RULES AND REGULATIONS
MILK MARKETING BOARD
[ 7 PA. CODE CH. 143 ]
Transactions Between Dealers and Producers; Termination of Dealer—Producer Contract
[51 Pa.B. 4223]
[Saturday, July 31, 2021]
The Milk Marketing Board (Board) amends §§ 143.31 and 143.33 (relating to written notice required; and individual variations) and deletes § 143.32 to read as set forth in Annex A.
The amendments will be effective upon publication of this final-form rulemaking in the Pennsylvania Bulletin.
Section 301 of the Milk Marketing Law (act) (31 P.S. § 700j-301) gives the Board the authority to ''supervise, investigate and regulate the entire milk industry of this Commonwealth, including the. . . purchase and sale of milk. . .in this Commonwealth, and including the establishment of reasonable trade practices. . . .'' Section 307 of the act (31 P.S. § 700j-307) gives the Board the authority to adopt and enforce regulations necessary or appropriate to carry out the provisions of the act.
Purpose and Explanation
This is an amendment extending the current 28-day notice requirement to terminate a dealer-producer relationship to 90 days. It also provides for waivers to address situations where a 90-day notice would financially imperil a milk dealer.
At the beginning of March 2018 approximately 27 independent dairy farmers in this Commonwealth received termination notices from the milk dealer purchasing their milk. These producers received 90 days' notice that their agreements would be terminated, yet many had difficulty finding new markets. One purpose of the amendment is to provide additional time for dairy farmers to find an alternative market when they lose their current market.
In the case of the 27 producers that received notices in March 2018, their dealer could not, from a financial and economic standpoint, continue to purchase their milk. The exceptions to the 90-day notice requirement in the amendment are intended to provide a shorter notice period in the case of a dealer's financial hardship, business loss or catastrophic event. The exceptions also provide for a dealer to make a charitable donation of packaged milk and maintain its purchasing agreement with a producer.
The amendment is intended to provide additional time to producers in a manner that minimizes adverse impact on milk dealers.
Description of Proposed Amendments
Section 143.31(a) is amended to increase the required notice period for dealers to terminate a dealer-producer purchasing agreement from 28 days to 90 days. Carried over from the current regulation is the requirement that dealers provide the reasons for termination in the notice; providing the reasons for termination provides producers an opportunity to correct any issues under their control as they attempt to find a new market for their milk.
The proposed version of subsection (a) also required producers to give 90 days' notice to terminate a dealer-producer relationship. This requirement has been removed from this final-form rulemaking. As evidenced by past milk marketing conditions, and due to current and foreseeable milk marketing conditions, 28 days is sufficient time for a dealer to acquire any milk necessary to make up for the loss of a producer or producers.
The payment provision is also carried forward in a modified manner to account for the extended notice period. The time period provides that producers who may be searching for a new milk market receive income as they search.
Subsection (c) is added to provide an exception to the 90-day notice requirement for dealers in ''financial distress.'' Financial distress is determined objectively by calculating the dealer's Ohlson O-Score. The O-Score was developed in the 1980s using financial information from over 2,000 companies. It is generally considered to be more accurate than its predecessor, the Altman Z-Score, which was developed in the 1960s using information from just 66 companies. The O-Score was selected as the primary objective metric for determination of dealer financial distress because of its reliability (consistent results over time) and validity (accurate results over time) in financial accounting since 1980. It is a result of a 9-factor linear combination of business-related ratios readily obtained through milk dealer financial statements currently filed with the Board by milk dealers on an annual basis. The O-Score is significantly more reliable than its predecessors as it was derived from a study of over 2,000 companies; it has over 90% accuracy. The O-Score provides an accurate determination of dealer financial distress to be used in a review of dealer applications for waiver of the 90-day producer termination notice requirement.
''Necessary documentation'' is defined in the regulation and includes reports already filed annually with the Board. ''Necessary documentation'' is the Balance Sheet and Statement of Operations found in the Milk Dealer's Financial Statement (PMMB-60), and the Statement of Cash Flows which is prepared annually with a dealer's financial statements.
Subsection (d) is added as an objective backup to address cases of potential dealer financial distress that are not captured in the O-Score.
Subsection (e) is added to provide an exception to the 90-day notice requirement for dealers not in financial distress but which lose customers or sales, or both, resulting in potential financial distress if required to continue to make producer purchases for which there is no customer for the packaged milk.
