), , , , (CH 11) Returned Food - Food Prepared in Private Homes Requirements for Food Handlers , , , Requirements for Food Handlers Hand Sanitizers Establishes criteria for use of hand sanitizers Prevention of contamination when tasting Posting of Signs , Posting of Signs Prevention of Disease Transmission , Prevention of Disease Transmission Significantly expands food employee health requirements Use and Storage of Pesticides Use and Storage of Pesticides Expands requirements for storage and use of pesticides Exclusion of Vermin , Exclusion of Vermin Disposal of Waste Disposal of Waste Expands requirements for refuse storage and disposal Maintenance of Premises Maintenance of Premises Exclusion of Live Animals (CH 2), Exclusion of Live Animals Maintenance , , , , , , Maintenance and Operation Expands maintenance, storage, and operational requirements for equipment and utensils. Page 11 of 22

12 Code Requirements for HACCP Plans Requirements for HACCP Plans HACCP Plans Requiring Approval HACCP Plans Requiring Approval Variances allowed Variances require approval from the State Department of Health Services (DHS) for certain specialized processes or alternate procedures Variance Provides a detailed process for evaluating, approving, and suspending/revoking a variance Date Marketing of Containers & Reduced Oxygen Packaging Date Marketing Expands requirements for reduced oxygen packaging Requirements for Manual Sanitization , Requirements for Manual Sanitization Equipment Standards Equipment Standards Expands equipment construction requirements, establishes procedures for cleaning equipment in place, and establishes standards for use of lubricants on food equipment Food Preparation Sinks Requires use of a food preparation sink for washing, rinsing, soaking, thawing, etc of food Single use articles not reused Preset tableware Establishes new requirements for preset tableware Using clean tableware for second portions and refills Condiment Dispensers Establishes requirements for service and storage of condiment containers Display and storage of single and multi-use utensils Handling of Soiled tableware Beverage tubing, separation Page 12 of 22

13 Code Fixed Equipment, spacing or sealing Ice units, separation of drains Securing Pressurized Cylinders Sulfite Prohibition Sulfite Prohibition Expands prohibition of sulfites to produce and prohibits use of other unapproved additives. Article 8. Sanitation Requirements for Food Establishments Page 13 of 22 Expands and groups CURFFL Article 8 requirements by category in the following chapters: Ch. 4 General Food Safety Requirements Ch. 5 Cleaning and Sanitizing of Equipment and Utensils Ch. 6 Equipment, Utensils and Linens Ch. 7 Water, Plumbing & Waste Ch. 8 Physical Facilities Ch. 9 Permanent Food Facilities Applicable CalCode sections for permanent food facilities Scope Food Display/Storage Requirements , , , , , Food display/storage requirements Expands requirements for methods of food display/storage Frozen Food Handling , Frozen Food Handling Expands frozen food requirements by adding slacking and keeping frozen food frozen Cleaning and Sanitization of Utensils and Equipment , Cleaning and Sanitization of Utensils and Equipment Establishes provisions for use of alternative ware washing facilities Returnables, cleaning for refilling Cleaning maintenance tools, preventing contamination Warewashing sinks, use limitation

14 Code Water Supply , , Water Supply Expands requirements by adding provisions for use of boiler water additives and providing a sufficient level and capacity of water under pressure Installation and Maintenance of Plumbing , , , , , Installation and Maintenance of Plumbing Toilet Facilities , Toilet facilities Exemption from Toilet Requirements for Amusement Exemption from Toilet Requirements for Amusement Parks, ETC. Parks, ETC Hand washing Facilities Hand washing Facilities Establishes new requirements pertaining to installation and use of hand washing facilities Customer Toilet-Facilities Customer Toilet-Facilities Employee Changing Room Employee Changing Room Expands storage requirements to employee medicines and first aid supplies Ventilation Ventilation Expands construction and make up air requirements and removes exhaust hood exemption procedure from review by the State of California Department of Health Services to review and approval by the local enforcement agency Enclosure of Food Establishments , , Enclosure of Food Establishments Enclosure of Food Establishments Exemption Exemption for Mercado La Paloma Food Preparation Counter Space, Protection from Environmental Contamination, Limited food preparation. Introduces the concept of limited food preparation to standardize construction requirements and methods of food preparation for both enclosed and unenclosed food facilities Construction of Floors , Construction of Floors Construction of Walls Construction of Walls and Ceilings Page 14 of 22

15 Code Linens Linens Expands requirements for use of linens and wiping cloths Janitorial Closet, Mop Sink Janitorial Closet, Mop Sink Lighting Lighting Sleeping Accommodations Prohibited Sleeping Accommodations Prohibited First Aid Instructions Article 9. Open-Air Barbecue Facilities Consolidates CURFFL Article 9 requirements into Chapter 6. Article 1. Design and Construction Scope Requirements , , Requirements Preemption of Air Pollution Control Requirements Preemption of Air Pollution Control Requirements Article 10. Vending Machines Chapter 6. Article 1 Vending Machines Consolidates CURFFL Article 10 requirements into Chapter 6. Article 1. Design and Construction Scope Declaration of Ownership Declaration of Ownership Manner of Food Storage Manner of Food Storage Sanitization of Food Contact Surfaces , Sanitization of Food Contact Surfaces Storage if Single Service Containers Storage if Single Service Containers Location of Vending Machines Location of Vending Machines Water Quality Water Quality Protection from Contamination during Transport Protection from Contamination during Transport Vending Machine Standards Specific Vending Machine Requirements Applicable CURFFL Page 15 of 22

