BRASS No Longer Viable Option Under Latest Regulations
December 1, 2003
WASHINGTON, D.C. - With the implementation of the new FDA regulations requiring prior notice of imported food shipments there will be some substantial changes to clearance mechanisms currently used by...
WASHINGTON, D.C. – With the implementation of the new FDA regulations requiring prior notice of imported food shipments there will be some substantial changes to clearance mechanisms currently used by shipper, carriers and brokers to ensure that formal entries of food can be made under FDA and Customs and Border Protection (CBP) regulations.
One of the primary clearance programs that will be affected by the new regulations will be the “line release” program known as BRASS (Border Release Advanced Screening and Selectivity) – food shipments crossing the border on the BRASS program currently represent about 50 per cent of the food volume.
It is imperative that carriers understand that the BRASS program will no longer be a viable option for clearing food shipments at the border once the new regulations come into effect on Dec.12, 2003.
This means that for a large number of carriers and shippers there will be a significant change in the way in which they deal with paperwork associated with cross-border movements.
With the elimination of BRASS, carriers moving food into the United States will have to explore other clearance options that have prior notice capabilities.
One clearance option already in use by a number of carriers that has prior notice capabilities is the Pre-Arrival Processing System (PAPS).
Under the new FDA rules the primary clearance program for submitting prior notice of shipments will be PAPS, unless the carrier/shipper have made alternate arrangements with their US broker to submit the required information.
If carriers are moving food product into the U.S. and wish to utilize PAPS they should consider contacting the shipper and US broker to ensure that PAPS will be a viable option for sending prior notice.
It is also very important for carriers to consider working with their shippers and U.S. brokers to determine that the brokers have evaluated participation in the FDA program known as “paperless” OASIS.
FDA categorizes brokers in two ways with regards to the OASIS program: those that are “paperless” and those that are “dual mode filers.”
“Paperless” brokers who receive an electronic “May Proceed” on an entry, need not submit any additional information to FDA, and the entry is released.
Carriers and shippers who use brokers that are FDA certified “paperless” OASIS participants will significantly increase their ability to clear shipments at the US primary inspection booths and continue on to their US destinations.
“Paperless” brokers must also supply paperwork to FDA if the shipment entry receives an electronic FDA review, and the broker does not electronically transmit quantity and value for the entry.
“Dual mode” filers must first submit electronic information to FDA and then are required to submit paper copies of the shipping documents and Customs invoices in order for FDA to verify the electronic data.
The process in the “dual mode” requires that the driver park the truck after CBP primary and take the paperwork to the broker, who in turn refers them to FDA and CBP for proper release of the shipment.
Carriers/shippers who use U.S. brokers who are not “paperless” OASIS certified will experience significantly longer border transit times than those who use “paperless” OASIS US brokers.
Carriers/shippers are encouraged to work with their U.S. brokers to ensure the benefits of “paperless” OASIS are examined so as to ensure their food shipments move across the border as efficiently as possible.
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