Available for download below (PDF) are initial comments submitted to FDA by CRN on August 30, 2002 on the agency's implementation of the Bioterrorism Act of 2002, with regard to three provisions: registration of facilities, recordkeeping, and prior notice of imports. These comments are based on discussions with the CRN Regulatory Affairs Committee and on materials developed by the Food Security Alliance organized by the National Food Processors Association, to permit dozens of food associations to share information and views on these issues.

FDA offered all affected industries the opportunity to submit initial comments and put important issues on the table by August 30. After that date, FDA will begin actual work on the regulations implementing these provisions. The proposed rules are intended to be published in December of this year, with 60 days for formal comment, and CRN will of course be submitting additional information at that time. These provisions are required by Congress to be implemented by December 12, 2003. FDA intends to finalize the rules at least 60 days before that time.

Comments on registration of facilities (PDF)

Comments on recordkeeping (PDF)

Comments on prior notice of imports (PDF)