Comment from lWalter Piatkowski

United States Canadian Border Association. 3555 Witmer Rd Niagara Falls, NY 14305 piatkowskimeats@aol.com Subject: Comments on the Import Rule- Food Safety and Inspection Service 9 CFR Parts 304, 327, 381, and 590 Docket No. FSIS-2009-0022 RIN 0583-AD39 (http://www.fsis.usda.gov/Frame/FrameRedirect.asp?main=http://www.fsis.usda.gov/OPPDE/rdad/FRPubs/2009-0022.htm ) BY ELECTRONIC MAIL FSIS Proposed Rule, “Electronic Import Inspection Application and Certification of Imported Products and Foreign Establishments; Amendments to Facilitate the Public Health Information System (PHIS) and Other Changes to Import Inspection Regulations” (November 27, 2012) Comments Sanitation Standard Operating Procedures (SSOP) - USDA-FSIS is proposing that official import establishments develop, implement and maintain written SSOPs per 9 CFR §§ 416.11- 416.17 in order to operate under a grant of inspection. ? In practice, most of the official import establishments have maintained SSOP’s for 5 years or more, especially during the reinspection of imported products. The requirements set forth for the import facility SSOP’s were well defined. By well-defined, specifically what areas the import inspector would have regulatory jurisdiction over regarding sanitation! ? Import establishment have physical parameters that go beyond the area of product reinspection. The majority of import establishments are warehouses rather than production facilities. The warehouse areas may be nine (9) or ten (10) story facilities or multi-acre facilities which in the most part, do not affect the areas were product will be staged or reinspected (exposed)! ? This language appears to be misleading with the new requirement. Most import establishments already have a grant of inspection