Overview
Title
Agency Information Collection Activities; Proposed Collection; Comment Request; National Agriculture and Food Defense Strategy Survey
Agencies
ELI5 AI
The FDA wants to ask certain groups questions about how they keep our food safe from bad things. They're looking for people's thoughts on this plan before they start asking questions to help make sure it's a good idea.
Summary AI
The Food and Drug Administration (FDA) is seeking public comments on a proposed information collection for the National Agriculture and Food Defense Strategy Survey. This survey, conducted under the FDA Food Safety Modernization Act, aims to gather information from state, local, territorial, and tribal agencies on their food defense activities against intentional contamination and emerging threats. The collected data will be used in a report to Congress to assess progress in food defense. The process includes electronic and written submissions, with guidelines provided to protect confidential information.
Abstract
The Food and Drug Administration (FDA or Agency) is announcing an opportunity for public comment on the proposed collection of certain information by the Agency. Under the Paperwork Reduction Act of 1995 (PRA), Federal Agencies are required to publish notice in the Federal Register concerning each proposed collection of information, including each proposed extension of an existing collection of information, and to allow 60 days for public comment in response to the notice. This notice solicits comments on the information collection requirements for a voluntary survey for the Department of Health and Human Services (HHS), the U.S. Department of Agriculture (USDA), and the Department of Homeland Security (DHS), which will inform the FDA Food Safety Modernization Act (FSMA), National Agriculture and Food Defense Strategy (NAFDS) Report to Congress. The proposed survey will be used to determine what food defense activities, if any, State, local, territorial, and/or tribal (SLTT) agencies have completed to date. The information will be compared to the initial baseline data collected by State(s) in 2018.
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AnalysisAI
Summary of the Document
The document is a notice from the Food and Drug Administration (FDA) seeking public comments on a proposed survey related to the National Agriculture and Food Defense Strategy (NAFDS). This survey aims to gather information from state, local, territorial, and tribal (SLTT) agencies regarding their activities in protecting food supplies from intentional contamination and new threats. The data collected will contribute to the FDA's report to Congress, mandated by the FDA Food Safety Modernization Act (FSMA). The survey is voluntary, and the notice details how respondents can submit their feedback either electronically or through written submissions.
Significant Issues and Concerns
One concern with the document is the lack of explicit detail regarding the potential impact or benefits of the proposed survey. It does not clearly outline how the results will specifically influence the NAFDS or improve food safety protocols. This lack of clarity makes it difficult to assess whether the resources and effort required for the survey are justified.
Furthermore, the document employs complex legal language with references to various statutes and regulations. This could pose challenges for non-expert stakeholders in interpreting the document and providing informed comments. Additionally, the increase in the estimated burden hours and respondent numbers is noted without offering detailed explanations or justifications.
The document describes a "purposive sampling strategy" but does not elaborate on what this entails or how it ensures the survey results are comprehensive and representative. This ambiguity may deter effective participation.
Impact on the Public
Broadly speaking, the document has implications for public health and safety by aiming to improve food defense strategies against threats. However, its effectiveness in achieving these goals is contingent on how well it engages stakeholders and incorporates their feedback.
For the general public, this process highlights ongoing efforts to enhance food safety, although the technical nature of the document might limit public engagement. The absence of accessible information might present challenges in understanding the objectives and importance of the survey.
Impact on Specific Stakeholders
State, local, territorial, and tribal agencies are directly impacted, as they are expected to participate in the survey. The document may positively provide these agencies with a platform to highlight their current food defense activities. However, without clear guidance or illustrative examples of the feedback sought, these stakeholders might find it challenging to contribute effectively.
The document also implies significant administrative work for these agencies, given the noted increase in burden hours. This could strain resources, especially in smaller or underfunded jurisdictions, unless adequate support or incentives are provided.
In summary, while the proposed survey has the potential to advance food defense strategies significantly, the document would benefit from clearer communication of its aims and processes. Enhanced transparency and guidance might facilitate better stakeholder engagement and more meaningful contributions to national food safety efforts.
Issues
• The document does not explicitly explain the potential impact or benefits of the proposed survey, making it difficult to assess if spending is justified.
• There is a lack of clarity on how the survey results will specifically influence or improve the National Agriculture and Food Defense Strategy and subsequent actions.
• The document uses complex language and legal references, such as multiple CFR and U.S.C sections, which could be challenging for non-expert stakeholders to understand.
• The document mentions an increase in burden hours and respondents without providing a detailed justification or explanation for these increases.
• There is ambiguity around what 'purposive sampling strategy' entails and how it will ensure that the survey results are representative and useful.
• The document outlines that comments will be posted publicly unless they are marked confidential, but it lacks detailed guidance on how individuals can effectively classify information as confidential.
• While the document requests comments on several aspects of the information collection, it does not provide examples or prompts to guide stakeholders on what specifically the agency is interested in receiving feedback on.
• The document does not provide clear information on how the survey’s methodology aligns with the broader goals of food safety and defense enhancement.