# Presentation: 388334

## What the Import Safety Working Group FoundMary StanleyOffice of International AffairsFood Safety and Inspection Service

- NACMPI—August 27, 2008

**Notes:**
A careful examination of import safety has been motivated by the recent challenges presented by an increasingly global economy in which US. Consumers are purchasing approximately $2 trillion worth of products that are imported by over 800,000 importers through over 300 ports

In developing the Strategic Framework, Immediate Actions, and Action Plan, the Working Group engaged in a campaign to solicit comments and recommendations from the public.

The seminal finding of the Framework was that to adapt to a rapidly growing and changing global economy, we must develop new import-safety strategies that expand and emphasize a cost-effective, risk based approach.

## Executive Order  13439 – July 18, 2007

- Establish an Interagency Working Group on Import Safety
*    **We need to continually improve our import safeguards to meet the changing demands of a global economy. We must ensure that our food supply and imported products remain among the safest in the world.  Our purpose is not just to look at today, but to anticipate tomorrow.*
- Secretary Michael O. Leavitt
- Chair, Interagency Working Group on Import Safety
- August 6, 2007

**Notes:**
A careful examination of import safety has been motivated by the recent challenges presented by an increasingly global economy in which US. Consumers are purchasing approximately $2 trillion worth of products that are imported by over 800,000 importers through over 300 ports

In developing the Strategic Framework, Immediate Actions, and Action Plan, the Working Group engaged in a campaign to solicit comments and recommendations from the public.

The seminal finding of the Framework was that to adapt to a rapidly growing and changing global economy, we must develop new import-safety strategies that expand and emphasize a cost-effective, risk based approach.

##  Interagency Working Group Membership

- Secretary of Health and Human Services
- Secretary of State
- Secretary of the Treasury
- Attorney General
- Secretary of Agriculture
- Dr. Richard Raymond
- Secretary of Commerce
- Secretary of Transportation
- Secretary of Homeland Security

- Director of the Office of Management and Budget
- United States Trade Representative
- Administrator of the Environmental Protection Agency
- Chairman of the Consumer Product Safety Commission

## Strategic Framework, Immediate Actions and Action Plan

- A Strategic Framework for Continual Improvement on Import Safety
- Issued September 10, 2007
- Three organizing principles
- Six cross-cutting building blocks
- Four immediate actions
- Action Plan for Import Safety:  A Road for Continual Improvement
- Issued November 6, 2007
- Action Plan contains 14 broad recommendations and 50 specific action steps.

**Notes:**
Strategic framework concluded that the U.S> must transition from an outdated “snapshot” approach to import safety, in which decisions are made at the border, to a cost-effective, prevention-focused “video” model that identifies and targets critical points in the import lifecycle where risk of the product is greatest.

The Action Plan presents broad recommendations and specific short-and long-term action steps, categorized under the organizing principles of prevention, intervention and response.  Each action item is based on the building blocks identified in the Strategic Framework.

The Strategic Framework and the Action Plan provide a national strategy for continually improving the safety of imported products.

Immediate Actions
Improve Collaboration and information sharing with the private sector to improve safety of imports
Interoperability Acceleration
Global Collaboration
Agreements with Foreign Governments

## Strategic Framework

**The Strategic Framework Organizing Principles**
- Prevention - prevent harm in the first place;
- Intervention - intervene when risks are identified; and,
- Response - respond rapidly after harm has occurred.
**The Strategic Framework Building Blocks**
- 1.  Advance a Common Vision
-   Increase Accountability, Enforcement and Deterrence
-   Focus on Risks Over the Life Cycle of an Imported Product
-   Build Interoperable Systems
-   Foster a Culture of Collaboration, and,
-   Promote Technological Innovation and New Science

**Notes:**
Strategic framework concluded that the U.S> must transition from an outdated “snapshot” approach to import safety, in which decisions are made at the border, to a cost-effective, prevention-focused “video” model that identifies and targets critical points in the import lifecycle where risk of the product is greatest.

The Action Plan presents broad recommendations and specific short-and long-term action steps, categorized under the organizing principles of prevention, intervention and response.  Each action item is based on the building blocks identified in the Strategic Framework.

The Strategic Framework and the Action Plan provide a national strategy for continually improving the safety of imported products.