Subsection (f) was included in the proposed form to provide an opportunity for milk dealers with producer milk purchase obligations in excess of customer sales to make a charitable donation of the associated excess packaged milk rather than to terminate producers. This section was not intended to limit or affect other charitable contributions that milk dealers make. As the Board drafted this final-form rulemaking it decided that charitable-related contributions should be addressed in the context of a complete review of charitable contributions. The Board concluded that this final-form rulemaking is not the place to undertake such a review and has deleted this section from this final-form rulemaking.
Subsection (g) is added to provide an exception to the 90-day notice requirement when a dealer suffers a sudden and large scale (''catastrophic'') event affecting its ability to handle, process or sell/deliver packaged milk products.
Subsection (h) is added to clarify when the exceptional 28-day notice requirement begins.
Subsections (i) and (k) are added to clarify that the notice period does not apply when contracts between dairy farmers and their cooperatives, and producers and dealers, respectively provide for a different notice requirement.
Proposed subsection (k), now subsection (j), is added because a common issue raised by producers who received termination notices in March 2018 was that they did not know who to contact for assistance. The Board will develop through industry contacts a list of government agencies and non-governmental organizations that provide services and assistance to address issues faced by producers who are losing a market and who want to find a new market. Dealers will be able to download the list from the Board's web site to include with termination notices. Any person, including producers, will be able to independently access the list as well.
Section 143.32 is deleted. As milk marketing conditions have changed and evolved, and continue to change and evolve, there is a likelihood that a producer may be selling some of its milk to a dealer while also processing, packaging and selling its own milk at its farm. At one time, exempting those producers from receiving notice may have been appropriate, but the Board has determined that current conditions are such that these producers should receive the same notice as other producers.
The Board received comments from the Pennsylvania Association of Milk Dealers (PAMD) and the Independent Regulatory Review Commission (IRRC).
The Board deleted two provisions in this final-form rulemaking. First, the Board deleted the requirement that producers provide a 90-day notice to dealers when producers want to terminate a contract. The Board deleted this provision for two main reasons: (1) no party requested this provision; and (2) milk marketing conditions are, have been and are anticipated to continue to be such that dealers can replace producer milk in 28 days or less if a producer terminates its contract with a dealer. Second, the Board removed § 143.31(f) regarding charitable donations. The Board concluded that charitable donations should be addressed in a separate regulation. The Board concluded that keeping regulations involving charitable donations together in one regulation is more logical and would be best for the industry, as opposed to requiring the regulated community to search for regulations related to charitable donations throughout the Pennsylvania Code. Comments regarding the 90-day producer notice and subsection (f) related to charitable donations will not be further addressed.
Based on comments from IRRC and PAMD the Board provided additional detail in the Regulatory Analysis Form (RAF) and made changes to Annex A.
Regarding § 143.31(a), based on IRRC comments, the Board clarified that payment from dealers to producers would be due by the 20th day of the month following actual termination; this would essentially mirror the provision in the existing regulation and there was no request to change it. Similarly, the Board carried forward the requirement in the current regulation that dealers provide reasons to producers when producers are terminated. No change to this provision was requested, and it has been used and followed by dealers since 1978 with no issue.
The Board added additional detail to the RAF regarding the definition of ''necessary documentation'' in subsection (c). ''Necessary documentation'' is defined in the regulation and consists of items already filed each year with the Board by dealers. In developing the regulation, the Board attempted to minimize any additional requirements for dealers. Based on IRRC comments, the Board added detail regarding notification requirements to the regulation and described those additions in the RAF. The regulation maintains the existing 28-day notice requirement for dealers to terminate a contract in cases of financial hardship as determined by the objective measures found in the regulation.
The Board added detail to the RAF regarding the requirements of subsection (k), now subsection (j). When producers are terminated, they have many questions and concerns. The Board added this section to ensure that producers received information regarding resources to assist them with their questions and concerns when they receive a termination notice from a dealer. The information will be available on the Board's web site at mmb.pa.gov at any time for any interested individual to download.
PAMD commented, and IRRC suggested the Board address, that the proposal to enlarge the notice period from 28 days to 90 days exceeds the Board's authority. PAMD based its comment on section 404(1) of the Milk Marketing Law (31 P.S. § 700j-404(1)). As the Board interprets section 404(1), that section is expressly not applicable to a milk dealer terminating a contract; inclusion in section 404(1) of the phrase ''. . .except where the contract has been lawfully terminated. . .'' establishes that.
