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134. American Frozen Food Institute

134. American Frozen Food Institute

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Published by lhfang

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Published by: lhfang on Dec 16, 2011
Copyright:Attribution Non-commercial


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November 14, 2011Don FoxActing Director and General CounselOffice of Government Ethics1201 New York Avenue NWWashington, DC 20005-3917Re: RIN 3209-aa04 [Proposed Amendments Limiting Gifts from RegisteredLobbyists and Lobbying Organizations]Dear Mr. Fox:The American Frozen Food Institute (AFFI) appreciates the opportunity to providecomments on the Office of Government Ethics’ (OGE) proposed rule [RIN 3209-AA04] that would prohibit executive branch employees from accepting invitations to “widely attended gatherings” (WAG) hosted by trade associations.AFFI is the national trade association that represents all segments of the frozenfood industry, including more than 500 companies located throughout the U.S. andaround the world. AFFI fosters industry development and growth througheducational programming and conferences; advocates on behalf of its membersbefore legislative and regulatory entities; and provides additional value-addedservices for its members and for the benefit of the consuming public.In its proposed rule, OGE justifies preventing federal employees from attendingtrade association WAGs based on the presumption that “the primary concern of such associations generally is not the education and development of members of aprofession or discipline.” This statement demonstrates a lack of understandingabout the mission of AFFI and other trade associations like ours.Indeed, OGE’s proposal fails to appreciate that one of the most significant benefitscompanies and their employees gain through their membership in AFFI is theopportunity to share best practices with one another and understand the latestregulatory developments that affect their operations. Education is very much at thecore of the services AFFI provides its members.Across a broad spectrum of topics, including food safety, food science, foodstandards, improved nutrition and enhanced logistical and environmentalperformance, AFFI provides its members with a substantial suite of educationalprograms and services. These programs and services are designed to ensure ourmembers have access to critical information.

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