NAMA's
Comments on
FDA's proposed regulation on registration of food
facilities under the Public Health Security and
Bioterrorism Preparedness and Response Act of 2002
April 3, 2003
Dockets Management Branch
(HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville, MD 20852
Re: Docket No. 02N-0276, Proposed Rulemaking “Registration of Food Facilities Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002”
To Whom It May Concern:
The North American Millers' Association (NAMA) appreciates the opportunity to comment on the Food and Drug Administration's (FDA) proposed regulation on registration of food facilities under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (a.k.a. The Bioterrorism Act). After the tragic events of September 11, 2001 protecting the United States public became of even greater importance and several legislative and regulatory actions have led to a significant increase in security. NAMA supports this focus on increased security and the need to better monitor the U.S. food supply.
As the national association representing 46 milling companies and over 95% of the U.S. milling capacity for wheat, corn, oats and rye, NAMA and its members have a vested interest maintaining a safe domestic food supply. Prior to the events of September 11, 2001 the U.S. milling industry was constantly working to improve the quality and security of the its products. Since that date millers have put an even greater emphasis on food safety and facility security.
NAMA commends FDA's efforts to continue the focus on food safety as it relates to bioterrorism through its proposed requirement for food facility registration. As proposed, the regulation provides logical and practical information from the food industry with regard to contact information and physical address for each food facility. NAMA believes that FDA has appropriately defined the scope of information necessary to accomplish the goal of quick response and notification in the case of a bioterrorist attack on the U.S. food supply.
NAMA recommends that FDA consider expanding the anticipated time frame for registration. During recent meetings, FDA has stated it intends to begin registration of food facilities on October 12, 2003 with a deadline for all facilities of December 12, 2003. NAMA is concerned that given the implementation of a new system and the hundreds of thousands of food facilities that will need to be registered that there is not enough time allotted. FDA should consider beginning the registration period earlier to account for unanticipated problems that arise in the introduction of any new system.
NAMA also recommends that FDA not unduly expand its current requirements for information under this proposed regulation. NAMA believes that FDA's proposed regulation has appropriately addressed the mandate of the Bioterrorism Act and also created a practical framework for those facilities that are to be governed by the regulation.
NAMA appreciates the opportunity to provide comments to FDA on its proposed regulation, and we look forward to working with the agency in its continued efforts to protect the U.S. food supply. If you have any questions about these comments or would like further information please contact T.J. Cantwell at 202/ 484-2200, ext. 109 or tjcantwell@namamillers.org.
Sincerely,
Betsy A. Faga
President
Read more . . .
News Release - North American Millers' Association Urges FDA to Increase Food Security Without Sacrificing Foreign Trade, April 9, 2003
NAMA comments on the Food and Drug Administration's proposed regulation on prior notice of imported food under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002
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