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 The second approach is HACCP. The HACCP feasibility study 

 considered requiring that both importers and their foreign 

 processors operate on the basis of HACCP controls. While many 

 importers are conscientious about the safety and quality of the 

 products they import, others have little understanding of the 

 potential hazards. The occasional denial of entry of a 

 violative lot may be regarded as simply a cost of doing 

 business. The burden is on FDA to track down problems and 

 require corrections. For the same reasons as provided for 

 domestic inspections, this burden should shift. 



We are convinced that a combination of international agreements 

 and HACCP will provide much greater assurance that potential 

 hazards are safely being controlled as a matter of design than 

 the current system can ever provide. Also, the harmonization 

 of international approaches to regulating seafood safety 

 through HACCP has the dual benefit of aiding the U.S. industry 

 to compete in a global economy and to assure international 

 cooperation on hazard intervention strategies applied to all 

 seafoods. 



F. Seafood Exports 



Starting July 1, 1993, and until December 31, 1994, the 

 European Economic Community (EEC) will require that a "Health 

 Certificate" accompany each shipment of fish and fish product 



