87-001611 The Citrus Hill Manufacturing Company vs. Department Of Citrus Status: Closed Recommended Order on Wednesday, December 9, 1987.

Summary: Petitioner requested to retain the word "juice" on its diluted citrus product lables. Recommend that Respondent recind order to discontinue word "juice."

STATE OF FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

THE CITRUS HILL MANUFACTURING )

COMPANY, an Ohio Corporation , )

)

Petitioner , )

)

vs. ) CASE NO. 87-1611

)

STATE OF FLORIDA, DEPARTMENT )

OF CITRUS , )

)

Respondent. )

________________________________)

RECOMMENDED ORDER

Pursuant to notice, an administrative hearing was held before Diane D.

Tremor, Hearing Officer with the Division of Administrative Hearings, on

September 24, 1987, in Lakeland, Florida. The issue for determination in this

proceeding is whether the Department of Citrus may require the petitioner to

eliminate the word "juice" from its labels for diluted citrus products produced,

manufactured, packaged and distributed in Florida.

APPEARANCES

For Petitioner : Peter J. Winders and

James J. Kennedy, III

Carlton, Fields, Ward,

Emmanuel, Smith, Cutler & Kent, P.A.

One Harbor Place

Post Office Box 3239

Tampa, Florida 33691

and

Karl S. Steinmanis, Esquire

One Proctor and Gamble Plaza

Cincinnati, Ohio 45292-3315

For Respondent : J. Hardin Peterson, Jr., Esquire

Peterson, Myers, Craig, Crews,

Brandon & Mann, P.A.

Post Office Drawer BS

Lakeland, Florida 33802

and

Kristen C. Chadwell, Esquire

General Counsel

Department of Citrus

Post Office Box 148

Lakeland, Florida 33802-0148

INTRODUCTION

Pursuant to Section 120.57(1), Florida Statutes, petitioner, the Citrus

Hill Manufacturing Company, sought a hearing on the issue of whether the

Department of Citrus may compel it to change the labels on its diluted citrus

fruit products by removing the word "juice" from the labels. This proceeding

was consolidated for hearing purposes with Division of Administrative Hearing's

Case No. 87-3078R, bearing the same caption, which challenged the validity of

Rule 20-66.001(4), Florida Administrative Code. The latter proceeding is the

subject of a separate Final Order entered on this same date.

In support of its position that the Department may not lawfully ban the

word "juice" from appearing on the labels of diluted citrus fruit beverages,

petitioner presented the testimony of Charles Anthony Parsons, the manager of

purchases for Citrus Hill Manufacturing Company (Citrus Hill); Richard J.

Coomes , the regulatory affairs manager for the beverage products division of

Proctor and Gamble; and Joseph Ottaviani , a vice-president and regional manager

with Burke Marketing Research. Petitioners' Exhibits 1, 2, 6 and 7 were

received into evidence.

The respondent, Department of Citrus, presented the testimony of Douglas

Hoffer, the former marketing director with the Department of Citrus, and Dr.

Poonam Mittal, a market research coordinator with the Department of Citrus. The

respondent's Exhibits A through D were received into evidence.

Official notice was taken of the documents listed in Hearing Officer's

Exhibit 1. Subsequent to the hearing, both parties submitted proposed orders.

To the extent that the parties' proposed findings of fact are not included in

this Recommended Order, they are rejected for the reasons set forth in the

Appendix hereto.

FINDINGS OF FACT

Upon consideration of the oral and documentary evidence adduced at the

hearing, the following relevant facts are found:

1. Citrus Hill Manufacturing Company (Citrus Hill) is a wholly owned

subsidiary of Proctor and Gamble. Citrus Hill is in the business of producing,

manufacturing, packaging and distributing citrus products throughout the United

States. It's main product has been "Select" orange juice which is 100 percent

orange juice. Its principle manufacturing facility is located in Frostproof,

Florida. While Citrus Hill has four other manufacturing sites outside the State

of Florida, its Florida plant is the only facility for manufacturing frozen

products. While it can produce chilled products at its plants located outside

Florida, Citrus Hill's Florida plant is necessary to supply the demand for its

chilled products on a national basis.