Section 404(1) applies to situations where a dealer rejects ''without either reasonable cause, or reasonable advance notice, milk delivered or made available. . .in ordinary continuance of a previous course of dealing, except where the contract has been lawfully terminated[.]'' Section 404(1) defines ''reasonable advance notice'' as not less than 14 days nor more than 45 days in the absence of an express or implied term in the contract specifying a longer period. However, section 404(1) does not provide a definition of ''lawfully terminated'' or ''reasonable cause.'' The legislature, by including the phrase ''except where the contract has been lawfully terminated'' left it to the Board's discretion to adopt regulations regarding the lawful termination of a contract, just as the legislature left to the Board's discretion to adopt regulations regarding ''reasonable cause'' to reject producer milk.
The legislature expressly provided a standard for reasonable advance notice to reject producer milk. If the legislature had meant that reasonable notice standard to apply to lawfully terminating a contract, the legislature would have either expressly said so, or not included in section 404(1) the phrase ''except where the contract has been lawfully terminated.'' Therefore, the Board adopted § 143.31 to provide direction regarding the notice period required to terminate a contract. Similarly, the Board adopted § 143.44 to provide direction regarding reasonable cause to reject producer milk. The milk marketing conditions that were present in 1978 when the Board adopted existing § 143.31 have changed. Therefore, the Board has concluded that it is necessary to amend § 143.31 to recognize those changed conditions and provide for a 90-day notice period for a dealer to terminate a dealer-producer relationship.
Based on IRRC and PAMD comments, the Board clarified that any notice required by the regulation to be given by dealers to producers shall be made by certified mail return receipt requested and filed simultaneously with the Board. This clarification is important and necessary because the period of notice begins when a producer receives the notice. The notice period begins on the date of delivery, or the date of first attempted delivery, whichever is earlier. PAMD also suggested that provision be made for hand delivery or express delivery. To maintain consistency and reduce potential for confusion regarding effective dates of notice, the Board is not providing for hand delivery or express delivery in this final-form rulemaking.
IRRC commented that the Board should explain the reasonableness of the 10-business day period to perform the analyses required in subsections (c), (e) and (f). The 10-business day period was chosen to account for the possibility that the two employees who would perform the analysis would be on vacation or otherwise unable to complete the analysis more quickly. As of the drafting of this preamble the Board has a total of 15 employees and there are no opportunities to cross-train additional employees to perform the analysis. The Board also anticipates that dealers contemplating terminating producers under an exception to the 90-day notice requirement will be in contact with the Board for a sufficient time prior to petitioning for an exception to plan for the unlikely, but potential unavailability of the Board employees who would perform the analysis. In practice the analysis and notice of approval/disapproval from the Board to the dealer and producers should take less than five business days.
IRRC suggested that the regulation be revised to explicitly provide for dealer notice under subsections (c), (d), (e) and (f). IRRC also suggested that the regulation be revised to explicitly provide that the Board would notify dealers and affected producers of its decision under those sections. These changes were made to this final-form rulemaking submission.
IRRC asked if a plant shut down or slow down should be considered ''catastrophic'' in the same category as a massive fire or tornado damage and whether it would be more appropriate to include such an event as a separate exception to the notice requirement. The Board relied on the definition of ''catastrophic'' found in Google's English dictionary as provided by Oxford Languages (https://www.google.com/search?q=catastrophic+definition) as ''involving a sudden and large-scale alteration in state.'' A sudden plant shut down or slow down would thus be ''catastrophic'' and it is not possible to define every circumstance that may lead to a sudden shut down or slow down. Since it is not possible to define every circumstance that may lead to a sudden shut down or slow down, the Board concluded that a separate exception would not be appropriate.
IRRC also suggested that the Board take into account the Federal Worker Adjustment and Retraining Notification (WARN) Act (29 U.S.C.A. §§ 2101—2109) when it prepared this final-form rulemaking. Producers do not fall within the criteria of the WARN Act.
