Two commenters submitted written comments outside of discussions within advisory committees. This rule was recently amended to adopt the 2013 FDA Food Code by reference. The first comment was from Utah State University concerning the requirement in the 2013 FDA Food Code stating that "at least one employee?shall be a certified food protection manager?through passing a test that is part of an accredited program". An accredited program, as defined in the 2013 FDA Food Code, is an agency which conforms to national standards. The commenter was worried that those food safety manager certification providers in Utah approved by UDOH (Rule R392-101) would no longer be valid if UDOH was not an approved provider. The second commenter was Davis County Health Department (DCHD), which submitted two comments. DCHD was concerned over "non-debitable" items in the 2013 FDA Food Code being adopted. DCHD was concerned over the requirement for all food establishments to have a pre-opening inspection before beginning operations, which would include all temporary events. This could become overly burdensome to regulators and operators alike.