2. In an effort to expand its market, Citrus Hill developed three products

which it produces and packs at its plant in Frostproof, Florida. These products

are and have been labeled as follows:

(a) " Lite Citrus Hill Orange Juice Beverage

- 60 percent Orange Juice,"

(b) " Lite Citrus Hill Grapefruit Juice Beverage

- 45 percent Grapefruit Juice," and

(c) "Plus Calcium Citrus Hill, Calcium Fortified

Grapefruit Juice Beverage - 60 percent Grapefruit

Juice." The " lite" beverages are reduced calorie

diluted juice beverages with the addition of

Nutrasweet . The third product is a diluted

grapefruit juice beverage fortified with calcium.

3. By a letter dated March 19, 1987, the Department of Citrus ordered

Citrus Hill to change its diluted citrus products labels and informed Citrus

Hill that the Department would enforce Rule 20-66.001(4), Florida Administrative

Code. That rule provides

"Labels for diluted citrus products

shall not include the word "juice" in

the name of the product."

By a Final Order entered this same date, that Rule was declared to be an invalid

exercise of delegated legislative authority.

4. As noted above, Citrus Hill markets and sells its product line

throughout the United States. It desires to utilize the names of its diluted

juice products as indicated in paragraph two above for three reasons. First,

Citrus Hill believes that its labeling is in compliance with federal law.

Second, it believes that a product name which includes the word "juice" more

fully informs the consumer of the nature of the product because it is more

exact, descriptive and less ambiguous than any name not using the word "juice,"

such as "drink," " ade," or "beverage." Third, Citrus Hill fears that if it were

unable to disclose through its product name that the product is primarily a

juice product, it would be placed at a competitive disadvantage in the national

marketplace where non-Florida producers of similar products would not be bound

by the challenged Rule's ban on the use of the word "juice" in the name of

diluted juice products. While Citrus Hill could move its packaging facilities

outside the state and utilize two product labels (one for Florida shipment and

one for the non-Florida market), this alternative would be extremely expensive

and would constitute a "distribution nightmare." Many distributors and large

retail grocery stores work in multi-state regions and may not be willing to

segregate and keep track of petitioner's different product labels for shipment

in Florida and in non-Florida states.

5. No other state in the United States prohibits the word "juice" in the

labeling of diluted citrus juice products.

6. In the late 1960's and early 1970's, the subject of proper labeling of

diluted fruit juice beverages was under discussion by both the Florida

Department of Citrus and the Federal Food and Drug Administration (FDA) under

the Food, Drug and Cosmetic Act. The FDA ultimately rejected the proposal of

prohibiting the word "juice" from the name of any product that was not 100

percent pure juice, and also rejected the approach of defining different

products through "standards of identity." This latter method of labeling

products would have defined a product as "fades" only if containing more than 10

percent, but less than 20 percent, juice, and various other category names based

upon the percentage of fruit juice contained in the product. The prohibition

against the word "juice" and the "standards of identity" proposals for the

labeling of diluted juice products were rejected by the FDA in favor of a common

or usual name approach, with a percent declaration of any characterizing

ingredient.

7. The pertinent federal regulations addressing the labeling of food

products are contained in 21 C.F.R. Chapter 1. The more general regulation

appears in 21 C.F.R. 102.5(a) and (b), and states, in pertinent part, as

follows:

"Section 102.5 General Principles.

(a ) The common or usual name of a

food ... shall accurately identify

or describe, in as simple and

direct terms as possible, the basic

nature of the food or its

characterizing properties or

ingredients. The name shall be

uniform among all identical or

similar products and may not be

confusingly similar to the name of

any other food that is not reasonably

encompassed within the same name.

Each class or subclass of food shall

be given its own common or usual name

that states, in clear terms, what it

is in a way that distinguishes it

from different foods.

(b ) The common or usual name of a

food shall include the percentage(s)

of any characterizing ingredient(s)

or component(s) when the .

component(s) ... has a material

bearing on ... consumer acceptance

or when the labeling ... may

otherwise create an erroneous

impression that such ...

component(s) is present in an amount

greater than is actually the case.

The following requirements shall

apply unless modified by a specific

regulation in Subpart B of this part.

(1 ) The percentage of a

characterizing ingredient or

component shall be declared on the

basis of its quantity in the finished

product...

(2 ) The percentage of a

characterizing ingredient or

component shall be declared by the

words "containing (or contains)

percent (or %) ---" ... with the

first blank filled in with the

percentage expressed as a whole

number not greater than the actual

percentage of the ingredient or

component named and the second blank

filled in with the common or usual

name of the ingredient or component."