IRRC and PAMD commented that subsection (h), now subsection (g) in this final-form rulemaking, could potentially have the effect of turning a 28-day notification period into a 43-day notification period. The Board understands this possibility and its impact on dealers. The Board has weighed the potential effects on dealers and producers. Given the nature of milk markets and the difficulty producers can have finding new markets, the nature of the producer-dealer relationship and the relative general financial conditions of producers and dealers, the Board concluded that the 28-day notice should begin upon the Board's approval of the request for exemption from the 90-day requirement. The Board also considered, and took into account, that Board staff would in most cases complete its analysis and notify affected dealers and producers in less than 10 business days of its decision on an exemption petition. The required analysis can be completed by one Board employee; only in cases where both Board employees qualified to perform the analysis are not able to due to vacation, illness, and the like, will the analysis potentially take longer than 5 business days.
In determining the fiscal impact, the Board has noted that the costs associated with purchasing milk are different for each dealer and are based on many factors, such as utilization, location, monthly milk price, and volume purchased. In the RAF, the Board determines the fiscal impact based on the January 2021 simple average of minimum value due from 15 Class I processing dealers to producers. January 2021 was chosen because it is the most recent month for which the Board has audited data. The Board uses a simple average because weighting the average based on any factor would potentially materially mis-state the illustrative amount due from any dealer by mis-weighting any particular factor as it applies to any specific dealer. This regulation will basically apply only to Class I processors and their independent producers and the 15 Class I processing dealers that comprise the cross-section are used for this example purchase the majority of independent producer milk.
IRRC suggested that the Board clarify where the subsection (k), now subsection (j), list of resources to be provided by dealers with termination notices could be found. The Board will maintain this list on its web site, as provided in this final-form rulemaking. This final-form rulemaking is also changed based on IRRC's suggestion to refer to this list in subsection (a).
Based on an IRRC comment the ''='' before ''0.285Y'' in subsection (c) was changed to a ''+.''
Based on an IRRC comment § 143.32 is now marked ''(Reserved),'' instead of being bracketed, to denote its deletion.
Based on an IRRC comment the Board included in this final-form rulemaking a change to § 143.33 to remove the reference to deleted § 143.32.
Based on an IRRC comment the phrase ''include, but not limited to'' has been changed to ''including'' in § 143.31(f)(1).
The proposed amendments will have little fiscal impact on the Commonwealth, its political subdivisions or the public.
Exceptions to the amended 90-day notice requirement that would allow milk dealers to essentially provide the current 28-day notice requirement would not be effective for up to 10 business days after a dealer requests the exception. Therefore, there is the possibility that a dealer may be required to purchase producer milk for up to 10 business days longer under the amendment than dealers are currently required. The cost associated with purchasing milk is different for each dealer and is based on many factors, including, but not limited to, utilization, location, monthly milk price and volume purchased. Given the uncertainties, a precise quantification of this impact is not possible, but at a minimum could be as much as $14,000.
Under section 5(a) of the Regulatory Review Act (71 P.S. § 745.5(a)), on July 1, 2019, the Board submitted a copy of the notice of proposed rulemaking, published at 49 Pa.B. 3606 (July 13, 2019) to IRRC and to the Chairs of the House and Senate Committees on Agriculture and Rural Affairs for review and comment.
Under section 5(c) of the Regulatory Review Act, the Board is required to submit to IRRC and the House and Senate Committees copies of comments received during the public comment period, as well as other documents when requested. In preparing the final-form rulemaking, the Board has considered all comments from IRRC and the public.
Under section 5.1(j.2) of the Regulatory Review Act (71 P.S. § 745.5(a)(j.2)), on June 16, 2021, this final-form rulemaking was deemed approved by the House and Senate Committees. Under section 5.1(e) of the Regulatory Review Act, IRRC met on June 17, 2021, and approved this final-form rulemaking.
Interested persons may obtain information regarding this final-form rulemaking by contacting Doug Eberly, Chief Counsel, Milk Marketing Board, 2301 North Cameron Street, Harrisburg, PA 17110, email@example.com, within 30 days after publication in the Pennsylvania Bulletin. Individuals who require this information in a different format may call the Board at (717) 787-4194 or the Pennsylvania Hamilton Relay Service for TDD Users at (800) 654-5984.
The Board finds that:
(1) Public notice of the intention to adopt these final-form regulations was given under sections 201 and 202 of the act of July 31, 1968 (P.L. 769, No. 240) (45 P.S. §§ 1201 and 1202), known as the Commonwealth Documents Law, and the regulations promulgated thereunder in 1 Pa. Code §§ 7.1 and 7.2 (relating to notice of proposed rulemaking required; and adoption of regulations).
