I do not see much information clarifying the sampling of imported product. The import residue program needs to be more well defined with actions based on a defined regulatory requirement. That being said I would like the following questions addressed;
1) I dont see any method mentioned regarding how imported product will be refused; based on production lot, carton, etc. How is FSIS proposing to identufy failed product from a foreign country?
Will recalls be conducted based on product lot? If not then what will be used?
2) How will residue sampling be conducted in the Beyond the Border import pilot?
3) What import products will be held under test and control for residue sampling?
4) How will the new proposal affect the sample numbers that are randomly assigned per country annually?
5) What are the expectations, based on equivelancy, of the foreign countries sampling program? Do they have to sample in a simaler method?
6) How are imported products handled that show a trace of a residue but are not over tolerence? Does the trace amount cause any further sampling action at port of entry?
Comment from Leonard Lang
This is comment on Rule
New Analytic Methods and Sampling Procedures for the United States National Residue Program for Meat, Poultry, and Egg Products
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