8. The FDA has also promulgated regulations dealing with the labeling of

specific nonstandardized foods, including diluted orange juice beverages and

diluted fruit or vegetable juice beverages other than diluted orange juice

beverages. With respect to diluted orange juice beverages, 21 C.F.R. Section

102.32 provides as follows:

"102.32. Diluted Orange Juice Beverages.

(a ) The common or usual name of a non-

carbonated beverage containing less than

100 percent and more than 0 percent

orange juice shall be as follows:

(1 ) A descriptive name for the product

meeting the requirements of Section

102.5(a)(e.g., diluted orange juice

beverage or another descriptive phrase),

and

(2 ) A statement of the percent of each

juice contained in the beverage in the

manner set forth in Section 102.5(b)(2).

The percent of the juice shall be declared

in 5 percent increments, expressed as a

multiple of five not greater than the

actual percentage of orange juice in the

product, except that the percent of

orange juice in products containing more

than 0 percent but less than 5-percent

orange juice shall be declared in the

statement as "less than 5" percent."

Diluted fruit or vegetable juice beverages other than diluted orange juice

beverages are the subject of 21 C.F.R. Section 102.33, 1/ which provides as

follows:

"102.33 Diluted fruit or vegetable juice

beverages other than diluted orange juice

beverages.

(a ) The common or usual name of a non-

carbonated beverage containing less than

100 percent and more than zero percent

fruit or vegetable juice(s), other than

only orange juice, shall be as follows:

(1 ) A descriptive name meeting the

requirements of Section 102.5(a)(e.g.,

" diluted grape juice beverage", "grape

juice drink", or another descriptive

phrase) and

(2 ) A statement of the percent of each

juice contained in the beverage in the

manner set forth in Section 102.5(b)(2).

The percent of the juice shall be

declared in five percent increments,

expressed as a multiple of five not

greater than the actual percentage of

juice in the beverage except that the

percentage of any juice in beverages

containing more than zero percent but

less than 5 percent of that juice shall

be declared in the statement as "less

than 5 percent."

9. The Department of Citrus has conducted two consumer surveys for the

purpose of determining whether the word "juice" in a product name of a diluted

citrus juice product is confusing or misleading. The Drossler study was

conducted in 1972, and concluded that consumers are confused by the word

"juice." However, that conclusion appears to be founded on the premise that the

only proper use of the word "juice" is in the technical sense of "100 percent

pure juice." In other words, what was measured in the survey was the consumer's

failure to use the word "juice" in a limited sense to mean "100 percent pure

juice." The surveyed consumer was asked to look at several products, and then

state "what kind of product is this?" The products viewed consisted of several

different dairy products and a citrus beverage. If the consumer used the word

"juice" to describe the kind of product pointed to, he was treated as being

confused if the product was less than 100 percent juice. No follow-up questions

were asked concerning the consumer's understanding of the content of the

product. The Chelsea study was conducted at the request of the Department of

Citrus in 1987. It, too, concludes that there would be less consumer confusion

if the word "juice" were eliminated from products comprised of less than 100

percent pure citrus juice. However, there was evidence that this study

attempted to address too many issues, including consumer preferences, and that

"question contamination" could well have occurred. This refers to the

intentional or unintentional biasing of the interviewees by the ordering or

phraseology of the questions asked. Both the Burke study and the Chelsea study

indicate that consumers are not confused by a beverage label using the word

juice in the product name when it is accompanied by the declaration of the

percentage of juice contained in the product.

10. The Burke study was conducted on behalf of the petitioner in 1987.

After conducting interviews of 1200 people from all age groups in six different

cities throughout the United States, it concluded that there was no significant

difference in consumer confusion between the use of the word "juice" and

"beverage" in the product name when the percentage of citrus juice content is

indicated on the label. In other words, whether the label identified the

product as a "juice beverage" or a "beverage," the respondents were able to

determine the amount of actual juice contained in the product.

