Todd Harrison, co-chair of Venable's FDA Group, guides clients through the myriad government regulations associated with food and drug labeling and marketing. Working extensively in the areas of food and dietary supplement safety, labeling, and advertising claims, Todd helps clients in the consumer products, drug and medical device, and dietary products industries comply with government regulations. He regularly achieves favorable results in defending clients against Federal Trade Commission (FTC) advertising complaints, enforcement actions, and prosecutions, and overcoming competitor challenges in courts and other fora.
Todd has substantial experience in food and dietary supplement marketing, including health claims, structure/function claims, and nutrient content claims. He is also well versed in federal, state, and international consumer protection agency rules related to drugs, food, supplements, homeopathic remedies, medical devices, and cosmetics. He concentrates on compliance and cooperation with the Food and Drug Administration (FDA), the Department of Agriculture’s Food Safety and Inspection Service (FSIS), the Animal and Plant Health Inspection Service (APHIS), the Agricultural Marketing Service (AMS), the FTC, and the Drug Enforcement Administration (DEA).
Todd advises clients on labeling requirements, organic products, and genetically modified organisms — developing strategies for companies to communicate information about their products without running afoul of agency regulatory requirements. He has assisted companies with compliance issues, including Hazard Analysis and Critical Control Points (HAACP), best practices in manufacturing, product recalls versus market withdrawals, inspections, warning letters, FDA and the FSIS standards of identities compliance, importing meat and poultry products into the United States, and recordkeeping.
Todd drafts opinion letters regarding the status of food ingredients in the United States and assists in the preparation of food additive petitions, Generally Recognized as Safe (GRAS) notifications, and new dietary ingredient notifications. He also helps companies develop self-determined GRAS positions for food ingredients.