Taming Of The 'Ostrich Officers'

Law360, New York (April 4, 2011, 1:51 PM EDT) -- Last month, the U.S. Food and Drug Administration amended its Regulatory Procedures Manual (RPM) to add Section 6-5-3, entitled “Special Procedures and Considerations for Park Doctrine Prosecution,” further signaling that it intends to pursue more criminal prosecutions against “responsible corporate officers.”

The new manual section states: “The Park Doctrine, as established by Supreme Court case law, provides that a responsible corporate official can be held liable for a first-time misdemeanor (and possible subsequent felony) under the Federal Food, Drug and Cosmetic Act (FFDCA) without proof that...
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