CONCLUSIONS OF LAW

11. As a producer, manufacturer, packager and distributor of citrus

products and diluted citrus beverages in Florida and throughout the United

States, the Citrus Hill Manufacturing Company's substantial interests are at

stake when the Department of Citrus issues a directive or order governing the

label contents of its products. Petitioner thus has standing, pursuant to

Section 120.57, Florida Statutes, to seek an administrative hearing challenging

the validity of the Department's action of attempting to prohibit the word

"juice" from appearing on the label of any diluted citrus product manufactured

or labeled by the petitioner in Florida.

12. Petitioner challenges the Order of the Department to change its labels

on the same grounds as it challenged the validity of Rule 20-66.001(4), Florida

Administrative Code. Just as an administrative agency may not adopt rules which

exceed or are in conflict with its delegated legislative authority, neither may

it enter orders or directives which exceed or are in conflict with its statutory

authority. Petitioner contends that the Department's action of prohibiting the

word "juice" in labels for diluted citrus beverage products is unlawful because

it conflicts with the respondent's statutory grant of authority, it is not an

appropriate regulatory measure to achieve the statutory goals and it bears no

rational relationship to the purposes and goals of the Florida Citrus Code.

13. The respondent Department of Citrus urges that the challenged action

is reasonable, rational and is within its statutory authority. It is further

urged that the federal rules are neither mandatory, preemptive or repugnant to

Florida's position regarding the labeling of diluted citrus products.

14. For the same reasons that Rule 20-66.001(4) constitutes an invalid

exercise of delegated legislative authority, the Department's order or directive

to the petitioner to change its labels in accordance with that rule is unlawful

and invalid.

15. The legislature recognized that the citrus crop is the major

agricultural enterprise in Florida and enacted the Florida Citrus Code to

protect health and welfare and to stabilize and protect the citrus industry.

Section 601.02(1), Florida Statutes. Other purposes for the enactment of the

Citrus Code include the protection and enhancement of the quality and reputation

of Florida citrus fruit in domestic and foreign markets, the stabilization of

the citrus industry, the protection of the public against fraud, deception and

financial loss through unscrupulous practices and haphazard methods of

processing and marketing, and the promotion of the general welfare of the citrus

industry. Section 601.02(3), (5) and (6), Florida Statutes.

16. To effectuate the purposes and intent of the Citrus Code, the

Legislature bestowed upon the Department of Citrus broad authority to adopt

rules and orders in order to exercise and perform its duties under Chapter 601.

See Section 601.10(1), Florida Statutes. With regard to the labeling of citrus

fruit products, the Department was delegated the authority to prescribe rules or

regulations

" provided, however, that no standard,

regulation, rule, or order under this

section which is repugnant to any

requirement made mandatory under

federal law or regulations shall apply

to citrus fruit ... products ...

which are being shipped from this

state in interstate commerce ...

(Emphasis supplied)

Section 601.11, Florida Statutes. That same section goes on to provide that the

Department's regulations, rules and orders with regard to the marking of citrus

fruit products

" shall, when not inconsistent with

state or federal law, have the force

and effect of law."

17. It is the respondent's position in this proceeding that the federal

rules regarding the general labeling of foods and the specific labeling of

diluted fruit juice beverages are not mandatory and are thus not preemptive of

Florida rulemaking or directives on the same subject. Whether those portions of

the federal rules are or are not preemptive, thus rendering the inconsistent

Florida position on the subject invalid as a violation of the Supremacy Clause

of the United States Constitution, is not and need not be determined in this

proceeding. The statute enabling the respondent to act in the area of the

marking and labeling of citrus products prohibits action repugnant to mandatory

requirements of federal rules, and also prohibits orders which are inconsistent

with federal law. It was not necessary for the Legislature to instruct the

Department of Citrus that it could not act in violation of the Supremacy Clause

of the Constitution of the United States. The legislative intent is clear. The

Department was given authority to adopt rules and orders not repugnant to

requirements made mandatory under federal law or regulations and not

inconsistent with federal law. Section 601.11, Florida Statutes.

18. There can be no doubt that both the general and the more specific

federal regulations regarding the labeling of food and beverage products are

mandatory. The federal regulations with respect to the labeling of food

products proclaim that the common or usual name of a food "shall" accurately

identify or describe the basic nature of the food and "shall" include the

percentage of any characterizing ingredient. 21 C.F.R. Section 102.5(a) and

(b). With respect to the labeling of diluted orange juice products, the federal

rule proclaims that the name "shall be" a descriptive name for the product

meeting the requirements of Section 102.5(a) and a statement of the percent of

each juice contained in the beverage. 21 C.F.R. Section 102.32. The labeling

of diluted juice beverages other than orange juice is similarly prescribed in

mandatory terms in 21 C.F.R. Section 102.33.

