2002N-0276 - Small Entity Compliance Guides on Registration of Food Facilities and Prior Notice of Imported Food; Availability
FDA Comment Number : EC355
Submitter : Mrs. HOPE CHEATLE Date & Time: 05/03/2004 05:05:01
Organization : HAROLD T. GRIFFIN INC.
Food Industry
Category :
Issue Areas/Comments
GENERAL
GENERAL
While we fully understand and support the reasons for prior notices, we are concerned about the time it takes to obtain same. We have U.S. vendors that will not supply their registration numbers (say they are confidential) and this makes it very difficult to obtain prior notices.

We are also very concerned when carriers choose arbitarily to cross at a different border crossing then first indicated. Courier companies such as FedEx, Purolator, UPS, etc. do not have experience/educated personnel to advise us of the correct information.

One last comment, having to have a prior notice for each SKU can and will cause an over abundance of work that will result in hiring people just to obtain prior notices or expense will be incurred if customs brokers have to be paid for doing same. One gentlemen in the seminar mentioned he could have as many as 400 SKU's on one truck and that means 400 different prior notices. At 1/2 hour average for one prior notice, this means 200 hours would have to be put in to obtain prior notices for a truckload shipment. It could take up to a month to do this with a person working continuously and having not interruptions or problems with the internet. There must be a simpler/faster/cost efficient way to handle these.

Thanks very much,

Hope Cheatle, CITT
Manager, Logistics
Harold T. Griffin Inc.