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."
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
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.
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.
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.
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."
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
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."
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,