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Scott Rafferty is an attorney in Walnut Creek, California. He served as Deputy Director at the Administrative Conference of the United States, where he managed research into third-party certification at the FDA and other agencies. Scott received his law degree from Yale and doctorate in regulatory economics from Oxford, where he was a Rhodes Scholar. He was counsel to the House Telecom Subcommittee during the AT&T divestiture, worked in the strategy practice at McKinsey & Co., ran NYNEX’s consulting division, and has testified as an economist for a dozen states on regulatory issues. Scott can be reached at

Congress told the U.S. Food and Drug Administration (FDA) to require importers, beginning no later than July 2012, to verify the safety of each shipment entering the U.S. Those who relied upon independent private inspections (“3rd party certification”) were to be rewarded with expedited entry through customs. Independent inspections
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