Docket Management
Docket: 02N-0277 - Bioterrorism Preparedness; Establishment and Maintenance of Records, Section 306
Comment Number: EC -6

Accepted - Volume 2

Comment Record
Commentor Mr. Ron Bulmer Date/Time 2002-08-27 17:24:07
Organization Fisheries council of Canada
Category Food Industry

Comments for FDA General
1. General Comments Section 306 (Record Keeping) #02N-0277 Fisheries Council would propose that the firm with ownership of a food product be considered the entity rresponsible for record keeping and the recipient next entity is when the ownership of the product changes. However such records shall note the handling and destinations of the product which may be physically in control of a food product (transport firm, distributor, warehouse, etc) without having an ownership responsibility for the food. Such a form could be developed by FDA and could provide a complete chain of custody record yet simplify the number and points of record keeping. Thus transportation firms or distributor warehouses could be noted on the form but only owners of the product would hold the records. Such records could be in hard copy or electronic fom. They should not be required to be kept longer than the shelf life of the product or two years maximum.

EC -6