(2) A public comment period was provided as required by law and all comments were considered.
(3) The regulation is necessary and appropriate for the administration of the act.
The Board, acting under authorizing statute, orders that:
(a) The regulations of the Board, 7 Pa. Code Chapter 143, are amended by amending §§ 143.31 and 143.33 and deleting § 143.32 to read as set forth in Annex A.
(b) The Board will submit this order and Annex A to the Office of Attorney General for review and approval as to legality and form as required by law.
(c) The Board shall certify this order and Annex A and deposit them with the Legislative Reference Bureau as required by law.
(d) The order shall take effect upon publication in the Pennsylvania Bulletin.
ROBERT N. BARLEY,
(Editor's Note: See 51 Pa.B. 3680 (July 3, 2021) for IRRC's approval order.)
Fiscal Note: Fiscal Note 47-18 remains valid for the final adoption of the subject regulations.
TITLE 7. AGRICULTURE
PART VI. MILK MARKETING BOARD
CHAPTER 143. TRANSACTIONS BETWEEN DEALERS AND PRODUCERS
TERMINATION OF DEALER—PRODUCER CONTRACT
§ 143.31. Written notice required.
(a) No dealer shall terminate its contract or purchasing agreement or ordinary continuance of a previous course of dealing with a producer except by giving such producer at least a 90-day written notice before termination. No producer shall terminate its contract or purchasing agreement or ordinary continuance of a previous course of dealing with a dealer except by giving such dealer at least a 28-day written notice before termination. The period of notice shall begin when the producer or dealer receives the notice. The dealer shall specify in such notice the reasons for termination, shall include the list of agencies and organizations required by section (j), and shall pay in full the producer whose contract has been terminated by the 20th day of the month following actual termination. If a dealer petitions for a shorter notice period under subsections (c), (d), (e) and (f), the notice to the producer must inform the producer that the dealer is petitioning for the shorter notice period, this notice must be provided simultaneously to the Board, and this notice shall be sent by certified mail return receipt requested to affected producers and the Board with notice effective no later than on the first date of attempted delivery. If a dealer petitions for a shorter notice period under subsections (c), (d), (e) or (f), the Board shall notify the dealer and affected producers by certified mail return receipt requested within 10 business days of receiving from the dealer the information required by the respective clause its decision to either approve or disapprove the petition.
(b) Repetitions of the causes set forth in § 143.44 (relating to rejection of producer's milk) may, however, cause termination of the contract without the requisite notice.
(c) A dealer may terminate a contract or purchasing agreement or ordinary continuance of a previous course of dealing with a producer by giving a 28-day written notice if the dealer is in financial distress. ''Financial distress'' means an Ohlson O-score of 0.5 and higher. The dealer's Ohlson O-score shall be calculated as follows:
O = −1.32 − 0.407log(TAt/GNP) + 6.03TLt/TAt − 1.43 WCt/ TAt + 0.0757 CLt/CAt − 1.72X − 2.37NIt/TAt − 1.83FFOt/TLt = + 0.285Y − 0.521 (NIt−NIt|m-1)/(¦NIt¦ + ¦NIt|m-1¦)
TA = total assets
GNP = Gross National Product price index level found at (https://fred.stlouisfed.org/series/A001RG3A086NBEA)
TL = total liabilities
WC = working capital = (current assets) − (current liabilities)
CL = current liabilities
CA = current assets
X = 1 if TL > TA, 0 otherwise
NI = net income after taxes
FFO = cash flow from operating activities
Y = 1 if a net loss for the last 2 years, 0 otherwise
t = most recent year data
t−1 = prior year data
The Board shall complete its computation and review of the Ohlson O-score, and notify the dealer and affected producers, within 10 business days of receiving the necessary documentation from a dealer. ''Necessary documentation'' is the Balance Sheet and Statement of Operations found in the Milk Dealer's Financial Statement (PMMB-60), and the Statement of Cash Flows prepared annually with the dealer's financial statements.
(d) A dealer may terminate a contract or purchasing agreement or ordinary continuance of a previous course of dealing with a producer by giving a 28-day written notice if the dealer's Ohlson O-score is between −1.0 and 0.5 if any three of the following five solvency ratio conditions are met:
(1) Quick ratio less than or equal to 0.6, where quick ratio = (cash on hand + accounts receivable)/current liabilities.
