28 February 2002

The following article is excerpted from the 28 February 2002 on-line edition of "The Journal of Commerce".

Every container is a possible bomb, every vessel, plane, railcar and truck a possible delivery device and every port a possible target! That's the threat which continues to circulate on Capital Hill. Homeland Security has been tasked by the White House to take the lead in addressing this national security issue. However, as with any effort as massive as this undertaking, those most affected - companies in the international supply chain - will have to wait for some time for anything concrete to be finalized. In the meantime, no one wants to sit idly by and wait. International traders want to shore up their supply chains now!

Moving to the forefront, the United States Customs Service quickly adopted the recommendations of the Customs Oversight Advisory Committee (COAC), a group of 20 private sector individuals who advise the Treasury Department about Customs issues. Appointees serve a two-year term.

In November 2001, Treasury Under Secretary of Enforcement James Grulle approached COAC asking for quick but solid advice about best practices for companies wanting to protect their cargo and how that process could be improved in light of the events of Sept. 11. To respond, COAC created a special sub-committee which then reached out further to the private sector. Anyone who wanted to participate was given a seat at the table. About 50 individuals representing all sectors of the trade community responded. Although the focus was on imports, exports were discussed in depth.

The end product of the COAC's efforts was produced in a remarkably short 40 business days and consisted of recommendations in a wide variety of disciplines. [JoC Online readers can obtain a copy of rthe report from Susan Kohn Ross by e-mailing [email protected].] COAC's sub-committee divided itself into working groups: Production and Manufacturing; Transportation and Distribution, and Import/Data Exchange. As deliberations proceeded, it was also decided to add a Technology group which continues its work even today. While each group met independently, the recommendations were remarkably similar, quoting from the Executive Summary:

Cooperative Effort. The security initiatives must be a vehicle that is sensitive to the competitiveness of the United States. We are pleased that both Treasury and Customs, from the outset, have recognized a dialogue with the trade was critical to devising a system that would attack the security issue while preserving the needs of modern-day international trade imperatives. This dialogue should continue.

Flexible Guidelines. The security initiatives should be flexible to fit differing industries and their existing security systems. The government should not devise a new protocol for all companies to meet. There is no one system that can work for all. More significantly, many companies have in place effective (and expensive) security, anti-theft and anti-smuggling procedures capable of meeting the new security challenges. In many instances, companies may only need more education about the indicia of terrorist concerns, and a hot communication link to the government. The government should put forth guidelines, not rules, requirements or recommendations.

Strategic Approach. The security initiatives should adopt a strategic approach modeled after the anti-smuggling initiatives of Customs with importers (BASC), carriers (Carrier and Super Carrier Programs) and brokers (Frontline). The security effort should not be added to existing audit programs, such as Compliance Assessments, Focused Assessments or Importer Compliance Measurement. These audit programs best handle post-entry commercial compliance rather than preventing an immediate terrorist threat, and are considered longer-term review-and-report programs rather than the immediate operational actions needed to combat terrorist threats.

Automated Systems. Any improved security measures should maximize the use of advanced, aut