Leman (Chip) Bown, Jr by ypl44131


									Leman (Chip) Bown, Jr                 FedEx Trade Networks           Telephone 716-871-3240
Managing Director                     Transport & Brokerage          Fax 716-871-3255
Regulatory Compliance                 128 Dearborn Street            Email: lgbownjr@fedex.com
                                      Buffalo, NY 14207

March 5, 2003                                                            Via E-Mail

Office of Information and Regulatory Affairs
Office of Management and Budget
New Executive Office Building
725 17th Street, NW, Room 10235
Washington, DC 20503

Attn: Mr. Stuart Shapiro, Desk Officer for FDA

SUBJECT: Prior Notice of Imported Food Under the Public Health Security and Bioterrorism
Act of 2002, Docket No. 02N-0278, RIN 0910-AC41, 21 CFR Part

Dear Mr. Shapiro;

We are responding to the NPRM of February 2, 2003, referenced above, specifically the
collection of information provisions.

The separate response to the “collection of information provisions” to OMB is confusing in
conjunction with its relationship to the overall proposal. We are confused as to whether
OMB/FDA wants comments on the proposed data elements to be collected, the cost analysis of
economic impact to provide this information, or the proposed form and it’s data elements that
would apparently be the information basis to the Internet application.

FedEx respectfully requests that OMB clarify the nature of their information request and provide
an additional opportunity to comment so that we may evaluate the impact on our operations and
convey any concerns to OMB.

Further, we have strong objections to the use of the Internet versus data transmissions through
existing ACS government applications. Due to the proposed redundancy and duplicative data in
both the proposed Internet and existing ACS transmissions, we estimate this new process will be
highly labor intensive, expensive and will result in a doubling of current cost to the importing

Yours truly,

Leman G. Bown, Jr.
Managing Director
Regulatory Compliance

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