U.S. Customs And Border Protection Announces Three New Members Of Commercial Targeting And Analysis Center

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[authors: J. Michael Taylor, Christina M. Markus, and Patrick J. Togni]

Participating agencies jointly target commercial imports that threaten health and safety

U.S. Customs and Border Protection (CBP) announced on April 1 that three additional Federal agencies have formally joined the Commercial Targeting and Analysis Center (CTAC). CTAC is designed to enhance the Federal government's ability to target commercial imports that pose threats to the health and safety of the American public and to address other border management goals. A key means of effectuating CTAC's goals is that personnel from all participating agencies work together at one location in Washington and also collaborate at ports around the country.

CBP explained that the U.S. Food and Drug Administration (FDA), the U.S. Fish and Wildlife Service (FWS), and the National Marine Fisheries Service (NMFS) formally joined CTAC. FDA, FWS, and NMFS will partner with eight other Federal agencies in CTAC, including CBP, the Animal and Plant Health Inspection Service, the U.S. Consumer Product Safety Commission, the U.S. Environmental Protection Agency, the Food Safety Inspection Service, U.S. Immigration and Customs Enforcement, the Pipeline and Hazardous Materials Safety Administration, and the National Oceanic and Atmospheric Administration's Office of Law Enforcement.

FDA's involvement with CTAC actually began in late 2009, when CTAC was created upon the recommendation of the Obama Administration's Food Safety Working Group, which advises the President on modifications to the U.S. food safety system in the 21st century.

FDA's involvement in CTAC has addressed multiple cases including products in the animal feed and animal drug program, biologics and vaccines, medical devices, and pharmaceuticals.

One example of FDA's previous participation in CTAC involved lasers regulated by FDA under the devices program. Through CTAC, FDA's Center for Devices and Radiological Health collaborated with CBP to stop the importation of so-called "Wicked Lasers," which FDA described as dangerously high-powered laser products that were marketed to U.S. consumers through the Internet. These products were subjected to detention without physical examination and FDA issued a warning to consumers not to use the products. Thus, FDA's recent agreement to formally join CTAC was preceded by several years of direct involvement in the program with other participating Federal agencies performing surveillance and risk analysis of imported products.

The latest CTAC expansion should increase collaboration among Federal agencies seeking to protect the American public from unsafe imports across a wide spectrum of commercial products. As a result of this latest round of expansion, CTAC will likely pursue surveillance and enforcement activities regarding food and other FDA-regulated products, as well as conservation of species and marine resources and habitat.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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