***Carriere Foods Inc.***

July 4, 2003

Dockets Management Branch

HFA-305

Food and Drug Administration (FDA)

5630 Fishers Lane

Room 1061

Rockville, MD 20852

Reference: **1. Establishment and Maintenance of Records - Docket No.
02N-0277**

**2. Administrative Detention -- Docket No. 02N-0275**

Dear Madam / Sir,

*Carriere Foods Inc*. is a Canadian leader processing canned and frozen
vegetable products in seven (7) federally registered food establishments
with the Canadian Food Inspection Agency (CFIA) located in Eastern
Canada: Quebec (4), Ontario (2) and Nova Scotia (1). We distribute our
canned and frozen vegetable products mainly in Canada, USA, and
Caribbean and in Europe to the retail, food service and industrial
markets under both national and private brands.

Please find attached our **comments** **on the proposed FDA
Regulations**: *Establishment and Maintenance of Records* and
*Administrative Detention* both issued in May 2003, following the FDA
Actions on New Bioterrorism Legislation of 2002. We certainly thank the
FDA for the opportunity to present our comments and help ensuring that
the U.S. food supply remains safe and secure for our valuable U.S.
customer while making the current proposals more effective, flexible and
less burdensome.

**1. Establishment and Maintenance of Records - Docket No. 02N-0277**

**Proposed Regulation** -- *The Public Health Security and Bioterrorism
... that would establish requirements regarding the establishment and
maintenance, for no longer than two years, of records by persons
(excluding farms and restaurants) who manufacture, process, pack or
import food.*

**Comments** -- In order to meet the specifications & expectations of
our Canadian and U.S. customer, comply with the regulatory requirements
& industry practices and give us the required flexibility, we would
rather suggest to establish and maintain a minimum retention period of
these records for all foods (minimum of two years after the date of
production) other than perishable foods and animal foods (minimum of one
year after the date of production). These records would be kept at the
facility and/or at the corporate office of the company in any current
format, paper or electronic.

.../2

\- 2 -

**Proposed Regulation** -- *For manufacturers, processors, packers, ...
, the records would have to: 1. Identify the immediate non-transporter
previous sources ... . 2. Identify the immediate non-transporter
subsequent recipients ... .*

Food Companies already keep extensive records to facilitate tracking of
products, recalls, etc. We suggest allowing companies to rely upon
existing records to avoid duplicate record keeping, extra financial
costs and useless burdens. Food processors commonly store raw
ingredients such as liquid sugar, bulk salt, etc. in large tanks and
silos. Usually, these tanks and silos are not dedicated but rather are
topped off as we are running low, making difficult to retrace the
immediate source of these bulk ingredients.

**2. Administrative Detention -- Docket No. 02N-0275**

**Proposed Regulation** -- *The proposed rule would require the
detention order to include the detention order number, the hour and
date, ... and location where the article of food is to be detained and
the appropriate storage and transportation conditions.*

**Comments** -- We would suggest to already include some provisions
regarding the appropriate storage and transportation conditions, such as
refrigerated foods kept under 40 degrees F and frozen foods kept under
-- 4 degree F to meet the regulatory requirements & common industry
practices and satisfy our customer expectations.

## General Comments

Our suggestions would also take into account the commercial realities
and the common business practices of our canned and frozen vegetable
products shipped into USA, especially with routine truck shipment
regularly scheduled between Canada and the U.S.

Under the Customs-Trade Partnership Against Terrorism (C-TPAT), Customs
will designate participating importers as low risk status if they have
shown a regulatory compliance history and effective supply chain
security. FDA should also recognize participating importers as low risk
status and evaluate the economic impact and financial costs of those
proposed regulations.

Best Regards,

# André Beaudoin

André Beaudoin

Director, Quality Assurance

*Carriere Foods Inc.*

540, Chemin des Patriotes

St-Denis-sur-Richelieu, Quebec, Canada

JOH 1KO