16 Code Article 11. Mobile Food Facilities Chapter 10. Mobile Food Facilities Consolidates and standardizes CURFFL requirements for Mobile Food Facilities, Mobile Food Preparation Units, and Stationary Mobile Food Preparation Units into the new definition of Mobile Food Facility. Consolidates general food safety requirements in Chapters 3-8 to ensure uniformity in interpretation and enforcement for regulated food facilities. Distinct construction and operational requirements for Mobile Food Facilities are included in chapter 10. Expands foods handled on Mobile Food Facilities to Limited Food Preparation (as defined in section ). Also expands construction and operation requirements commensurate with the types and methods of food prepared. Facilities approved prior to the implementation date are grand fathered unless there is a significant change in menu or modification of equipment Scope Applicable CURFFL Applicable Cal Code Types of Food Handled, Requirements Types of Food Handled, Requirements Construction Requirements , , , , , , , , Construction Requirements Sale of Non-prepackaged Food Sale of Non-prepackaged Food Exemption , Exemption Height and Width of Occupied Areas Height and Width of Occupied Areas Article 12. Mobile Food Preparation Units, Stationary Chapter 10 Mobile Food Facilities Mobile Food Preparation Units Consolidates and standardizes CURFFL requirements for Mobile Food Facilities, Mobile Food Preparation Units, and Stationary Mobile Food Preparation Units into the new definition of Mobile Food Facility. Consolidates general food safety requirements in Page 16 of 22

17 Code Chapters 3-8 to ensure uniformity in interpretation and enforcement for regulated food facilities. Distinct construction and operational requirements for Mobile Food Facilities are included in chapter 10. Exempts Mobile Food Facilities operating at community events from the commissary requirements Scope Applicable Requirements, Exemptions, Initial Applicable Requirements, Exemptions, Initial Approval Approval Operation from a Commissary Operation from a Commissary Cleaning and Servicing of Mobile Food Facilities Cleaning and Servicing of Mobile Food Facilities Hot and Cold Beverage Counter, Stationary Mobile Food Preparation Unit Page 17 of Hot and Cold Beverage Counter, Mobile Food Facilities Expands requirements allowing Mobile Food Facilities (as defined in Cal Code) to have a staffed counter while operating at a community event Storage of Non-potentially Hazardous Food Adjacent Storage of Non-potentially Hazardous Food Adjacent Expands requirements for Mobile Food Facilities (as defined in Cal Code) operating at a community event by allowing storage of foods adjacent to the facility under certain conditions Exterior and Surrounding Area to be Sanitary Exterior and Surrounding Area to be Sanitary Waste Containers for Customer Use Waste Containers for Customer Use Protection from Contamination Protection from Contamination Storage of Non-food Items, Chemicals, Food, , , , Storage of Non-food Items, Utensils Chemicals, Food, Utensils Identification of Owner, Location of Compressors, , Identification of Owner, Location of etc. Compressors, etc Construction, Equipment Requirements , , , , , , , , , , Construction, Equipment Requirements Mechanical Exhaust Ventilation Mechanical Exhaust Ventilation

18 Code Safety Requirements Safety Requirements Pass-Through Windows Pass-Through Windows Electrical Power Requirements Electrical Power Requirements Water Supply and Wastewater Tanks, Toilet , , , , Water Facilities Article Commissaries Page 18 of 22 Supply and Wastewater Tanks, Toilet Facilities Consolidates CURFFL Article 12.5 requirements into Chapter 10. Mobile Food Facilities Scope Applicable Requirements , Applicable Requirements Liquid and Solid Waste Disposal , Liquid and Solid Waste Disposal Potable Water Supply , Potable Water Supply Electrical Power Outlets Electrical Power Outlets Mobile Support Unit Plan Review, Approval, Mobile Support Unit Plan Review, Approval, Identification Identification Article 13. Temporary Food Facilities Chapter 11. Temporary Food Facilities Scope General Requirements General Requirements Food from an Approved Source , Food from an Approved Source Identification of Operator Identification of Operator Permit Requirements for Event Organizer Permit Requirement for an Organizer Expands permit requirement to the person or organization responsible for facilities that are shared by food facilities at a swap meet Permit Requirement for Temporary Food Facility Expands requirements by adding facility layout and procedures , Temperature Requirements for Potentially Hazardous Foods Temperature Requirements for Potentially Hazardous Foods Live Animal Prohibition Live Animal Prohibition Equipment Standards Equipment Standards

