| 2002N-0278 - Prior Notice of Imported Food Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002; Reopening of Comment Period|
|FDA Comment Number :||EC476|
|Submitter :||Mr. Martin Rice||Date & Time:||05/17/2004 06:05:14|
|Organization :||Canadian Pork Council|
| The Canadian Pork Council (CPC) is pleased to have the opportunity to submit feedback to the FDA regarding Docket: 2002N-0278 - Prior Notice of Imported Food Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002. The following comments are being submitted specifically on behalf of one of CPCs members, the Ontario Pork Producers Marketing Board (OPPMB).
Martin T. Rice
1) Should food products subject to FDA's prior notice requirements be eligible for the full expedited processing and information transmission benefits allowed with C-TPAT and FAST? If so, how should this be accomplished?
More perishable food products and livestock subject to prior notice requirements should be eligible for the expedited processing and information transmission benefits offered through C-TPAT and FAST participation. However, the only way for this to be fairly accomplished will be for all food product hauling carriers to be involved in the C-TPAT and FAST programs so that all transporters are on a level playing field.
2) If the timeframe for submitting prior notice for food arriving by land via road is reduced to 1 hour, consistent with the timeframe in the CBP advance electronic rule, would a shorter timeframe be needed for members of FAST?
It is not certain a shorter timeframe is `needed? for FAST members but in theory, since it should take less time to process a FAST participant?s paperwork, less time may be required from the FDA?s end to review prior notice submissions from pre-screened importers, truck carriers and commercial drivers.
3) Should the security and verification processes in C-TPAT be modified in any way to handle food and animal feed shipments regulated by FDA? If so, how?
Yes, the security and verification processes in C-TPAT to handle food and animal feed shipments regulated by the FDA must be more comprehensive. OPPMB?s carriers haul livestock and there doesn?t appear to be any questions on the Supply Chain Security Profile Questionnaire to specify the type of freight being hauled. There are also no opportunities to indicate different locations a company?s regularly shipping to and insurance held to cover those states.
Should FDA offer a prior notice submission training program for submitters and transmitters, including brokers, to ensure the accuracy of the data being submitted?
Although OPPMB staff has been submitting prior notices since December 12th, 2003, it has never been communicated whether ample information is being provided to the FDA. A prior notice submission training program would prove beneficial in assuring that adequate/accurate information is being transmitted to meet regulation compliance.