The public has less than a month to supply comments on U.S. government proposal to streamline the reporting process for participants in the Seafood Import Monitoring Program.
Last month, NOAA Fisheries unveiled a draft rule regarding the creation of a Commerce Trusted Trader Program, a voluntary effort that seeks to reduce costs for both industry and the government. The first public meeting regarding the proposal took place on 15 February.
Public comments, which can be submitted at the Regulations.gov website, must be submitted by 19 March.
John Henderschedt, director of NOAA Fisheries Office of International Affairs and Seafood Inspection, said the public comment period also gives key stakeholders an opportunity to learn more about the proposed rule.
Henderschedt said NOAA officials planned for a Trusted Trader concept when SIMP was first announced. However, the agency needed to develop the SIMP framework first before delving into the specifics of the Trusted Trader program.
Companies that participate in the Trusted Trader Program still would be required to maintain the traceability records – from the time of harvest to the time it reaches the U.S. – on all seafood products listed under SIMP.
In general terms, the Trusted Trader Program will run similar to the PreCheck initiative offered to frequent travelers by the Transportation Security Administration, with a couple of exceptions. First, seafood importers will have to adhere to the SIMP regulations and incorporate them into their standard operating procedures.
Second, the participating companies will be required to hire a third-party firm to audit their records annually to ensure they’re maintaining compliance with SIMP. If the Trusted Trader Program becomes reality, companies could lose their status if audits indicate they’re not abiding by the regulations.
“Through that process we're going to be able to monitor compliance with these Trusted Trader plans much more closely, or once they verify the clients, much more closely than we could if were relying solely on our agency's capacity to audit all these programs,” Henderschedt said.
Hiring an auditor also would not keep the government from auditing a company’s records on its own, he added.
Companies interested in becoming Trusted Traders would also have to pay an application fee that NOAA Fisheries expect to cost around USD 30 (EUR 24.37).
There haven’t been many comments received, Henderschedt said. During the first meeting, stakeholders mainly listened to the presentation by NOAA officials.
One organization that has supplied comment is the Southern Shrimp Alliance. While the group said it supports the concept of such a program for “legitimate importers,” John Williams, SSA’s executive director, did outline some concerns in a letter posted online 23 February.
The SSA wants importers to only use third-party auditors who not only understand the seafood trade, but have experience in auditing such records. Another concern raised by the group is data security. Williams said the SSA wants assurances that importers in the Trusted Trader Program cannot alter data at any point in their record-keeping process.
“As we fully expect the agency and importers will find out, neither the SIMP or CTT programs will achieve their stated objectives if such security measures are not incorporated into the chain-of-custody data systems,” Williams said. “At a minimum, the agency should insist on such security measures as part of a CTTs internal control system.”
Once the public comment period ends, NOAA Fisheries will review the remarks and determine what, if any changes, it will make to the proposed rule. As long as the feedback does not cause substantial changes to the current proposal, Henderschedt said he would like to see a Trusted Trader Program implemented in some fashion during the 2019 calendar year.
“We believe that the program does offer some benefits to importers of record, and we would really like to offer those benefits as soon as possible. We're certainly going to be expediting the process as much as we can,” he said.
An informational webinar on the program is slated to take place Wednesday, 28 February, and a session is also scheduled for 12 March during Seafood Expo North America in Boston.
