The FDA is explicitly authorized to rely on inspections of other Federal, State and local agencies to meet its increased inspection mandate for domestic facilities. The FSMA also allows the FDA to enter into inter-agency agreements to leverage resources with respect to the inspection of seafood facilities, both domestic and foreign, as well as seafood imports. Employee protections The FSMA also includes provisions that protect employees who try to prevent food safety problems. Section 402 of the FSMA prohibits employers engaged in the manufacture, processing, packing, transporting, distribution, reception, holding or importation of food from retaliating against employees who disclose violations of the Federal Food, Drug, and Cosmetic Act. This particular portion of the FSMA is administered by the U.S. Department of Labor. Implementation With the Act in place, the FDA began the rulemaking process to codify how to enforce the new laws. Effective June 12, 2011, many food companies became required to develop food safety plans based on an evaluation of hazards related to food manufactured, processed, packed or held in all registered facilities. Following a hazard analysis, firms were required to identify and implement preventive controls to significantly minimize or prevent the occurrence of such hazards. Examples of preventive controls include sanitation procedures for food contact surfaces; employee hygiene training; environmental monitoring to verify pathogen controls; a recall plan; supplier verification activities; and a food allergen control program. Even after completion of the rulemaking process, it was estimated that time would be required for the FDA to become fully equipped to enforce the new laws. The agency estimated that it would require at least 1,000 more inspectors and $1.4 billion over the following five years, with uncertainty that Congress would appropriate such funds given the economic climate at the time, and calls for spending cuts. Rules In 2012, the FDA was sued by consumer groups the Center for Food Safety (CFS) and the Center for Environmental Health for its failure to meet deadlines. In settling the litigation, the agency agreed to deadlines in 2015 and 2016 for certain rules. The first public comment period occurred in 2013, and the agency received tens of thousands of comments in that period. The FDA previously submitted their proposed regulations to the Office of Management and Budget (OMB) for review, and in that process the OMB weakened the regulations in a variety of ways. FSMA progress report The FDA has planned to