Immediate Actions
Improve Collaboration and information sharing with the private sector to improve safety of imports
Interoperability Acceleration
Global Collaboration
Agreements with Foreign Governments

## Strategic FrameworkRecognition of the Strengths of the Current FSIS System

- FSIS _statutory _controls for imports
- Foreign country inspection systems must be determined eligible to export to the United States
- Every shipment is presented for port-of-entry reinspection
- Foreign inspection systems are verified that they continue to meet U.S. requirements (FSIS audits)
- Government to government dialogue

**Notes:**
Strategic framework concluded that the U.S> must transition from an outdated “snapshot” approach to import safety, in which decisions are made at the border, to a cost-effective, prevention-focused “video” model that identifies and targets critical points in the import lifecycle where risk of the product is greatest.

The Action Plan presents broad recommendations and specific short-and long-term action steps, categorized under the organizing principles of prevention, intervention and response.  Each action item is based on the building blocks identified in the Strategic Framework.

The Strategic Framework and the Action Plan provide a national strategy for continually improving the safety of imported products.

Immediate Actions
Improve Collaboration and information sharing with the private sector to improve safety of imports
Interoperability Acceleration
Global Collaboration
Agreements with Foreign Governments

## Immediate Actions

**Interoperability Acceleration of Automated Commercial Environment/International Trade Data System (ACE/ITDS)**
- OMB directive (September 10 and September 28 memoranda)
- USDA submitted the Implementation Plan for completing ACE/ITDS interface with U.S. Customs and Border Protection on November 12
- Implementation plan included:
- Budgetary resources needed to support the ACE/ITDS interface
- Performance measures for programs delivered through ACE/ITDS
- Business and technical requirements for the ACE/ITDS interface

## FSIS Status—Immediate Actions

- FSIS has completed or is nearing completion of items required by OMB for ACE/ITDS
- Completed a Concept of Operations (CONOPS) document to CBP which includes import port of entry and enforcement business process scenarios
- Drafted a Memorandum of Understanding with DHS to support the ACE/ITDS interface
- FSIS awarded a contract to develop the Public Health Information System (PHIS), which will support the interface with ACE/ITDS

## Recommendations of the Action Plan on Import SafetyNovember 2007

- Safety Standards: Create new and strengthen existing safety standards.
- Certification: Verify compliance of foreign producers with U.S. safety and security standards through certification.
- Good Importer Practices: Promote good importer practices.
- Penalties: Strengthen penalties and take strong enforcement actions to ensure accountability
- Foreign Collaboration and Capacity Building: Make product safety an important principle of our diplomatic relationships with foreign countries and increase the profile of relevant foreign assistance activities.
- Common Mission:  Harmonize federal government procedures and requirements for processing import shipments.
- Interoperability: Complete a single-window interface for the intra-agency, interagency and private sector exchange of import data.

**Notes:**
The Federal departments and agencies with jurisdiction over imported products should work with industry, standards development organizations, and other members of the public to strengthen U.S. Safety standards where needed and appropriate, particularly for products determined to be high-risk.

Federal departments and agencies should increase their participation in international standards-setting organizations to encourage the development of international standards.

When developing standards, Federal agencies should consider best available science, industry best practices, and standards set by credible national and international standards development organizations.

Extend mandatory declaration of conformity—Requiring a dec. of conformity improves supplier compliance with mandatory standards. Extending the existing conformity requirement under the CPSA to other statutes administered by the CPSC would enhance the Commission’s ability to ensure product safety. 

Clarify the FDA authority to require preventive controls—Would strengthen the FDA’s ability to require by regulation preventive control measures to address risks and might occur for domestic and foreign produced foods.

Standards programs established and administered by the private sector with input from government can provide a generally accepted forum for developing safety standards.

## Recommendations of the Action Plan on Import SafetyNovember 2007

- Information Gathering: Create an interactive import-safety information network.
- New Science: Expand laboratory capacity and develop rapid test methods for swift identification of hazards.
- Intellectual Property Protection: Strengthen protection of intellectual property rights to ensure consumer safety.
- Recall: Maximize the effectiveness of product recalls.
- Federal-State Rapid Response:  Maximize federal-state collaboration.
- Technology: Expedite consumer notification of product recalls.
- Track-and-Trace: Expand the use of electronic track-and-trace technologies

**Notes:**
The Federal departments and agencies with jurisdiction over imported products should work with industry, standards development organizations, and other members of the public to strengthen U.S. Safety standards where needed and appropriate, particularly for products determined to be high-risk.

