NCC did note, however, that the proposed rule requires some additional clarifications and refinements. For example, the comments:

• Highlight the cost and time associated with label approval as well as requesting clarification on the definition of "special statements or claims" to reflect the discussion in the preamble of the proposed rule;
  
  
• Ask that FSIS extend generic approval to certain types of temporary approvals and to label approvals based on temporary labels; and
  
  
• Request that the agency clarify the inspector’s role, with a specific emphasis on ensuring any enforcement action be appropriately commensurate with the type of technical violation that would result from incorrect application of generic approval regulations and not be overly invasive into the production process.

"NCC supports efforts to reform the FSIS label approval process by expanding generic approval," the comments conclude. "The label approval process is in dire need of reform, and the principle announced in the preamble—reserving agency resources for reviewing only labels presenting difficult public health or policy issues—would create a workable, realistic framework for this reform. Clarity as to requirements and appropriate roles will be crucial to enacting meaningful reform, though, and NCC urges the agency to incorporate these recommendations into a final rule on generic label approval."