| Comment Record|
Mr. Denny Morrow Morrow ||
2002-08-29 10:31:20 |
Nova Scotia Fish Packers Association |
Food Industry |
| Comments for FDA General |
1. General Comments
To Whom It May Concern:
I am writing on behalf of the 60 member companies in the Nova Scotia Fish Packers Association. Our member companies process and pack a wide variety of seafood products for Canadian domestic consumption and for export. The value of our exports during 2001 was in excess of $400 million. At least 70% of those exports went to the United States. Some of our member companies also import US seafood products for distribution in Canada.
We have a motto in the seafood business - Keep it clean, keep it cold, and keep it moving. During the month of December, we estimate that a daily average of a quarter million pounds of live lobster is trucked through the Calais, Maine border station. At other times of the year, fresh ground fish, tuna, swordfish, scallops, and clams are among the perisahable seafood items being shipped to buyers and distributors in the United States. The success of this trade is based on the seafood industry's ability to put products in retail stores and restaurants in the freshest possible condition.
Our members support the efforts of the U.S. government in taking measures to prevent acts of bio-terrorism (the intentional adulteration of food) against the American people. We understand the intent of the Prior Notice of Imported Food Shipments Section of the new Bio-terrorism Act is to provide USFDA with information that will assist USFDA inspectors at the various border points.
It is with concern that our members note that the Act specifies 8 hours as the default minimum time period for prior notification of a shipment coming to a border point like Calais, Maine.
The current reality is that shipments, often from two or three Nova Scotia lobster/fish companies, are put together in short order at the request of our American customers. These shipments are often finalized while the truck travels from one processor/shipper to another, and as the truck travels toward the Maine/New Brunswick border. From the initial partial loading at the first Nova Scotia plant to the arrival of the truck at the Calais border point, the elapsed time may amount to no more than 3 - 5 hours. For seafood exporters in New Brunswick, the time period may be as little as one to two hours.
Much of the product that is exported to the USA is fresh, or live, perishable seafood. Some of the shipments are headed for Boston or New York for air freight to Europe or Asia. Late shipments can result in missed flights, or lower prices from our American customers due to reduced freshness or increased mortalities of live product.
It is our hope that USFDA will be able to implement an electronic notification system that will require only two hours of prior notice to Canadian shippers so that our perishable seafood products can get to their U.S. destinations in the best possible condition. The electronic notification system should also be operating on a 24 hour/7 day week basis.
USFDA might also consider a system whereby perishable seafood shipments on trucks are allowed to continue to destinations like Portland, Boston or New York under the provision that the shipment can not be distributed until the Prior Notice information has been reviewed and processed by USFDA. In most cases, the additional truck travel time to the USA destination point would allow for the minimum eight hours.
One of the objectives of the terrorists on September 11 was likely to disrupt and hinder economic activity. The eight hours prior notice section of the Act, if implemented without consideration of the realities of U.S./Canada seafood trade, will have a negative impact on Canadian exporters and on our American customers who sell our products.
NSFPA members appreciate the invitation to provide comments on the new Act. We hope that the comments above prove helpful.
Nova Scotia Packers Association
38-B John Street
Yarmouth, Nova Scotia