Len Lang - Comment

FDA-2011-N-0920-0013 Comments by USCBIA Tim Sullivan and IEA The USCBIA would like to know why FDA and FSIS could not do sampling at one location along the border - Import establishments. FDA and USDA both handle imported food products. Why not allow Import Establishments to conduct the sampling of all imported food products (FDA and USDA). Makes sense regarding budget? More of a controlled area that is built for testing imported food products. Makes imported products be controlled at the port and sampling done before food product is actually in the interior of the country. Over 10 years ago Pembina, ND USDA FSIS conducted FDA testing for FDA; why not again? It worked then and should work now. It worked and did not hold up trade. It bolstered security, sampling, testing, and food security. See article below Government’s tendency to throw money rather than solutions at difficult problems often results in bureaucratic colossus.And, this appears to be true in the food industry.The Government Accountability Office, for instance, recently identified as many as 15 federal agencies collectively administering at least 30 federal laws relating to food safety.Agencies include the FDA, USDA, FSIS, EPA, FTC, and many, many more.The potential for redundancy and waste is obvious. The inefficiencies become more apparent with the recent passage of the FDA’s Food Safety Modernization Act (“FSMA”).It used to be that the laws applicable to the meat and poultry industries and all other foods were vastly different. In order to operate legally, meat and poultry companies were required to develop written HACCP programs – while most other food companies were exempt. Meat and poultry companies were also required to operate under continuous federal inspection, while all other FDA-regulated food companies could operate for years without a single visit from a government inspector. That has all changed.FSMA now represents the largest expansion of FDA’s food safety autho