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Phản hồi quan trọng từ Catfish Farmers of America

September 24, 2018
Comments on the Eligibility of Vietnam to Export Siluriformes Fish to the U.S.
Thank you for the opportunity to provide comments regarding the Proposed Rule on the eligibility of Vietnam to Export Siluriformes Fish to the United States. The Catfish Farmers of America (CFA) represents catfish farmers, processors, feed mills, researchers, and suppliers of U.S. Farm-Raised Catfish across the United States.

Our organization is a non-profit trade association that was formed in 1968 and is the United States’ strongest aquaculture organization. We are proud to say that our government food safety programs in the U.S. have decades of established history of operation and records of being the safest food source producer in the world. We are in support of this process to determine foreign equivalency to our federal program and provide consumers with safe alternative choices. We do not believe that this equivalence of safety is sustainable on a newly created system and implemented over months by conducting two short inspection record reviews and on-site inspection of eight establishments.
Equivalency to the U.S. inspection program should be verified multiple times in the course of a year and continue over a period of many years to verify compliance and earn the equivalency status of the U.S. This is especially important when only one small part (Siluriformes) of this country’s food supply has been mandated to higher standards. It should be noted that Vietnam required inspections in May and again in August. In addition, a reduction in certified plants to thirteen occurred before FSIS was able to get their audit information. These events further support that Vietnam needs repeated verifications in order to sustain a genuine equivalent inspection system. We are very pleased and supportive to see that every imported shipment will be subject to reinspection upon entry in order to receive the official mark of inspection. Upon re-inspection, when a failure occurs, we request the same recall classification be applied, with the same consequences, as our US producers.
We do not believe unsafe and adulterated fish should ever have the ability to enter commerce and be offered for human consumption anywhere in the world. We believe the penalty should be mandatory product destruction instead of leaving US soil. Our concerns center on the newness of Vietnam’s inspection process, ongoing verification of their compliance, creating a significant change on a singular product at all levels of their regime, system dilution from turnover of directly involved personnel, and lesser consequences for inferior product/companies than the US establishments. Please carefully review the site and record inspections of the next operations slated for their approval. Please evaluate carefully the timing and number of new foreign establishments certified once rule becomes final. Also monitor significant changes in product volume from the existing establishments once rule has been finalized.
These all could be potential indicators of a short-term façade and channeling products from unapproved producers or opportunities to circumvent our system. Thank you for the opportunity to provide comment on this proposed rule. We continue to make our industry available in any way that would be of assistance to FSIS in your efforts to continue providing American consumers the safest food safety system in the world.

Sincerely,
Townsend Kyser President, Catfish Farmers of America

October 12.2018

Camerican International would like to express its support for the Food Safety and Inspection Service’s (FSIS) proposed rule Docket No. FSIS-2018-0029, which would grant eligibility of the Socialist Republic of Vietnam to export Siluriformes Fish and Fish Products to the United States. We applaud FSIS’s thorough analysis of Vietnam’s laws, regulations, and inspection system as implemented which resulted in the determination that Vietnam's Siluriformes fish inspection system is equivalent to the system that the U.S. has established under the Federal Meat Inspection Act (FMIA) and its implementing regulation.
Camerican International is a full-service food Importer. We have been actively doing business on the international stage importing Seafood, Fruits, and Vegetables for over 100 years. I have personally worked with Vietnamese Siluriformes Fish and Fish products for over 15 years. In working with this product, I have not encountered any serious food safety problems. I have visited the plants where these products are produced and have found that in every case that I witnessed, the factories are at the very least equivalent, and in some cases superior to the plants I have been in in the US. Our customers can be certain that they are purchasing a quality, safe product.
We believe the proposed rule is based on sound science and laud FSIS’s science-based approach in reaching this decision. As was concluded by FSIS, imported Siluriformes products are safe for U.S. consumers. For many years, including during the time that inspection of this product was under FDA jurisdiction, there have been no major cases of unsafe imported Siluriformes products and we are confident this will continue in the future.
The proposed rule will certainly benefit the overall industry and bring back certainty to the commerce of this important product. Consumers in the U.S. will continue to enjoy this product and have access to more choices when purchasing Siluriformes fish, specially of the Pangasius family (native to Vietnam, China, and other Asian countries). Pangasius have a different flavor, color and texture than other catfish species found in the U.S., which creates more options and competition for U.S. consumers. The implementation of this rule would also bring stability and continued opportunity for trade between the U.S. and Vietnam at a time when strengthened trade relationships are highly valued by both countries.
We kindly request FSIS promptly publish the final rule for the import of Siluriformes Fish and Fish Products from Vietnam into the U.S.
Sincerely,
Rick Fox Senior Director, Seafood


October 8, 2018
Piazza’s Seafood World, LLC would like to express its support for the Food Safety and Inspection Service’s (FSIS) proposed rule Docket No. FSIS-2018-0029, which would grant eligibility of the Socialist Republic of Vietnam to export Siluriformes Fish and Fish Products to the United States. We applaud FSIS’s thorough analysis of Vietnam’s laws, regulations, and inspection system as implemented which resulted in the determination that Vietnam's Siluriformes fish inspection system is equivalent to the system that the U.S. has established under the Federal Meat Inspection Act (FMIA) and its implementing regulation.
Piazza’s Seafood World, LLC is seafood importer and wholesale distributor. We have worked with Vietnamese Siluriformes Fish and Fish products for over 20 years. In working with this product, we have not encountered any serious food safety problems. Our customers can be certain that they are purchasing a quality, safe product.
We believe the proposed rule is based on sound science and laud FSIS’s sciencebased approach in reaching this decision. As was concluded by FSIS, imported siluriformes products are safe for U.S. consumers. For many years, including during the time that inspection of this product was under FDA jurisdiction, there have been no major cases of unsafe imported siluriformes products and we are confident this will continue in the future.
The proposed rule will certainly benefit the overall industry and bring back certainty to the commerce of this important product. Consumers in the U.S. will continue to enjoy this product and have access to more choices when purchasing siluriformes fish, specially of the Pangasius family (native to Vietnam, China, and other Asian countries). Pangasius have a different flavor, color and
texture than other catfish species found in the U.S., which creates more options and competition for U.S. consumers. The implementation of this rule would also bring stability and continued opportunity for trade between the U.S. and Vietnam at a time when strengthened trade relationships are highly valued by both countries.
We kindly request FSIS promptly publish the final rule for the import of Siluriformes Fish and Fish Products from Vietnam into the U.S.
Sincerely,
Jennifer Champagne Piazza’s Seafood World, LLC Manager

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