19 Code Ice Restrictions Ice Restrictions Operating Requirements ,114356, , Operating Requirements Conditions of Transport Conditions of Transport Toilet Facilities Toilet Facilities Employee Personal Effects Storage Employee Personal Effects Storage Lighting Lighting Water Supply , Water Supply , , Liquid Waste Liquid Waste Facilities Facilities Open Air Barbecue , Open Air Barbecue Enforcement Officer Discretion in Imposing Requirements Enforcement Officer Discretion in Imposing Requirements Requirements for Prepackaged Foods , Requirements for Prepackaged Foods Requirements for Non-prepackaged Foods , , , , Expands requirements by allowing alternative methods to full enclosure of temporary food facilities Staffed Counter Article Nonprofit Charitable Temporary Food Facilities Chapter 10. Article Nonprofit Charitable Temporary Food Facilities Scope Scope Frequency and Duration of Operations Frequency and Duration of Operations Hand Washing, Utensil Washing, Liquid Waste, Toilet, Food Contact Surface Requirements Hand Washing, Utensil Washing, Liquid Waste, Toilet, Food Contact Surface Requirements Operational Requirements Operational Requirements Additional Requirements Additional Requirements Open-air Barbecues Open-air Barbecues Authority to Inspect and Require Permits Authority to Inspect and Require Permits Page 19 of 22

20 Code Article 14. Produce Stands Consolidates CURFFL Article 14 requirements into general food safety requirements with Produce Stand defined in Chapter 2. Section Scope Produce Stand is defined as a permanent food facility. Consolidates CURFFL Article 14 into general food safety requirements in the Cal Code so construction and operation are commensurate with the types of food handled. A producer remains exempt from the code Requirements , , , Requirements Article 15. Certified Farmers Markets Chapter 12. Certified Farmers Markets Scope Requirements , Requirements Article 16. Swap Meet Prepackaged Food Stands Page 20 of 22 Consolidates CURFFL Article 16 requirements into Chapter 11. Temporary Food Facilities Requirements Requirements Consolidates requirements for swap meet prepackaged food stands into Chapter 11, Temporary Food Facilities. Expands requirements allowing swap meets to operate temporary food facilities under certain conditions. Article 17. Satellite Food Distribution Facilities Chapter 4. Article 7. Food Display and Service Scope Requirements Requirements Permitted Activities , Permitted Activities Expands permitted activities to Limited Food Preparation (with approved equipment) Food Storage , Food Storage Support by Onsite Food Establishment Support by Onsite Food Establishment Restroom Requirements , Restroom Requirements Exemption from Full Enclosure , Exemption from Full Enclosure Location Location

21 Code Requirements Requirements Written Procedures Written Procedures Article 18. Restricted Food Service Transient Occupancy Consolidates CURFFL Article 18 requirements into general Establishments, Agricultural Homestay food safety sections Scope Requirements (CH 2 Definition of Restricted Food Service Facility) Consolidates CURFFL Article 18 into general food safety requirements in the Cal Code to ensure uniformity in interpretation and enforcement. The construction exemptions remain the same Not a Private Home Not a Private Home Exemption from Required Signs in Guestrooms Exemption from Required Signs in Guestrooms Exemption from Prohibition of Live Animals Exemption from Prohibition of Live Animals Exemption from Equipment Standards Exemption from Equipment Standards Exemption from Requirement for Employee Exemption from Requirement for Employee Changing Changing Room Room Requirements for Sanitizing of Utensils and , Requirements for Sanitizing of Utensils and Equipment Equipment Exemption from Indirect Sewer Connection Exemption from Indirect Sewer Connection Requirements Requirements Exemption from Ventilation Requirements Exemption from Ventilation Requirements Exemption from Construction Requirements Exemption from Construction Requirements Exemption from Plumbing Requirements Exemption from Plumbing Requirements Exemption from Prohibition of Sleeping/Living Exemption from Prohibition of Sleeping/Living Quarters Quarters Food from Approved Source Food from Approved Source Article 19. Food Facility Food Donations Page 21 of 22 Chapter 13. Food Facility Donations The requirements for food facility donations, formerly a separate article, are consolidated into Chapter Donations of Food to Charity Donations of Food to Charity

22 Code Definition of Nonprofit Charitable Organization Definition of Nonprofit Charitable Organization Definition of Food Bank Definition of Food Bank Immunity from Civil Liability Immunity from Civil Liability Citation of Additional Immunities Citation of Additional Immunities Article 20. Child Day Care Facilities, Community Care Chapter 13. Article 8. Child Day Care Facilities, Community Facilities, and Residential Care Facilities Care Facilities and Residential Care Facilities for the Elderly Intent for Legislature Definitions Definitions Exemptions from CURFFL Exemptions from CURFFL Delegation to State Department of Social Services Delegation to State Department of Social Services Establishes requirements for referring facilities with repeat and major violations to the appropriate state or local enforcement agency. Requires the State Department of Social Services to develop regulations that are consistent with Cal Code. Page 22 of 22

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