Protecting American Consumers Every Step of the Way: A strategic framework for continual improvement in import safety

INTRODUCTION: On July 18, 2007, President Bush issued Executive Order 13439, establishing an Interagency Working Group on Import Safety (Working Group). The Working Group, chaired by Health and Human Services Secretary Michael O. Leavitt, is comprised of senior officials from 12 federal departments and agencies, each with unique and critical import safety responsibilities. This Executive Order and call for review was prompted by the recent dangers found in some imported apparel, pet food ingredients, toys, seafood, and other products.

Ship with cargo The Executive Order defines the Working Group’s mission as: (1) reviewing or assessing current procedures and methods aimed at ensuring the safety of products exported to the United States, including existing cooperation with foreign governments, foreign manufacturers, and others in the exporting country’s private sector, (2) identifying potential means to promote all appropriate steps by producers and the U.S. importing community to enhance the safety of imported products, and (3) surveying authorities and practices of federal, state, and local government agencies regarding the safety of imports to identify best practices and enhance coordination among agencies.

The U.S. import system faces challenges from a changing world that are driven in large part by consumer demand.  The volume and value of U.S. imports continues to grow due to the increasing demand by American consumers for goods that come from access to global markets, including goods that are only available from such markets, such as the year-round availability of seasonal fruits and vegetables.

Americans must be able to purchase goods with confidence in the safety of, and knowledge of the risks posed by, the product, whether the product is from a domestic source or imported.  Incidents over the past several months, however, have highlighted the need for our present import system to keep pace with this changing world and to continue meeting the expectations of the American people. 

These incidents are not simply signaling the need for additional resources and authorities, although additional resources and authorities may be needed and may be recommended by the Working Group after public input is received. Rather, these incidents are telling us that aspects of our present import system must be strengthened to promote security, safety, and trade for the benefit of American consumers.

The Strategic Framework presents a new import safety strategy that emphasizes a cost-effective, risk-based approach.  It is a strategy that considers risks at the points they are most likely to occur, and then targets the application of controls to those critical points to minimize the likelihood of unsafe products reaching U.S. consumers. ...

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A Report to the President
Interagency Working Group on Import Safety
September 10, 2007

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Table of Contents
I. Introduction .......................................................... 2
II. Background .......................................................... 4
III. Existing Environment ......................................... 6
IV. Strategic Framework .......................................... 11
V. Conclusion .......................................................... 22

Conclusion

The benefits of international trade are wide-ranging, yet these benefits bring with them new and complex challenges.   Although they are of great value to the American consumer, the increasing volume of imports entering the United States creates an urgent need for a new, forward-looking Strategic Framework for import safety that considers risks over the life cycle of an imported product and focuses actions and resources to minimize the likelihood of unsafe products reaching U.S. consumers.

This will require shifting from the current model that relies on “snapshots” at the border to interdict unsafe products to a cost-effective, prevention-focused “video” model that identifies and targets those steps in the import life cycle where the risks of unsafe products is greatest and verifies the safety of products at those important phases. Such a risk-based, prevention-focused model will help ensure that safety is built into products before they reach our borders. 

Recognizing that some risk will always remain, and that it is impossible to inspect our way to safety given the increasing volume of products entering the United States, a major component of the Strategic Framework is identifying means for increasing cooperation with foreign governments, foreign manufacturers, importers, and others to ensure that the private sector takes a leading role in effectively and efficiently strengthening the safety of imports both now and in the future.

Adopting a forward-looking approach to import safety will require us to find new ways to gather, aggregate, integrate, analyze, communicate, and act upon information about imports from across the import life cycle.  As such, the Working Group recommends a Strategic Framework based on the organizing principles of Prevention (prevent harm in the first place), Intervention (intervene when risks are identified), and Response (respond rapidly after harm has occurred).

Supporting these keystones of the Strategic Framework are six building blocks: 1) Advance a Common Vision, 2) Increase Accountability and Enforcement, 3) Focus on Risks Over the Life Cycle of an Imported Product, 4) Build Interoperable Systems, 5) Foster a Culture of Collaboration, and 6) Promote Technological Innovation and New Science.

Americans properly have high expectations for the safety of the foods they eat and the products they use.  This Strategic Framework, when coupled with the forthcoming Action Plan, will ensure that as the global economy expands, public and private sector actors will be working to continue to meet the expectations of the American consumer -- not just today, but for years to come.

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