Monthly Archives

October 2012

U.S. Customs and Border Protection (CBP)U.S. Transportation Security Administration (TSA)

Keep Your Shoes ON When Going Through TSA

posted by Jennifer Diaz October 30, 2012 1 Comment

If you travel often, read on, you’ll be glad you did. When was the last time you had the ability to go through security WITH YOUR SHOES ON? Without taking out your laptop? WITH your jacket on? Without having to take out your liquids?

If this appeals to you, which it definitely did for me, you’ll be pleased to know the Transportation Security Administration (TSA) is partnering with U.S. Customs and Border Protection (CBP) for TSA Pre-Check, an initiative that allows eligible passengers to qualify for expedited screening at participating airports.

U.S. citizens, who are members of a CBP Trusted Traveler program, including Global Entry, SENTRI, and NEXUS are automatically eligible to participate and receive expedited screening benefits for domestic travel through the TSA Pre-Check initiative. TSA Pre-Check benefits include keeping shoes, light outerwear and belts on, keeping laptops in their cases, and leaving the 3-1-1 compliant liquids/gels bag in one’s carry-on during screening through TSA security checkpoints.

Members interested in participating in TSA Pre-Check through their Trusted Traveler program membership must enter their PASS ID into the ‘Known Traveler’ field when booking a flight reservation or saving their PASS ID to their airline’s frequent flyer profile. Members can find their PASS ID either online by accessing their GOES account, or on the back of their membership card in the top-left corner.

When traveling on one of the TSA Pre-Check participating airlines, CBP Trusted Traveler members should remember to provide the airline with their full name, date of birth, and PASS ID exactly as it appears in their CBP Trusted Traveler program online account to ensure they are properly considered for TSA Pre-Check.

To learn more, visit Global Entry or TSA, you’ll be glad you did!

Disclaimer, I’ve been displeased as this is not sure proof. Don’t expect it to work 100% of the time, it doesn’t… But, when it does, you’ll be ecstatic!

U.S. Customs and Border Protection (CBP)

CBP Symposium Postponed Due to Weather

posted by Jennifer Diaz October 26, 2012 0 comments

Hurricane Sandy is busy disrupting the sunshine state as well as D.C.  Breaking news from CBP, the CBP Symposium, due to start this coming Monday, is now postponed.  CBP’s message is below.  This is a great opportunity for CBP to join the C-TPAT conference with the symposium.  I hope they do.  I’ll keep you advised when the CBP symposium is back on.

Dear Registrants,

Due to concerns over participant safety and potential travel disruptions related to Hurricane Sandy, U.S. Customs and Border Protection has decided to postpone the East Coast Trade Symposium that had been scheduled for Monday and Tuesday.

We apologize for this inconvenience, but due to the strength and breadth of this storm we believe this postponement is the appropriate decision. We do not want to risk the safety of our participants, many of whom would be traveling to Washington D.C. to attend.

The nature of the storm is such that the agency’s emergency response protocols have been activated and must take precedence.

CBP will provide additional information regarding the registration for this event at a later date. The new date and location within the Washington DC Metropolitan Area for the symposium will be announced as soon as possible. CBP officials apologize for this inconvenience and will reschedule this important event in the near future.

U.S. Customs and Border Protection (CBP)

Your Chance to Meet Some of CBP’s TOP Officials

posted by Jennifer Diaz October 12, 2012 0 comments

Have you met CBP’s Chief Operating Officer, Thomas Winkowski? How about the Director of Field Operations in Miami, Vernon Foret? Or CBP’s Senior Advisor for Private Sector Engagement, Maria Luisa O’Connell?

Start thinking of what questions you have for CBP.  Assistant Commissioner Al Gina recently shared his thoughts on CBP’s Priority Trade Initiatives with NCBFAA.  See them here. The seven hot topics are:

  1. Role of the Broker;
  2. ACE,The agency’s automated cargo processing system;
  3. The Centers of Excellence and Expertise,
  4. Simplified Entry-Air Cargo Advanced Screening,
  5. Trusted trade partnerships;
  6. Trade intelligence, and
  7. One U.S. Government at the Border.

