AMI Voices Opposition to User Fees Included In Proposed Rule on Electronic Export Application and Certification RequirementsTuesday, March 27, 2012
(American Meat Institute)
AMI has submitted comments regarding the Food Safety and Inspection Service’s (FSIS) proposed rule Electronic Export Application and Certification Charge; Flexibility in the Requirements for Export Inspection Marks, Devices, and Certificates; Egg Products Export Certification, 77 Fed. Reg. 3159 (Jan. 23, 2012).
AMI notes that while the proposed rule would eliminate certain regulatory requirements, it also seeks to assess an unjustified user fee for entities that wish to use the soon-to-be developed electronic export application and certification system that will be a component of the agency’s Public Health Information System (PHIS).
“AMI objects to the proposed fee for several reasons, but primarily because assessing such a fee conflicts with the provisions of the Federal Meat Inspection Act (FMIA) and the Poultry Products Inspection Act (PPIA),” the comments state.
AMI also commented that it is critical that, as FSIS develops the electronic system, the agency work closely with exporters to ensure that the system is compatible with industry needs. Such a system needs to ensure that it requires minimal manual input. In effect, FSIS needs to develop a system that has “computer-to-computer” application.
AMI favors the following proposed changes to the meat and poultry regulations:
- Deleting the phrase ‘‘upon request’’ in the poultry regulations;
- Deleting certain specific certificate requirements, e.g., signature by a program employee and bearing a letterhead and the USDA official seal;
- Deleting references to ‘‘triplicate’’ and ‘‘duplicate’’ forms and allowing ‘‘copies’’ of the export certificate to be distributed to the required parties and to accompany the product;
- Deleting provisions that require filing a copy of the export certificate with Customs within four (4) business days of the clearance of the vessel at the time of filing the complete manifest;
- Making parallel the meat and poultry export regulations, to the extent possible; and
- Allowing exporters to mark product containers with a unique identifier that must link the product to the export certificate issued by inspection personnel.
AMI also stated that FSIS should consider providing greater flexibility with respect to export stamping.
To view the comments in their entirety, go to http://www.meatinstitute.org/ht/a/GetDocumentAction/i/76726.share on facebook share on twitter