Federal departments and agencies should increase their participation in international standards-setting organizations to encourage the development of international standards.

When developing standards, Federal agencies should consider best available science, industry best practices, and standards set by credible national and international standards development organizations.

Extend mandatory declaration of conformity—Requiring a dec. of conformity improves supplier compliance with mandatory standards. Extending the existing conformity requirement under the CPSA to other statutes administered by the CPSC would enhance the Commission’s ability to ensure product safety. 

Clarify the FDA authority to require preventive controls—Would strengthen the FDA’s ability to require by regulation preventive control measures to address risks and might occur for domestic and foreign produced foods.

Standards programs established and administered by the private sector with input from government can provide a generally accepted forum for developing safety standards.

## Recommendation #6Common Mission:  Harmonize Federal  Procedures for Processing Import Shipments

**Develop uniform inter-departmental procedures, where appropriate, for clearing and controlling shipments at ports-of-entry.**
**Develop a strategic plan for rapid response to import-safety incidents.**
**Co-locate border officials from multiple agencies, when feasible, to enhance targeting and risk-management decisions on import safety.**
- Exercise commissioning and cross-designation authority to leverage Federal resources to prevent unsafe products from reaching U.S. consumers.

## Recommendation #7Interoperability:  Complete a Single-Window Interface for the Intra-agency, Interagency, and Private Sector Exchange of Import Data

**Require Federal departments and agencies, by the end of 2009, to have the capability to exchange commercial data and, to the extent allowable by law, communicate electronically with the importing community and other agencies through ACE/ ITDS.**
**Develop, as appropriate, within the Automated Targeting System (ATS), risk-based screening technologies to target high-risk products in a more effective way and facilitate the entry of low-risk products.**
**Develop an implementation plan for the integration of the Standard Establishment Data Service (SEDS) module into ACE/ITDS. **

## Import Safety Action Plan UpdateJuly 2008FSIS Highlights

- Co-located FSIS staff with CBP at the National Targeting Center
- FSIS implemented the Import Alert Tracking System (IATS) that enables better coordination in enforcement actions through quicker access to information collected on illegal entries
- FSIS detected and took enforcement action on 156 shipments (2.4 million pounds) of potentially ineligible shipments that entered U.S. commerce without FSIS inspection

**Notes:**
Strategic framework concluded that the U.S> must transition from an outdated “snapshot” approach to import safety, in which decisions are made at the border, to a cost-effective, prevention-focused “video” model that identifies and targets critical points in the import lifecycle where risk of the product is greatest.

The Action Plan presents broad recommendations and specific short-and long-term action steps, categorized under the organizing principles of prevention, intervention and response.  Each action item is based on the building blocks identified in the Strategic Framework.

The Strategic Framework and the Action Plan provide a national strategy for continually improving the safety of imported products.

Immediate Actions
Improve Collaboration and information sharing with the private sector to improve safety of imports
Interoperability Acceleration
Global Collaboration
Agreements with Foreign Governments

## Import Safety Action Plan UpdateJuly 2008FSIS Highlights

- Initiated electronic transfer of certificate data elements from the New Zealand Food Safety Authority into the FSIS Automated Import Information System (AIIS)
- To be expanded to Australia upon completion of the testing phase
- DHS and FSIS participated in a G-8 exercise on food contamination, including a process for sharing information related to containment events and other import/export information
- Coordinated a public meeting with local, state, federal health partners, as well as consumer groups and industry to share best practices and challenges for effective coordination during multi-jurisdictional food-borne outbreaks

**Notes:**
Strategic framework concluded that the U.S> must transition from an outdated “snapshot” approach to import safety, in which decisions are made at the border, to a cost-effective, prevention-focused “video” model that identifies and targets critical points in the import lifecycle where risk of the product is greatest.

The Action Plan presents broad recommendations and specific short-and long-term action steps, categorized under the organizing principles of prevention, intervention and response.  Each action item is based on the building blocks identified in the Strategic Framework.

The Strategic Framework and the Action Plan provide a national strategy for continually improving the safety of imported products.

Immediate Actions
Improve Collaboration and information sharing with the private sector to improve safety of imports
Interoperability Acceleration
Global Collaboration
Agreements with Foreign Governments