© [2020], NCBFAA, Washington D.C., Monday Morning eBriefing. Originally published [08/03/2020]. www.ncbfaa.orgReprinted by permission.

NCBFAA submitted comments in response to the Food and Drug Administration’s (FDA) public meeting on “Modernizing FDA’s Data Strategy.” The FDA is looking at ways to modernize how they receive data and how they use it across all areas of the agency. NCBFAA focused on the topic of “putting data to use,” particularly in the context of food safety. “Putting data to use’ is what we do,” NCBFAA President Jan Fields wrote, “Customs brokers are at the heart of the data flow to FDA for imported products. Data is the lifeblood of our work. PREDICT relies on the data that customs brokers provide on customs entries submitted through CBP’s Automated Commercial Environment (ACE) and pushed through to FDA to be screened by PREDICT.

While AI and Machine Learning can transform PREDICT into an even more potent analytical tool, the data elements transmitted by customs brokers are the basic fuel that powers PREDICT.” The NCBFAA President explained the vital role of brokers in this process: “Customs brokers are not mere conduits, passively moving data from importers to the agencies,” she explained, “We are active drivers of the data flow. We educate and instruct importers on what information is needed for a particular product to comply with FDA import requirements. We work with importers to create efficient data flows through the supply chain so we can transmit the right information at the right time.

The enormity of this undertaking should not be discounted. In 2019, customs brokers transmitted nearly 45 million lines of entry data for FDA-regulated products.” NCBFAA expressed support for the use of new and emerging technologies, such as blockchain, Artificial Intelligence and Machine Learning, all of which “have the potential to sharpen and expand FDA’s predictive analytics capabilities tremendously.”

At the same time, the association reminded FDA not to shortchange its existing infrastructure. “We cannot succeed in transforming the agency’s use of data with 21st-century technology while clinging to outdated infrastructure and procedures.” NCBFAA offered to work with the FDA as the agency moves from strategy to implementation with regard to data on imported products. “Being in the field with direct day-to-day contact with importers, customs brokers can rapidly advise on what will work and what will not, as well as help assure the accuracy of data submitted.”