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 : EC400
Submitter : Mr. Donald Werden Date & Time: 05/03/2004 05:05:21
Organization : The Norfolk Fruit Growers' Association
Private Industry
Category :
Issue Areas/Comments
Prior Notice requirements have added a great deal of extra work to prepare loads for export to the USA and for loads going through the USA on a T&E bond. Needing a separate Prior Notice for each package size and each consignee can mean a very large number of Prior Notices. For our firm the number of notices needed multiplies the amount of time required to prepare the paperwork.

We pack and ship apples to many countries of the world. When we pack we get 2 or 3 grades and maybe 16 package sizes from each bin. The apples are all the same except for size and grade.

If one commodity was allowed on each Prior Notice it would save alot of time or even only 1 Prior Notice for each FDA code would save time. At the current time we could have over 10 different packages with all the same FDA code on the same truck. The only difference being the size of the apples in the box. If the load has 10 sizes of apples and all the same FDA code, one Prior notice could cover the whole load and give the same information as all 10 Prior Notices.