Comment from Chris Overholt

In the September 3, 2010 stakeholder update on PHIS the agency listed four main components of PHIS: Domestic Inspection, Import Activities, Export Activities and Predictive Analytics. Of the 4 components, export activities and particularly electronic submission of export applications provide the most benefit to industry by reducing paperwork hurdles to meat and poultry exporting that our own government has put in place and result in a competitive disadvantage to US meat and poultry exports. Anyone involved in preparing an export certificate for Canada (perfectly typed in blocks to small to see), gaining pre-clearance from CFIA, presenting product to establishment FSIS and sending the completed cert to a vet for final signature knows that the documentation requirements for exporting products from the US far exceed the requirements any importer is required to meet. It's about time (actually about 2 years too late) that the agency considers amending the regulations.