New Import Safety Group Publishes Strategic Framework

The Interagency Working Group on Import Safety was established by Executive Order on July 18, 2007, to conduct a comprehensive review of current import safety practices and identify actions to promote, improve and enforce safety standards on imported products. The establishment of this group was prompted by the recent dangers found in some toys, pet food ingredients and seafood; however, the working group is also concerned with the safety of all imported food, health products, tires, toys and other products. Chaired by the Department of Health and Human Services’ Secretary Michael O. Leavitt, the working group is comprised of officials from 12 federal agencies with responsibilities related to import safety.

The group’s first order of business was to review the current safety processes and procedures and identify some of the current industry best practices. The result was a 22-page preliminary report issued on September 10 that introduced a strategic framework outlining the steps necessary to implement cost efficient risk-based approach to improve the safety of imported products.

The report begins by summarizing import statistics and providing background information. Next, an analysis of the existing conditions resulted in list of deficiencies and challenges which include: obtaining comprehensive information to address import safety, coordination of safety and security measures, acquiring additional authorities to address and implement effective safety measures, obtaining adequate product information, and creation of systems to share information between federal and state systems and addressing circumvention to avoid U.S. restrictions on certain goods. From this analysis, the group formulated three organizing principles and the implementation for the Strategic Framework. The principles of the Strategic Framework consist of prevention, intervention and response. The report advises implementing these principles through six “building blocks” that include:

· Advance a Common Vision
· Increase Accountability, Enforcement and Deterrence
· Focus on Risks Over the Life Cycle of an Imported Product
· Build Interoperable Systems
· Foster a Culture of Collaboration
· Promote Technological Innovation and New Science

The initial provisions of the Strategic Framework proposed by the Working Group are similar to the principles of C-TPAT, which require a shift from the reliance on individual inspections to a risk-based program where importers certify that their supply chain uses the best practices and CBP validates this through random inspections. Like C-TPAT, this risk-based program will help ensure that safety is built into the processes and products throughout the supply chain from point of manufacture in the foreign country to point of delivery in the U.S.

As a result of the initial report, the Working Group has two events currently on the agenda: a public meeting in October and the publication of an action plan in November. Stay tuned to this blog and the agency’s web site for new developments from the Working Group on Import Safety.