NAMA Comments
Re:
Docket No. 02N-0275, Proposed Rulemaking
“Administrative Detention of Food for Human or
Animal Consumption Under the Public Health Security and
Bioterrorism Preparedness and Response Act of 2002”
July 8, 2003
Dockets Management
Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville, MD 20852
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 the administrative detention of food for human and animal consumption under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (a.k.a. The Bioterrorism Act). The tragic events of September 11, 2001 demonstrated the need to protect the U.S. public from the threat of terrorist attacks and the FDA plays an important part by ensuring the security of the U.S. food supply. NAMA supports the increased focus on the security of the U.S. food supply and the efforts of Congress and the FDA to strengthen the agency's ability to guard against potential attacks.
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 in maintaining a safe food supply. To help maintain a safe food supply NAMA members work diligently to comply with all U.S. regulations governing food safety and plant security. In addition, NAMA members often set higher internal standards in order to ensure the products a mill is processing are of the highest possible quality.
Since NAMA members firmly believe in the need for a safe food supply and to protect the public from future terrorist attacks directed at the food supply, NAMA members support useful and logical enhancements to FDA's detention authority.
However, as members of the entire food chain and companies in the business of providing food to U.S. and foreign customers, NAMA wants to emphasize one point that the FDA should consider in when implementing the final regulations.
Judicious Use
of Authority
FDA officials have previously stated in public
meetings that the administrative detention authority
will rarely be used and reserved solely as another
tool available to the agency. NAMA encourages the FDA
to carefully and judiciously employ any of the
additional authorities granted it under the
Bioterrorism Act. This authority should be reserved
for occasions when all other possible solutions have
been exhausted. The administrative detention
authority is designed to fill a possible gap in the
current authority FDA has to protect against a
terrorist attack on the food supply and should be
used only when necessary.
Thank you for the opportunity to provide comment on this proposed regulation. NAMA looks forward to working with the FDA on these and other regulations to help ensure the security of the U.S. food supply. If you have any questions please contact me at 202/484-2200, ext. 104 or at bfaga@namamillers.org.
Sincerely,
Betsy Faga
President
Read more:
NAMA comments on the Food and Drug Administration's proposed rulemaking “Establishment and Maintenance of Records Under the Public Health Security and Bioterrorism Preparedness and Response Act of 2002”. July 8, 2003
NAMA 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
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
last updated July 30, 2003
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