19. The Department's action of banning the word "juice" from the labeling

of diluted citrus products is both repugnant to and inconsistent with the

federal rules. Where the general federal rule requires a common or usual name,

in as simple and direct terms as possible, along with the percentage declaration

of any characterizing ingredient ; the Department position would prohibit both

the common name and a percentage declaration. Likewise, the more specific

federal rules pertaining to diluted juice beverages require both a descriptive

name for the product and a statement of the percent of each "juice" contained in

the product. It would be impossible to comply with these federal requirements

without utilizing the word "juice." Thus, the Department's position is both

repugnant to and inconsistent with the federal regulations set forth in 21

C.F.R. 102.5(a) and (b), 102.32 and 102.33.

20. An agency has no inherent authority, but has only those powers granted

by statute. The principles applicable to an agency's authority to adopt rules

are equally applicable to an agency's authority to enter orders or take other

forms of agency action. Administrative regulations must be consistent with the

statutes under which they are promulgated, and they may not add to, amend or

repeal the statute, Department of Health and Rehabilitative Services v. The

Florida Psychiatric Society, Inc., et al., 382 So.2d 1280 (Fla. 1st DCA, 1980),

nor can an administrative rule enlarge, modify or contravene the provisions of a

statute. The Department of Health and Rehabilitative Services v. McTigue, 387

So.2d 454 (Fla. 1st DCA, 1980). Action which is directly repugnant to and

inconsistent with the federal regulations on the same subject clearly

contravenes the legislative delegation of authority to the Department to take

actions regarding the marking and labeling of citrus products. As such, the

challenged action exceeds the Department's statutory authority, and is unlawful

and invalid.

21. Even if there were no federal regulations concerning the labeling of

foods and diluted citrus juice products, the agency action in question does not

appear to be reasonably related to the purposes of the enabling legislation.

The purposes of the Citrus Code are to both protect and promote the citrus

industry and to protect consumers from fraud or other deceptive practices. The

petitioner in this proceeding has demonstrated that Citrus Hill, a Florida

producer, packager and distributor of Florida citrus products in Florida and

throughout the United States, would be severely disadvantaged economically and

competitively if it were not able to include the word "juice" or list the

percentage thereof, in its products containing less than 100 percent pure citrus

juice. The studies performed on behalf of the Department of Citrus indicated a

consumer preference for products containing "juice." No other state prohibits

the word "juice" from appearing on labels for diluted citrus fruit beverages.

The federal law on the subject, as discussed above, requires the word "juice" to

appear on the labels of diluted fruit juice beverages. By severely limiting the

competitive strength of national distributors operating out of Florida, the

challenged action does not "stabilize and protect the citrus industry of the

state" (Section 601.02(1)), nor does it "promote the general welfare of the

Florida citrus industry" (Section 601.02(6)). There was no evidence presented

by the Department that the availability of diluted citrus juice beverages in the

market place would adversely affect the sale of Florida citrus fruit.

22. A further purpose of the Citrus Code is the protection of consumers.

It is difficult to imagine how the listing of a beverage by the common name of

the fruit juice contained therein, together with a statement of the actual

percentage of such fruit juice contained therein, could be more informative,

truthful or accurate. Certainly, a label containing such information could not

be considered an "unscrupulous practice" or a "haphazard method of marketing."

See Section 601.02(5), Florida Statutes. The Department's position on this

subject requires the choosing of an arbitrary word other than "juice," such as

"drink," " ade" or "beverage," without denoting any attributes of the product.

This requirement does not accurately or completely describe the product offered

for sale and thus does not protect the public against fraud, deception or

financial loss. See Section 601.02(5), Florida Statutes. Indeed, where the

characterizing ingredient in a product is citrus juice, it would be false and

misleading to label the product as a "beverage," " ade" or "drink" without any

designation of its citrus "juice" content. By communicating less information to

consumers about the product offered for sale, the prohibition against the word

"juice" for diluted citrus fruit products frustrates the legislative purpose of

protecting consumers from unscrupulous practices, and bears no rational

relationship to any other statutory provision of the Florida Citrus Code.

