Scott Joseph Burton Smith - Comment

I have been involved with the seafood import industry for over 20 years. The pace of our industry is much faster today than it was 20 years ago, as technologies have improved and competition has continued to force us to become more efficient. With all due respect, FDA has not gotten any faster in handling it's oversight of the seafood industry. In fact, they have gotten slower. Increasing the safety of imported seafood is in my company's best interest and I am in favor of making this happen. However, in my opinion, it would be best to get the private industry more involved. Specifically, the sampling of imported seafood items can be much more efficiently done by the private labs already in place. Currently, we get a private lab to pick-up samples in two days. It takes FDA in Los Angeles up to two weeks. We get a private lab to run a decomp test in two days. It takes FDA at least a week. We do need FDA to monitor the labs and ensure that regulations are being followed, but having the responsible for the work is an inefficient use of funding. This docket will establish fees for FDA's testing and handling of Importer Reinspection User Fees. I have no reason to believe that FDA will improve their efficiency, so expect the fees charged to be double or triple with private industry would need for the same functions. These increased fees will be passed on to the consumer, raising seafood prices even higher, hurting small businesses at all levels in the marketing chain during an alrelady difficult time. I wish there had been more thought and discussion to using private industry. I believe that this is a move in the wrong direction for the seafood import industry and all those involved. Sincerely - Scott Smith Union Fish Company