VHC -Vương quốc cá tra

September 20, 2018

Comments on the Eligibility of Vietnam to Export Siluriformes Fish to the U.S.

First off, let us say that our government food safety programs in the US have many years of established history of operation and records of being the safest food source 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 safety is sustainable on a brand new system created and implemented over months by passing a record review and on-site inspection of 8 establishments. The equivalency to the US 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 and possibility reduced amounts of inspection. This is especially important when only one small part (Siluriformes) of the country’s food supply is called to stricter standards and a minority few of government employees are responsible in a culture where less has been and is accepted. 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 suggest 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 reflect around the newness of their inspection process, ongoing verification of their compliance, creating a significant change on a singular product at all levels of their culture (business and government), system dilution from turnover in directly involved personnel, and lesser consequences for inferior product/companies than the US establishments. Please consider site and record inspections of the other 5 operations slated for 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 could be potential indicators of a short term façade, channeling products from unapproved producers or opportunities to circumvent our system.
Russ McPherson
Director of Technical Services
Alabama Catfish LLC, dba Harvest Select
Plant CPW354 Uniontown, AL 36786

GG dịch:

October 9, 2018
Mr. Paul Kiecker, Acting Administrator Food Safety and Inspection Service United States Department of Agriculture 331-E Jamie L. Whitten Building 12th Street and Jefferson Drive SW Washington, DC 20250
RE: Docket Number FSIS-2018-0029; Request for Comment Period Extension
Dear Mr. Kiecker:
On behalf of the advocacy organization Food & Water Watch, I am requesting that the comment period for Docket Number FSIS-2018-0030, “Eligibility of the Socialist Republic of Vietnam To Export Siluriformes Fish and Fish Products to the United States,” (83 FR 47528-47532) be extended by thirty days. We are making this request for several reasons.
First, the agency has proposed three different rules to grant equivalency for the inspection systems for three different countries whose comment periods all end on the same date. The proposed rules are unique and each presents different issues to address. In order for us to make substantive comments to articulate our concerns, we will need more time.
Second, it has been customary for the agency to hold sixty-day comment periods for proposed rules dealing with initial equivalency determinations, so the comment period the agency has set in this Federal Register notice is out of the ordinary.
Third, while we understand that one of the agency’s reasons for truncating the comment period was that it was under congressional direction to have completed the equivalency determination process by September 2018, the agency has already failed to meet that deadline. Furthermore, because the Socialist Republic of Vietnam will still be able to export its products to the United States pending the completion of the rulemaking process, Vietnam will not be adversely impacted by granting the public additional time to file comments.
Food & Water Watch has a long history of providing comments to equivalency determination proposed rules, and we would like adequate time to address our concerns with each one of the proposed rules that you have published. We are also submitting this request to the docket.
Thank you for your consideration.
Sincerely,
Wenonah Hauter Executive Director



10/3/18
U.S. Department of Agriculture Food Safety and Inspection Service 1400 Independence Avenue SW, Room 6065 Washington, DC 20250-3700.
Re: Docket No. FSIS-2018-0029
To Whom It May Concern:
Marques Food Distributors 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.
Marques Food Distributors is a full line food distributor. We have worked with Vietnamese Siluriformes Fish and Fish products for 10 + 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 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,
Shane Guillot Marques Food Distributors

--- Gộp bài viết, 19/10/2018, Bài cũ: 19/10/2018 ---

Trong gần 27 kiến nghị ,ý kiến thì có 2 ý kiến đến từ Việt Nam
1 từ Vĩnh Hoàn VHC
1 từ Cục quản lý chất lượng nông lâm sản và thủy sản Việt Nam

Không có ý kiến nào từ Hùng Vương ,không từ Biển ĐÔng,không từ IDI...!
Như thế để nói lên điều gì ?A e có thấy sự "chuyên nghiệp" và " không chuyên nghiệp" ở đây không?
Cái kiểu cha chung không ai khóc?hoặc nước lên thì thuyền nó lên là đây chứ đâu ?
Tâm lý này không chỉ ở ngành thủy sản mà còn rất nhiều ở ngành khác ở VN!

Hi, đúng là ỷ lại quá nhỉ.

From to Hanoi,2Tth September 20 I B

Mrs. Janell Kause Acting International Coordination Executive Office of International Coordination Food Safety and Inspection Service (FSIS)
Dear Madam, On behalf of the National Agro-Forestry and Fisheries Quality Assurance Department (NAFIQAD), under Vietnamese Ministry of Agiculture and Rural Development (MARD), I would like to express its compliments to you. I am aware that on 19 September 2078, the Federal Register published a proposed rule for public comments in 30 days to list Viet Nam as a country eligible for exporting Siluriformes fish to the United States and determine that our Siluriformes fish inspection system is equivalent to that of the United States. NAFIQAD really applauds and appreciates the professional, scientific based approach applied by FSIS in conducting document review, on-site audit and verifuing our coffective actions as well as taking into consideration of our response to the draft audit report as part of the equivalence process for Viet Nam Siluriformes fi sh inspection system. NAFIQAD commits to continue working closely with FSIS and MARD's subordinated agencies to control food safety of Siluriformes fish in line with FSIS's requirements. It would be highly appreciated if FSIS could expedite the equivalence determination process after the comment period to further promote agricultural cooperation and trade between the two countries.
Thank you for ygur cooperation./.

Nguyen Nhu Tiep
Director General of NAFIQAD

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Mấy hôm trước cầu không thấy đâu, các cụ chỉ dám rón rén chốt. Hôm nay tin tốt ra ầm ầm, cầu vào như mây, chốt đã tay các cụ ạ

--- Gộp bài viết, 19/10/2018, Bài cũ: 19/10/2018 ---

Không nhanh tay, là lại hết phần, lại phải đợi đấy

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