2002N-0278 - Small Entity Compliance Guides on Registration of Food Facilities and Prior Notice of Imported Food; Availability
FDA Comment Number : EC455
Submitter : Mr. Simon Soni Date & Time: 05/17/2004 06:05:45
Organization : British Airways plc
International Industry
Category :
Issue Areas/Comments
To whom it may concern:

The following comments are being submitted in response to the Food and Drug Administration (FDA) proposal of May 9, 2003 titled ?Prior Notice of Imported Food Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (Docket # 2002N-0278) which has been reopened until May 14, 2004.

British Airways is a major global airline with operations serving 20 US cities from the United Kingdom and all global markets. Following the terrible events of 9/11 we, perhaps more than any other industry, understand the necessity to protect customers and markets from terrorist activity. As such we have a significant interest in the safety of international air travel and from a catering perspective, we strongly support reasonable measures to ward off any bioterrorist threat to our food supply

We wish to record a specific concern with regard to the above and wish to be sure that an exclusion as included in the above document covers the normal and safe operating practice of airlines.

The document may be interpreted to require the alerting of the Food and Drug Administration and/or the Customs and Border Patrol (CBP) that there will be some leftover unopened cans of soda, unopened small bottles of liquor (to be held in bonded storage) or other ?dry-stores? items on flights inbound to the U.S. and intended for use on later flights. Assuming these items ever leave the aircraft, they would be held at the Flight Catering unit prior to their re-loading on a future service from the US.

There is no danger to the American public from this operation. Additionally, there is no possible way to determine at ?wheels up? what will remain upon landing in the U.S. What is clear is that these items will only be used again in the inflight catering of services leaving the US and hence it is important that the exclusion ?Food that is exported without leaving the port of arrival until export? is broadened to make very clear that this exclusion includes any food items removed from any inbound aircraft and held at the catering unit for use on any outbound aircraft.

Such added clarity of the exclusion will allow the Federal regulatory agencies to concentrate their efforts on the parts of the food supply that pose some real risk from intentional contamination and will allow us to focus on safely and economically serving our passengers.

Yours sincerely

Simon P.R Soni
Manager Catering Operations
British Airwayls Plc

S777 Compass Centre
PO Box 10
Heathrow Airport
Hounslow Middx