pronouncement must “(1) prescribe substantive rules — not interpretive rules, general statements of policy or rules of agency organization, procedure or practice —and, (2) conform to certain procedural requirements.” Id. at 698 (emphasis in original). To satisfy the first requirement the rule must be legislative in nature, affecting individual rights and obligations; to satisfy the second, it must have been promulgated pursuant to a specific statutory grant of authority and in conformance with the procedural requirements imposed by Congress. Id. Clearly, this internal procedure for alerting Customs officers to possible infringements of 19 U.S.C. § 1527 was not intended as a substantive rule, and was not entitled to the force and effect of law against the government. See id. at 698-99 (<HOLDING>) Appellant cites Morton v. Ruiz, 415 U.S. 199,
holding that the court reviews noncompliance with an agency pronouncement only if it actually has the force and effect of law holding that va lenders handbook and va circulars do not have the force and effect of the law holding that the trademark manual of examining procedure tmep does not have the force and effect of law holding that district courts could consider ftca claims alleging negligence against va doctors because it would not have any effect on benefits holding federal regulations have the force of law and may create enforceable rights