2002N-0276 - Registration of Food Facilities Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002; Reopening of Comment Period
FDA Comment Number : EC356
Submitter : Mr. John Hiles Date & Time: 05/03/2004 05:05:32
Organization : UniGroup Worldwide UTS
International Industry
Category :
Issue Areas/Comments
UniGroup Worldwide UTS is an international provider of transportation for used personal household customers. Many of our customers wish to bring small quantities of foods such as canned goods, spices and other types of consumable items in small quantities that were in their possession prior to preparing to move to the USA. In addition, these same customers wish to bring small quantities of wine and other alcoholic beverages in their household goods shipments for their personal consumption. The manner in which the BTA of 2002 is currently written and manner in which prior notice is prepared and submitted is time consuming, not user friendly, and prohibitively difficult to complete. We have tried to prepare prior notices on-line as recommended in the FDA website only to find the process to be prohibitively time consuming for both our personnel and the customer. We have found contradictory guidance in the Federal Register, the FDA website and personnel at FDA and USC&BP offices. This has resulted in guidance being given to our customers to not pack food or consumables in their shipments. While other moving companies and packing companies have ignored these requirements, we are loosing customers to these competitors.

An alternative must be found for private citizens who wish to ship small quantities of consumables with their private property for their own consumption. The provisions of the BTA of 2002 were not targeted at this population, however the time, effort and paper required to complete these requirements violates the intents of other US Government Regulations.