Docket Management
Docket: 02N-0278 - Bioterrorism Preparedness; Prior Notice of Imported Food Shipments, Section 307
Comment Number: EC -7

Accepted - Volume 2

Comment Record
Commentor Mr. Ron Bulmer Date/Time 2002-08-27 17:38:28
Organization Fisheries Council of Canada
Category Food Industry

Comments for FDA General
1. General Comments Section 307 (Prior Notice) Docket #02N-0278 The Fisheries Council would propose that prior notice of the article , the manufacturer, shipper, country of origin, country from which it is shipped and port of entry to the USA may be provided by the importer or the exporter in the foreign market. Allowing the exporter/ manufacturer to file the notice saves time, cost, and simplifies the process for accuracy of records. The minimum time for prior notice should be no more than two hours for exports from Canada as many manufacturers are less than this time from a truck leaving a facility and reaching a point of entry. This is particularily important for perishable goods like fresh fish and shellfish in that final manifests are often made up only on loading of available goods. Perishable goods have a limited shelf life and should be allowed to move into the USA to the next designated owner of the goods ( one down) even if the notification form is not at the point of entry. Notice of release could be provided to the importer prior to further distribution. Expensive food items like live lobster with a total shelf life of 24 hours out of water would be compromised at great expense with any paperwork delay at the point of entry.

EC -7