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NITL submits ocean security recommendations to DOT

The National Industrial Transportation League (NITL) of the US told the National Infrastructure Security Committee's (NISC) Container Working Group (CWG) that "policies and procedures must be developed that will reduce the risk that transportation will be used as a conveyance for terrorist threats."

In developing these new security safeguards the League said the government must be careful not to unnecessarily compromise or undermine the efficiency and reliability of our liner transportation industry. This system, the League said, has contributed substantially towards the nation's economic strength and has led to many innovations in business practices which have benefited US consumers.

As a general rule the League said that "no network as complex as the international ocean liner transportation system can be made completely secure over the short-term." Specifically while legislation and regulations may be advanced and imposed immediately, in many instances the League said these proposed safeguards could have the effect of backing up "essential commerce and congest the nation's ports; may cripple vital industries; and, could have serious adverse economic implications for not only the U.S., but the rest of the world's economies."

In this regard the League identified the following six areas where shippers believe attention should be focused: pre-certification of "known" shippers/receivers; loading containers at foreign off-port (remote) ocations or at a foreign port; inbound shipments; outbound shipments; use of pre-shipment third party inspections; seals on containers; and, non-intrusive container inspections/new technology.

With respect to "pre-certification of 'known' shippers/receivers" the League said this is a viable process to facilitate cargo flows. It would also have the advantage of increasing the visibility of shipment flows to the appropriate /required parties so that anomalies may be easily detected.

As for inbound shipments, the League cautioned that imposing an immediate requirement that all cargo information be provided prior to tendering the cargo to the ocean carriers would significantly delay legitimate shipments, produce dire consequences to "just-in-time" supply chain management, and could lead to massive service failures.

The League recommended that a phased-in approach be adopted to permit better coordination among overseas suppliers, non-vessel operating common carriers, drayage operators, consolidators, and carriers. It said that at least 12 months will be required to accomplish these tasks.

Unless this type of approach is adopted, "serious delays will result in getting products to the US, raising costs to consumers." Another fallout of a non-gradual approach the League said is that "large volumes of containers may have to be left at overseas unsecured locations while they await the completion of full documentation, resulting in a greater chance that the container could be subject to unauthorized tampering."

As for outbound shipments (from the US), the League said as a short-term solution, documentation should be required to contain the "Export Identification Number (EIN), a commodity description using the harmonized code, the point of origin, the name of the shipper, the foreign consignee, and the foreign port of discharge."

With respect to the use of "pre-shipment" third party inspections the League cautioned that they would probably not be effective and could result in creating traffic delays because they wouldn't have the resources or manpower to handle large volumes of cargo. In its place the League recommended "certification of ëknowní suppliers."

For seals on containers, the League said it supports greater use of these devices as a means to protect against unauthorized tampering of the contents of a container.

On the matter of new technology, the League said it supports the "government's use of new technologies which would permit non-intrusive inspections of all containers."

In conclusion, the League emphasized that there is no single "silver bullet" for curing all the security risks outstanding today. "Whatever rules are eventually applied, must be concise and unambiguous, and have a realistic time frame for full implementation." For a complete text of the League's security recommendations, visit www.nitl.org.