Docket Management
Docket: 02N-0215 - Agency Info Collection; Proposed Collection; Comment Request; Export Certificates
Comment Number: EC -4

Accepted - Volume 1

Comment Record
Commentor Mrs. Sheila Planer Date/Time 2002-07-11 17:33:48
Organization DairiConcepts, L.P.
Category Food Industry

Comments for FDA General
1. Is the proposed collection of information necessary for the proper performance of FDA's functions? Will the information have practical utility? 1. Supporting documentation must be sent with each request for export documents. Much of this is redundant information and creates a paperwork overload. Also, each document must be notarized. 2. Providing lot numbers on certain documents creates a serious time issue with most export shipments, as this information is not available until the actual shipment occurs.
2. What is the accuracy of FDA's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used? Different State USDA offices require different information from the exporter to prepare the same document. There is also inconsistency in billing practices. All state USDA offices should be standardized to assist the exporter in meeting requirements.
3. What are ways to enhance the quality, utility, and clarity of the information to be collected? Keeping abreast of the custom requirements of all the importing countries is difficult. Guidelines should be published and updated for use by each USDA/FDA office issuing documents to ensure consistency within offices and agencies. The guidelines should include country specific requirements on animal control issues. The guidelines should also be available to the general exporting public as requirements change often.
4. What are ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques, when appropriate, and other forms of information technology? 1. Allowing one notarized affadavit to be held on file at the USDA offices where each exporter requests documents would allow exporters to file their requests electronically and would reduce paper overload. 2. If the requirement for lot numbers on each request for documents were eliminated, the request could occur earlier. Export documentation could be assembled earlier and ultimately make the import process easier for the end user.
5. General Comments Obtaining approval for exportation into the European Union is a difficult and innefficient process. It requires the efforts and time of two US agencies - USDA and FDA - and duplicate paperwork. Also, the process must be started several months prior to exportation due to significant delays at the European Commission. It creates an environment of constant re-examination in order to determine whether approval has been granted. There is no automatic notification system.

EC -4