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How safe is that drink?Ensuring product integrity from
manufacture through consumption
William H. FosterAssistant Administrator, Headquarters Operations
March 11, 2008
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…a global issue
…Progress will require that we work collaboratively, partner with the importing community and state and local government, and reach out to foreign producers, exporters and governments. By doing so, all involved will…benefit from an abundant and safe marketplace.
--Michael O. Leavitt, Secretary, Health and Human Services “Action Plan for Import Safety” November 2007
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…requires a global solution
“snap shot” vs. “video”6 building blocks – Common vision Increased accountability, enforcement and
deterrence Focus on risks over product life cycle Interoperable systems Culture of collaboration Technological innovation and new science
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Strategic framework
PreventionInterventionResponse
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Prevention
Prevent harm in the first place
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TTB Mission -- Prevention
Collect alcohol and tobacco excise taxes.
Ensure that these products are labeled, advertised, and marketed in accordance with the law.
Administer the laws and regulations in a manner that protects the consumer and the revenue, and promotes voluntary compliance.
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Role of Food and Drug Administration (FDA)
Approval of ingredients for food products
Bioterrorism Act of 2002Key Provisions: Food facility registration Prior notice of importation Establishment and Maintenance of Records Administrative Detention of Food
For more information go to: http://www.fda.gov/oc/bioterrorism/bioact.html.
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TTB Statutory Authority
Internal Revenue Code (26 U.S.C.): Chapter 51 (Distilled Spirits, Wine and
Beer) and 27 CFR parts 19, 24, and 25
Federal Alcohol Administration Act(27 U.S.C. Chapter 8) 27 CFR parts 1, 4, 5, 7, and 16
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Prevention in accordance with IRC …
Classification of alcohol products for excise tax purposes.
Methods of operation for distilleries, wineries, breweries, industrial alcohol producers and users, and importers and exporters.
Regulation of the operations of distilleries, wineries, brewers.
Regulation of the production, packaging, bottling, labeling, and storage requirements related to alcohol beverages.
Issuance of permits and regulation of the operations for importers.
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Federal Alcohol Administration Act (FAA Act)…an ounce of prevention
Provisions that ensure the integrity of the industry:
Require a permit for those who engage in the business as a producer, importer, or wholesaler;
Issue, suspend, and revoke permits; Screen permit applicants to prevent persons
not likely to comply with the law from entering the trade, including organized crime and terrorists.
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FAA Act…prevention, another ounce
Provisions that ensure the integrity of the product:
Require that importers and bottlers of most alcohol beverages obtain a certificate of label approval (COLA) before selling product in interstate commerce.
Prevent misleading labeling and advertising that may result consumer deception regarding the product.
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Intervention
Intervene when risks are identified
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Intervention– TTB Consumer Protection Programs
Product Safety Alcohol Beverage Formulas Alcohol Beverage Sampling
Program Consumer Complaints
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Response
Respond rapidly after harm has occurredIn the event that an unsafe product makes its way into domestic commerce, swift action must be taken to limit potential exposure and harm to the American public.
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Consumer Protection Programs, continued
Verification of Label Claims Label Fraud Investigations Lab Viticultural and Varietal
Authentication Program
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Producers and importers
…bear responsibility for food safety—use wholesome ingredients, produce with best practices, distribute responsibly
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Summary
Government program keystones Prevention Intervention Response
Producer responsibilities Responsible and accountable
practices
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Questions?
www.ttb.gov