Issue 329, November 30, 2001
On November 27th, Commissioner Bonner made an appeal to the trade to craft proposals on tightening supply-chain security. The appeal responds to fears relating to the perceived possibility of terrorist weaponry being introduced into the U.S. via the commercial cargo system. The Commissioner promised that importers who develop secure supply chains will be rewarded with "the fast lane through seaports and our land borders." This initiative coincides with the U.S. Congress" consideration of the pending Port Security Measures - S.1214 (Senate) and the companion bill, H. 3013 (House Subcommittee on Coast Guard & Maritime Transportation.)

Containerized cargo may pass through as many as sixty (60) different handlers from the point of origin to destination. At each handling point, the cargo is potentially vulnerable to insertion of contraband, including chemical, biological or nuclear weaponry. For example, terrorism was suspected when, on October 18th, an Egyptian national was found inside a shipping container being transshipped through Italy destined for Canada. Customs is calling on the trade to provide a means of assuring security on its containers.

Customs' officials pointed to several existing programs from which to model an initial framework for supply-chain security. The Carrier Initiative Program (CIP), Super Carrier Initiative Program and the Business Anti-Smuggling Coalition (BASC) are being looked to as examples. Under these programs, U.S. Customs and carrier companies, under signed agreements, cooperate to prevent commercial conveyances from being used to smuggle narcotics. These programs are likely to be expanded to embrace broader cargo-security issues. Furthermore, importers are being encouraged to get their carriers to participate in these programs.

There is no set program an importer or exporter must undertake to participate in a new cargo-security program. However, it is clear that companies will need to have a written supply-chain security program, which is both followed and enforced. Key elements of this cargo-security policy must likely include:

	An employee policy manual.
	Employee identification procedures (photos, color coded, visible at all times, etc.)
	Training of personnel to identify suspect shipments, and incentives for reporting such activity
	Procedures for reporting the discovery of contraband, diversions, suspicious shipments, etc.
	Facility security at both points of origin (i.e., the foreign factory) and destination (distribution center)
	Limited access to shipping/receiving areas.
	Sealing, locking, and securing all loaded trailer/containers as well as limited access to, control over, and inspection of all empty and stuffed conveyances, containers, chassis, etc.
	Use of newer, high-technology seals (electronic and advance algorithmic seals).
	Systematic tracking of shipments (GPS transponders, etc.).
	Procedures for controlling/processing documentation.
	Time controls for preparing documentations, movement of shipments, unloading shipment, etc.
	A policy requiring signatures for the following transactions: paperwork preparation, affixing of seals, breaking of seals, physical piece counts, trailer inspections, driver checklists.
	Cargo-Security agreements with other business partners requiring similar security measures.

Comments and suggestions on cargo security can be forwarded to Customs at symposium2001.feedback@customs.treas.gov.

Our contributing writer, David M. Murphy, works for Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP in New York City and can be reached at dmurphy@gdlsk.com.

Please note that due to the complex nature of the subject matter, DHL Danzas Air & Ocean cannot be responsible for actions taken by the reader in reliance on the information contained herein without prior consultation with DHL Danzas Air & Ocean.