| 2002N-0278 - Small Entity Compliance Guides on Registration of Food Facilities and Prior Notice of Imported Food; Availability|
|FDA Comment Number :||EC395|
|Submitter :||Mr. Sheldon Novak||Date & Time:||05/03/2004 05:05:34|
|Organization :||Payne Transportation Inc|
| With the prior notification, FDA removed the ability of shippers to use the BRASS/Line Release system. By now having a truck driver stop at the customs brokers' office to manually clear a load for entry into the US the time that is lost has greatly increased.
The PAPS system (Pre Arrival Processing System) has been designed to replace Line Release, but the main problem is that whereas Line Release was a shipper generated number, PAPS is carrier based. Therefore, the shipper usually does not have the PAPS number available before the prior notification is sent to the customs broker to complete and send to FDA. When the driver arrives to load, he is usually not allowed to fax the customs invoice with the PAPS sticker to the broker as the broker is unable to marry up the PAPS sticker to the previous FDA prior notification without generating a second prior notification or causing other errors.
If the system could be ammended where a PAPS number could be added after the fact, but before the truck arrives at the border, this would greatly decrease a trucks waiting time at the border and aid in quickly clearing trucks through customs.
From preliminary examination of the CBP Advance Manifest Notification coming into effect later this year, it looks as if PAPS will be almost required for most loads. If FDA and CBP are going to align their systems, this would be a good place to start.