(2) Current ratio less than 1.0, where current ratio = current assets/current liabilities.
(3) Current liabilities/total equity greater than 2/3.
(4) Total liabilities/total equity greater than 1.0.
(5) Fixed assets/total equity greater than 3/4.
(e) A dealer may terminate a contract or purchasing agreement or ordinary continuance of a previous course of dealing with a producer by giving a 28-day written notice if the dealer has raw milk volumes for which there are insufficient customer sales. Raw milk volumes for which there are insufficient customer sales shall be determined as follows:
(1) Identify sales reductions or customer losses experienced within any 90-day rolling period.
(2) Document weekly average sales history in pounds for the customer(s) decreased volume or for the lost customer(s) based on a 26-week rolling average, or a lesser time period if such customer was a customer for less than 26 weeks or was a school(s) and the school contract was lost during the school year.
(3) Affirm that good faith efforts were made to replace the lost sales.
(4) If the lost sales calculated according to paragraph (2) amount to at least 40,000 pounds or 3% of raw milk receipts, whichever is less, of raw milk per week and the dealer has made the affirmation required by paragraph (3), the Board shall approve the 28 day written notice based on the dealer having raw milk volumes for which there are insufficient customer sales.
(5) The Board shall determine if a dealer has raw milk volumes for which there are insufficient customer sales, and notify the dealer and affected producers, within 10 business days of receiving the necessary documentation from a dealer.
(f) A dealer may terminate a contract or purchasing agreement or ordinary continuance of a previous course of dealing with a producer by giving a 28-day notice if the dealer has raw milk volumes for which there is insufficient plant output due to a verifiable catastrophic event affecting a milk plant's ability to handle, process or sell/deliver historical volumes of packaged milk products, which is reasonably expected to last beyond 28-days. Raw milk volumes for which there is insufficient plant output shall be determined as follows:
(1) Identify catastrophic event to including mechanical failure; weather-related damage; infrastructure-related damage; shut down or slow down of plant operations; government-imposed plant shutdown, partial or otherwise; or other similar catastrophic circumstance.
(2) Document weekly average plant output as measured by sales in pounds of packaged milk products prior to catastrophic event based on a 26-week rolling average.
(3) Document weekly average raw milk receipts in pounds prior to catastrophic event based on a 26-week rolling average.
(4) Document reasons, nature and extent (estimated in pounds) of reduced ability to handle, process or sell/deliver historical output of packaged milk products.
(5) Affirm that good faith efforts have been made to return to historical plant output documented under paragraph (2).
(6) Affirm that despite good faith efforts the reduction in output will last beyond 28-days.
(7) If the reduction in plant output documented in paragraph (4) amounts to at least 40,000 pounds or 3% of historical raw milk receipts in paragraph (3), whichever is less, of raw milk per week and the dealer has made the affirmations required in paragraphs (5) and (6), the Board shall approve the 28-day written notice based on the dealer having raw milk volumes for which there is insufficient plant capacity due to a catastrophic event.
(8) The Board shall determine if a dealer has raw milk volumes for which there is insufficient output due to catastrophic event and notify the dealer and affected producers within 10 business days of receiving the information required by this subsection.
(g) Any 28-day notice period as provided by this section shall commence on the day the 28-day notice is approved by the Board.
(h) If a contract between a cooperative and a member of the cooperative provides for the amount of notice required to terminate the contract, this section shall not apply.
(i) Notwithstanding subsection (a), a producer and dealer may contract for either more or less than a 90-day notice period to terminate a contract or purchasing agreement. Subsection (a) shall apply when the contract, purchasing agreement or ordinary continuance of a previous course of dealing between a producer and dealer does not contain a termination provision.
(j) The Board shall maintain and make available on its web site a current list of government agencies and nonprofit organizations which are available to assist producers who receive a termination notice. The termination notice shall not be considered received by the producer unless it includes this list.
§ 143.32. (Reserved).
§ 143.33. Individual variations.
Nothing in § 143.31 (relating to written notice required) shall prohibit a contract or agreement providingfor a longer period of notice, or severing a relation between dealer and producer by mutual agreement on shorter period of notice.
[Pa.B. Doc. No. 21-1224. Filed for public inspection July 30, 2021, 9:00 a.m.]
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