FDA inspector’s time Sample Clauses
FDA inspector’s time. The proposed rule would require us to confirm that the owner or consignee affixes the label to the refused food import or otherwise complies with the label requirement.3 We estimate that this process would require approximately 30 minutes per shipment. We estimate the value of an FDA inspector’s time based on a GS–10, step 5 rate, plus 30 percent in benefits. At this hourly rate, FDA’s labor costs for each shipment would be $15 (0.5 hours x $30 per hour). We request comment on these estimates. TABLE 4.—MEAN ANNUAL LABELING COST ESTIMATES cost of labeling these shipments would be nearly $195 thousand in labor costs and nearly $46 thousand for labels. It would cost the government more than $55 thousand to confirm the labels had been affixed. The sum of these costs is about $296 thousand. The static annual
1 There are many reasons a shipment may be initially refused and subsequently released. For example, a violative shipment may be
2 Given a 1 percent inspection rate, an importer has a 99 percent chance of getting violative shipment into the United States. One out of every 100 shipments gets caught. Without this rule, the odds of getting into the next port, given a refusal, are roughly the same as the first port. So if an importer plans to port shop a violative shipment at least once, they have a 99.9999 percent chance to successfully get the shipment into the United States. Therefore this proposed rule increases the risk of getting caught when shipping a violative reconditioned successfully, samples of food suspected to be in violation may test negative, or paperwork, originally insufficient, might be corrected. shipment by a factor of 100 for those that plan on port shopping. FDA believes this would yield a heavy enough disincentive to warrant the use of 25 to 75 percent in an ‘‘if-then’’ scenario. 3 There are several ways of verifying that the label has been affixed. For the purpose of this analysis, our estimates are based on a scenario where FDA inspectors supervise the labeling of refused food. TABLE 4.—MEAN ANNUAL LABELING COST ESTIMATES—Continued Static Dynamic Owner/Consignee Labor Cost per Re- fusal $53 $53 Total Owner/Con- signee Labor Cost $194,616 $96,142 Label Cost per Re- fusal $12.50 $12.50 Total Label Cost $45,900 $22,675 Total Owner/Con- signee Cost $240,516 $118,817 Total Annual Cost $295,609 $146,040 TABLE 5.—FIXED LABELING COSTS Number of Ports 132 Label Guns Needed per Port of Entry 3 Cost per Label Gun $100 Total Label Gun Costs $39,60...
