2002N-0278 - Prior Notice of Imported Food Under the Publich Health Security and Bioterrorism Preparedness and Response Act of 2002; Notice of Availability of Joint FDA-CBP Plan for Increasing Integration and Assessing the Coordination of Prior Notice Timeframes
FDA Comment Number : EC443
Submitter : Mrs. Patrice Summer Date & Time: 05/17/2004 06:05:20
Organization : Global Trading Resources, Inc.
Category : Individual Consumer
Issue Areas/Comments
I am the President of Global Trading Resources, Inc. an independantly owned and operated Customshouse Brokerage and Freight Forwarding company. Though we are realtively small, we handle a number of commercial and household shipments that currently require prior notice to be filed. I have followed the process of ruled making from the beginning and my company has made enourmous efforts to make sure we are in compliance with all requirements and have educated our clients as well.

I am very disturbed by the recent publication by FDA that 50% of the prior notices received by FDA are either incorrect or incomplete and that we have had absolutely no feed back from the agency on what mistakes or omissions are being made. We don't know if it is failure to provide information by our staff, technical errors, problems with our software or problems on transmission between CBP's system and FDA's.

For this reason I urge FDA to extend the phase III implementation of the BTA until such time that information on tenchical errors of the prior notice filings can be communicated to the trade and that the number of errors are greatly reduced. Otherwise the economic consequences could be devestating for the trade and cause havoc for the ports of entry, CBA and FDA.

I also submit that there should be exemptions for those food products that do not constitute a biological threat to the country in the form of commercial samples sent for testing within the importer's own facility, unadulterated u.s. goods being returned and household goods shipments which include food products from the importers own pantry and intended for their own use. I recently spent 15 uninterrupted hours inputting prior notices the the PNSI and I did have most of the required information provided to me. It takes much longer if I have to do the research and often the information is simply not available.

I also feel that it is important to have FDA personnel trained in each port of entry so that they are at least familiar with the BTA requirements on registration and prior notice.

Thank you for your attention to my concerns.

Patrice A. Iversonp-Summer
Global Trading Resources, Inc.
12695 NE Marx #12
Portland, OR 97230
503-262-5506 tel
503-262-5511 fax