23. Even if the Department or the State of Florida has some interest in

promoting products containing 100 percent pure Florida citrus juice (a fact not

proven at the hearing), it has no power to prohibit the manufacture or sale of

diluted juice products. It may not discourage the production and sale of

diluted products by requiring potentially misleading or non-descriptive labeling

or by requiring the labeling of a product in a manner which is inconsistent and

in conflict with federal regulations.

24. It is interesting to note that the banning of the word "juice" from

diluted citrus product labels conflicts with the remaining portions of Rule 20-

66.001. Subsection (1) of Rule 20-66.001 requires that all Florida processed

citrus products be labeled in compliance with established Florida standards and

any other applicable "Federal food labeling requirements or regulations.

Labeling may include any truthful and non-misleading qualifying adjectives."

Subsection (2) of Rule 20-66.001 provides that where no Florida standards have

been established, the label

" shall bear a factual and descriptive

product name and shall include a

statement in immediate conjunction

with the product name which fully and

truthfully describes the product and

its ingredients."

And, subsection (3) of Rule 20-66.004 requires that labels for unsweetened

single strength and concentrated citrus juices prominently show that the product

is 100 percent juice. To single out diluted citrus products for a different

manner of labeling which is not descriptive of the product or its ingredients

conflicts with the remaining portions of the rule and finds no statutory

support. In addition, any alleged "confusion" on the part of consumers should

be cured by the regulatory requirement set forth in Rule 20-66.001(3) that

single strength products be labeled "100 percent."

25. In summary, it is concluded that the Department's action of requiring

the petitioner to remove the word "juice" from its diluted citrus product

beverage labels conflicts with and exceeds the authority delegated to the

Department of Citrus by the legislature and bears no rational relationship to

the stated purposes for the enactment of the Florida Citrus Code, and is

therefore unlawful and invalid.

RECOMMENDATION

Based upon the findings of fact and conclusions of law recited herein, it

is RECOMMENDED that the Department of Citrus rescind its order or directive to

the petitioner to discontinue the use of the word "juice" in its labels for

diluted citrus juice beverages.

Respectfully submitted and entered this 9th day of December, 1987, in

Tallahassee, Florida.

_________________________________

DIANE D. TREMOR

Hearing Officer

Division of Administrative Hearings

The Oakland Building

2009 Apalachee Parkway

Tallahassee, Florida 32399-1550

[phone]

Filed with the Clerk of the

Division of Administrative Hearings

this 9th day of December, 1987.

ENDNOTE

1/ Apparently, enforcement of 21 C.F.R. Section 102.33 has been stayed by the

FDA, and the agency has requested comments on the rule.

APPENDIX TO RECOMMENDED ORDER, CASE NO. 87-1611

The proposed findings of fact submitted by both parties have been fully

considered and are included and/or incorporated herein, except as noted below:

Petitioner:

Many of the petitioner's proposed findings of fact constitute legal

conclusions or legal argument. As such, they have not been incorporated into

this Order's Findings of Fact, but have been considered or included in the

Conclusions of Law.

Respondent:

B. Rejected as contrary to the evidence.

C. Accepted with regard to the Department's intent, but rejected as to the

Rule's effect.

D. Rejected as contrary to the evidence.

COPIES FURNISHED:

Peter J. Winders and

James J. Kennedy, III

Carlton, Fields, Ward,

Emmanuel, Smith, Cutler & Kent, P.A.

One Harbor Place

Post Office Box 3239

Tampa, Florida 33601

Karl S. Steinmanis, Esquire

One Proctor and Gamble Plaza

Cincinnati, Ohio 45292-3315

J. Hardin Peterson, Jr., Esquire

Peterson, Myers, Craig, Crews,

Brandon & Mann, P.A.

Post Office Drawer BS

Lakeland, Florida 33802

Kristen C. Chadwell, Esquire

General Counsel

Department of Citrus

Post Office Box 148

Lakeland, Florida 33802-0148

Dan L. Gunter, Executive Director

Department of Citrus

Post Office Box 148

Lakeland, Florida 33802-0148

Liz Cloud, Chief

Bureau of Administrative Code

1802 The Capitol

Tallahassee, Florida 32399-0250

Carroll Webb, Executive Director

Administrative Procedures

Committee

120 Holland Building

Tallahassee, Florida 32399-1300