GlobalCompliancePanel, a leading provider of professional training for all the areas of regulatory compliance, is organizing a two-day, in person, live seminar on the topic, “FDA and U.S. Customs Import Rules and Export Traps in 2020”, on December 4 and 5.
Casper Uldriks, an ex-FDA Expert and former Associate Center Director of CDRH, will be the Director of this seminar. Please enroll for this session by visiting https://www.globalcompliancepanel.com/seminar/tougher-import-rules-for-FDA-901966SEMINAR
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Smarter, more sophisticated, more agile and more demanding. These are what the FDA and the Customs and Border Patrol Service (CBP) have become of late when it comes to their expectations and requirements from importing firms of the submission of information and adherence to government procedures. Firms that fail to properly execute an import and export program can expect the FDA and the CBP to delay, detain or refuse their shipments.
The new Automated Commercial Environment (ACE) computer program from the CBP has brought in many changes to the process of import logistics and information reporting for FDA regulated products. As a result, companies that do not comply with the requirements set out in the ACE program can experience one of the worst nightmares they can think of: having their shipment stopped before it is even loaded at the foreign port! And then, if they refuse to or fail to use the ACE program, such ships also carry a fine of up to $10,000 for every offense.
There is more: such companies whose products the FDA detains face a cumbersome, long winding and expensive legal process. The FDA expects companies to have the import coding information accurate and up-to-date. Any company that lacks a thorough and clear understanding of the automated and human review process are almost certain to have their shipments detained.
And then, what happens in a scenario in which the FDA decides that importers should bring the products back to the port of entry after they received a release but cannot locate the product that has been sold? Well, in such instances, such companies are slapped a fine that is three times the value of the shipment, not to speak of the additional adverse legal concerns and strategies that come along.
What do all these mean? Simple: if you are an importer, you are doomed if you fail to comply with the FDA’s guidelines on imports.
Yet, there is a way out of this quagmire, in the form of the Voluntary Qualification Importer Program, which the FDA is implementing under the FDA Food Safety and Modernization Act. This plan seeks to reward importers who demonstrate a level of confidence about the quality of food they import by establishing an FDA-supervised, fee-based program. What this program does is that it facilitates the review and importation of foods from importers who establish a higher level of control over the safety and supply chain aspects of the imported food items.
And then, there is also the extra perk that the FDA offers: its export certificates. Offered at a reasonable fee; these certificates can go a long way in giving an importer a competitive advantage in foreign markets. In fact, a few foreign governments make an FDA export certificate a requirement.
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The aim of this seminar is to offer learning on all these core areas of the FDA and US Customs Import Rules in 2020. The Director will explain how to deal with common problems, such as returns for repair, importing QC samples, and investigational products. The learning will be taught over the following agenda:
Day 1 Schedule
Lecture 1:
FDA Legal Authority Customs and Border Control (CBP) Import Process FDA Import Process Registration and documentation
Lecture 2:
FDA Import Process (continued)
- Import Brokers
- Prior Notice Information
- CBP and FDA computer programs
- Import Codes
- Bonds and Bonded Warehouses
- FDA “Notice of Action”
Lecture 3:
Import Delays Import Alerts Detention Refusals
Day 2 Schedule
Lecture 1:
Foreign Inspections FDA 483 – Inspectional Observations
Lecture 2:
FDA Warning Letters and Automatic detention
Lecture 3:
Import Hypothetical FDA Import for Export Program FDA Export Program Export Hypothetical
Lecture 4:
FDA Export Program Special Import Issues
- Trade Shows
- Personal Use
- Compassionate Use
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https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/ucm448728.htm
This is going to likely impact these important nodal cities of the global economy to the extent that the world’s GDP is going to shrink by as much as 1.5% percent till 2019. This translates to something in the order of $ 1.2 trillion.
All these factors would not have had the same impact as they are likely to have in the current scenario and in the immediate and intermediate future, if not for globalization. The world’s shift towards globalization is now certain and irreversible. The interconnected nature of the 
The primary driver of this metamorphosis is risk management. Risk management and analysis for medical device manufacturers has been the lynchpin among the agents of change brought about into this field. Quality has evolved as a result of the change in the import regime in the US in the seventies, when products from around the world used to deluge the US market.
In the context of medical devices, risk management and analysis for medical device manufacturers means applying a set of processes, policies, methods and practices into their manufacturing systems in alignment with respective and relevant standards as set out by global standards such as the ISO. The aim of these standards and practices is to analyze, assess, control and monitor risk. The ISO 14971 has been revised many times and each time this is done, the latest one becomes the extant version. This and other standards and practices prescribe steps and processes that need to be implemented at all stages of the product lifecycle.
Risk management and analysis for medical device manufacturers is to be carried throughout the lifecycle of the medical device. A set purpose is set out at each stage of the manufacturing process. For example, medical device manufacturers are required to identify and eliminate potential hazards at the initial stage using the concepts of product optimization, and use the principles of risk elimination at all the next stages, and to use the methods prescribed during a product recall.
It needs to be understood that risk management is a set of processes that need to be implemented extremely stringently and diligently at every possible stage. Risk management is a journey, not a destination. For the benefits of 
Yet, even though the dynamics of risk management are different across all industries and are unique to each of them; the benefits of risk management in all industries are there to be felt and experienced.
In order to realize the benefits of risk management in all industries fully, risk managers need to be on their guard all the time. This is obvious and goes without saying, but in the light of the fact that some risks can become enormous and uncontrollable at later stages, it is best for 
The answer to the question of how risk management is important to project success has to start with a basic understanding of risk. In the context of 
In order to manage a project successfully, the first step is carrying out 
Planning:This involves understanding the importance of risk management to project success by planning the risk management in terms of its size. It is generally true that the bigger the project from the operational, logistical and financial perspectives; the greater the risk, and vice versa.
Measuring the result: Judicious and farsighted project managers measure the fallout of a risk management activity by what it fetches. If a risk management activity has accrued a certain expense that cannot be justified in the light of the benefit it brought, then such a risk management action is not effective and has not understood the importance of risk management to project success.
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