Import establishments may request that meat and poultry products be pre-stamped with the official marks of inspection prior to the completion of the assigned type of inspection (TOI), including controlling stamping of “SKIPPED” lots. 9 CFR 327.10(d) and 381.204(f) provide import establishments with the option to stamp product without continuous supervision by import inspection personnel.

Part2, Section1 "Pre-Stamping of Imported Product," dated 11/15/03

Import establishments desiring pre-stamping privileges shall submit an original letter on their company letterhead
to the Regional Import Field Supervisor (RIFS) who in turn will provide a copy to the Import Inspection Division
(IID) Director. The IID Director will prepare a response letter for the supervisor’s signature based on the final
decision to approve or deny the request. The Regional Import Field office (RIFO) will file a copy of the request
letter and the response letter in the appropriate import establishment file, which will indicate approval or disapproval
of the request.

 The written procedure for pre-stamping should be in the form of a letter and shall include the following information:

1. Identify the establishment official(s) who will ensure compliance with the provisions listed in section IV (Provisions for Pre-Stamping) of this document.

2. Indicate that pre-stamping will be limited to lots which will be reinspected on the day of stamping;

3. Describe the control procedures for removing or obliterating marks of inspection of any pre-stamped lot which subsequently fails reinspection;

4. Indicate that all pre-stamped product will be stored in the establishment where the reinspection will occur; and,

5. Indicate that the establishment will maintain a daily log and that the log will be presented to FSIS inspection program personnel at the end of each work day. The log must contain the following:

   1. Date the lot was pre-stamped/reinspected,

   2. Country of origin,

   3. Foreign establishment number,

   4. Name of product,

   5. Number of units,

   6. Shipping mark,

   7. Foreign health certificate number and Lot number from FSIS Form 9540-1, and

   8. Location of incubated lots in the import establishment where the pre-stamped product is being stored.

Once approved or disapproved by the RIFS, the RIFO will forward the original letter of request back to the
requesting import establishment along with the original response letter. Further, the RIFO shall provide
copies of the request and response letters to import inspection personnel at the import establishment, and
copies to the Import Inspection Division Director and the Deputy Director of Operations (DDO). Import
inspection personnel shall maintain the letters in the inspector’s office.

The RIFO and inspection personnel shall verify that the plant profile in the PBIS system includes the
04B04 procedure for label verification for General Labeling and/or Pre-stamping.

4. PROVISIONS FOR PRE-STAMPING

   1. All lots are eligible for pre-stamping except those lots placed on "Intensified" because of a failed TOI, or those on “Voluntary Hold” at the importers request.

   2. Pre-stamped lots must have all physical TOI(s) completed on the day of stamping. (Currently, the only exceptions are Incubated lots and SIFT).

   3. Import establishments choose which lots will be pre-stamped. However, lots shall not be pre-stamped until they have been examined for general condition, count, document/product verification, and label verification by import inspection personnel.

   4. Lots shall be pre-stamped in the staging area.

   5. Lots must have the marks of inspection obliterated or removed on the day of rejection. The obliteration/removal process shall occur in the staging area.

   6. Pre-stamped lots shall not be removed from the establishment until the reinspection is complete.

   7. The import establishment shall:

      1. Advise import inspection personnel at the time the lot is staged that the lot will be pre-stamped;

      2. Apply the marks of inspection in a manner that such markings are legible and do not interfere with other container markings; and

      3. Maintain a daily log containing the information stated in III.E (Obtaining Approval for Pre-Stamping) of this section and present it to import inspection personnel for review at the end of each work day.

   8. The Regional Import Field Supervisor shall develop and implement a systematic plan to have import
      inspection personnel examine pre-stamped lots to ensure they are properly stamped.

   9. Import inspection personnel shall:

      1. Know the assigned TOI(s) prior to allowing the lot to be pre-stamped;

      2. Verify that the establishment maintains the provisions for pre-stamping per 9 CFR 327.10(d) or 381.204(f) through PBIS scheduled or unscheduled procedures.

      3. When required, issue FSIS Form 5400-4, Non-Compliance Record (NR) under PBIS procedure code 04B04 for General Labeling as it relates to verification of other consumer protection (OCP) regulatory requirements.

Examples of when an NR may be issued documenting an establishment’s failure to comply with pre-stamping requirements are when:

(a) the establishment fails to maintain pre-stamp records accordingly;
(b) the establishment pre-stamps ineligible product; or,
(c) the stamps are improperly applied to containers (over other markings, illegible,
not readable, etc.)
 

5. SUSPENSION OF PRE-STAMPING PRIVILEGES

   1. An establishment's pre-stamping privileges may be suspended by the import inspector orally and followed up by issuing a NR no later than the end of the day whenever inspection personnel find that the establishment has failed to comply with the provisions of 9 CFR 327.10(d), 327.26 or 381.204(f) or any conditions pursuant thereto. The import inspector shall enter this information into PBIS and ensure that synchronization has taken place.

   2. Inspection personnel shall notify the Regional Import Field Supervisor at the time of the suspension by phone and indicate that the information has been entered into PBIS and that synchronization has taken place enabling supervisory review, if necessary.

6. APPEALS

   1. Any establishment whose pre-stamping privilege has been suspended may appeal the decision, with all of the facts and reasons of wrongful suspension, to the import inspector within 3 days after receiving the NR.

   2. After meeting with establishment management concerning the appeal of the suspension, the import inspector will enter the appeal information into the PBIS.

   3. If the establishment still feels that the pre-stamping privileges were wrongfully suspended, they shall notify the Regional Import Field Supervisor in writing within 7 days after meeting with the import inspector regarding the appeal of the suspension.

   4. The appeal shall state all of the facts and reasons upon which the person relies to show that the pre-stamping privilege was wrongfully suspended.

   5. The Regional Import Field Supervisor will notify the Deputy Director-Operations of the appeal and they will jointly review the circumstances surrounding the suspension and will also review the import inspector’s data entered into the PBIS before rendering a decision.

   6. If a decision still cannot be made to uphold or grant the appeal of the suspension, the establishment may request that the appeal be forwarded to the next level for review, which would be the IID Director.

   7. The suspension of pre-stamping privileges will remain in effect until there is a final determination.
       

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