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 : EC471
Submitter : Ms. Susan Hays Date & Time: 05/17/2004 06:05:15
Organization : Wild Bird Feeding Industry
Category : Animal Feed Industry
Issue Areas/Comments
Comment on Question 4: Companies participating in C-TPAT and FAST are required to file application that includes being subject to government inspections prior to approval. This process is intended to aid the foreign supplier, customs brokers, and the US importer with expedited movement of their freight. However, the process of approval is extremely slow due to the enormous quantity of applications received.
The impact on the quality of service at US Ports has been severely reduced by the DHS legislation. Instead of adding more inspections within the US, the use of DHS finances would be better utilized by educating inspectors in the area of agricultural commodities. The current level of Knowledge is extremely low and it is doubtful that the average inspector would recognize potential problems without eduction in the appropriate area. Industry has already voluntarily elected to implement quality standards.
The import process has become time consuming and expensive for the importer. FDA and CBP should focus on coordinating their efforts to achieve uniformity of inspections at all ports of entry while focusing their efforts to relieve the congestion and expense in the US Ports of Entry. The current situation is causing significant financial harm to small US businesses.
The FDA has provided guidance for the industry, and facilities that hold imported food have responded by voluntarily implementing security measures. US facilities are well aware of the need to protect the food chain and to subject these firms to additional inspections should not be the focus of DHS.