Here’s your chance to ask questions about CBP’s progress with implementation of its priorities.  I for one want to hear CBP’s progress in ensuring the Centers of Excellence are yielding a more uniform decision making process for CBP at all ports of entry.

You are invited to attend a round table discussion on U.S. Customs and Border Protection’s (CBP) trade transformation initiatives.  This meeting will provide a great opportunity to have an open discussion with Chief Operating Officer, Thomas Winkowski; Director of Field Operations (Miami) Vernon Foret; and Senior Advisor for Private Sector Engagement, Maria Luisa O’Connell.   There will be two meetings held at different times, on October 24, 2012, but will contain the same information.  

Due to limited seating, CBP requests that only ONE representative from each company sign up for one of the meetings. Your choices are:

  • Wednesday, October 24, 2012 from 10:00 – 11:00 a.m. at the Cargo Clearance Center (CCC), Conference Room 264, 6601 NW 25th Street, Miami, FL 33122.  Since space is limited, online registration is required.  Click here to register for this time slot.  RSVP’s must be in by close of business October 18, 2012
  • Wednesday, October 24, 2012 from 1:30 – 2:30 p.m. at the Cargo Clearance Center (CCC), Conference Room 264, 6601 NW 25th Street, Miami, FL 33122.  Click here to register for this time slot

You will receive a confirmation email with further details regarding the meeting.  If for some reason you need to cancel your registration, please click here.  

In addition, if you have specific questions you would like addressed during the meeting, please forward them to Phyllis Ratliff: no later than October 18th.  Please limit your response to two (2) questions.

What are your questions?  See you there?


FDA Biennial Registration is Up and Running

posted by Jennifer Diaz October 8, 2012 0 comments

Biennial Registration Renewal for Food Facilities is now available, as of October 22, 2012.

Here’s what you need to know about FDA’s new FSMA requirement on Bioterrorism Act registrations. Owners, operators, or agents in charge of domestic or foreign facilities that manufacture/process, pack, or hold food for consumption in the U.S. are required to register the facility with the FDA. 

The Food Safety Modernization Act of 2011 (FSMA) has for the first time, specifically put the onus on importers to have a program to verify that the food products they are bringing into this country are safe. The idea behind FSMA is to change FDA regulatory enforcement and focus to more of a preventative approach, instead of reactionary. These new requirements include risk-based controls, foreign supplier verification program, certification, and audits. A brief overview of the requirements may be found here.

I’ve summarized the requirements relevant to your Bioterrorism Act Registration below, so you can be sure your registration doesn’t lapse.  If your not re-registered by December 2012, FDA will cancel your Bioterrorism Act registration and your importations will be delayed.

New Biennial Registration Requirements
FSMA amended the Food, Drug & Cosmetic Act (FD&C Act) Section 415 to provide for biennial registration updates. Facilities which are required to register will have to re-register every 2 years, during the period beginning on October 1 (in this case, October 22) and ending on December 31 in even numbered years. This will first occur in October-December 2012.

Note that even facilities which are already registered with the FDA are still required to renew their registrations during the October 22– December 2012 registration renewal period.

U.S. Agent
FDA requires that foreign facilities have a U.S. agent. The U.S. agent must:

  1. live or maintain a place of business in the U.S. and
  2. be physically present in the U.S.

The U.S. Agent is also responsible for the payment of "reinspection fees" of foreign facilities and failure to comply with recall orders. Reinspections are follow-up inspections conducted by the FDA after a previous inspection by the FDA where the FDA identified non-compliance issues materially related to food safety. The purpose of the reinspection is to assure the issue has been remedied and food is now safely produced. Fees are adjusted each fiscal year. For FY 2013 (October 1, 2012-September 30, 2013), the fees are steep, at $221 an hour if no foreign travel is required, and $289 an hour if foreign travel is required.

Need a U.S. Agent?
The law firm Becker & Poliakoff, P.A. provides registration services and will act as a U.S. agent with the FDA for a nominal fee, but, the foreign facilities are always responsible for the payment of any reinspection fee or fee for a failure to comply with a recall order. Please visit for more information about how to make Becker & Poliakoff, P.A. your U.S. agent with the FDA.