2004D-0065 - Guidance for Industry: Questions and Answers Regarding the Interim Final Rule on Prior Notice of Imported Food (Edition 2); Availability
FDA Comment Number : EC8
Submitter : Ms. Florence Gushue Date & Time: 06/10/2004 05:06:04
Organization : Ontario Commercial Fisheries' Association
Food Industry
Category :
Issue Areas/Comments
GENERAL
GENERAL
Great Lakes Freshwater fishing Industry

COMMENTS / RECOMMENDATIONS

1. When preparing paperwork for export. Prior Notices release numbers should only be required for the consolidated INWARD CARGO MANIFEST FOR VESSEL UNDER FIVE TONS, FERRY, TRAIN, CAR, VEHICLE, ETC, 19 cfr 123.4 123.7 123.61. Presently we are required to obtain prior notice numbers for each line on each Customer invoice that represents a different species, form etc. It could upward of a 100 plus prior notice release numbers required. It would be beneficial if prior notice is completed as per the above cfr document or for each product code on the truck.
REASONING: All products on one truck, one border crossing and all exporting Canadian fish companies have a recall program to locate product if problem.

2. Companies completing their own PN's versus a broker may be challenged to get the PN's back before the truck reaches the border. Time frames should be dropped to one hour from time receiving PN versus two hours.

3. When the quantity of a shipment of product changes after the Prior Notice has been sent and the PN release numbers have come back. Companies should be allowed to increase quantities within a reasonable amount, when that product has already been released. i.e. PN release received for 25 x 10 lbs Yellow perch fillets. If order comes in for addditional 10 x 10 lbs before truck leaves industry should be able to add that product to the truck.