2003D-0545 - Guidance for Industry: Questions and Answers Regarding the Interim Final Rule on Registration of Food Facility (Edition 3); Availability
FDA Comment Number : EC8
Submitter : Mr. Stephen Ward Date & Time: 04/19/2004 03:04:56
Organization : Seawind Trading International
Category :
Issue Areas/Comments
I submitted a two part commentary on an idea for security to our port system. The first part of my commentary was send before I was able to proof read and copy it.

I wanted to provide my name and phone in case anyone from the FDA or U.S. customs had an interest in further discussing this plan.

Stephen Ward
Seawind Trading International

My company is an International Import company that has arranged for shipment and distribution of food products in the U.S. and other parts of the world for almost two decades.

We currently have a food processing plant in the Peoples Republic of China. We are also active in imports from Thailand, Sri Lanka, and Europe.

Our company experience in International trade has heightened our awarness of the vulnerability of our Port System. We strongly beleive that the volume of daily vessels and containers arriving to our Ports, is currently the most vulnerable aspect of our country.

The program that we have thought through and researched is viable, but will most certainly require hard decisions, and strong administrative support.

A program of voluntary acceptance and alignment is not realistic for a country at war. It is my opinion that we must act swiftly to detour a weakness in our ports security and the economic out fall, that a single terrorist act would bring.

A combination of on the ground physical inspections, joined with electroinc tracking will empower our customs agents to know what is headed to our ports.

The largest error we could make in regards to the ports is to enact a program to effect shipments upon arrival to the ports. We must stem the potential threat before the goods arrive, not afterwards.

I applaud the administrations efforts to address the port system. I do beleive that time is of the essence and that we must take affirmative action to avoid the incredible impact a disaster at any of our ports could do to our economy and security.


Stephen Ward
Seawind International

Office: 760) 438-5600
Home: 760) 720-1800