BTS Director of Cargo and Trade Policy Outlines Goals for Cargo Security

(The Director explained that BTS is an umbrella agency which ties together the Transportation Security Administration (TSA), Customs and Border Protection (CBP), Immigration and Customs Enforcement (ICE), and the Federal Law Enforcement Training Center (FLETC).)

The following are highlights of the three goals outlined by the BTS Director:

Goal 1 - Continue to build assessment capabilities and analytical tools for cargo inspection

This goal relates to BTS' need to pinpoint risk as it is impossible to inspect all cargo. As result, BTS is developing a Threat and Vulnerability Process which entails mapping and assessing the vulnerabilities of places such as ports and critical infrastructure locations.

DHS is working to augment its risk assessments by incorporating the best intelligence and data. The Director stated that the requirements of the Trade Act of 2002 (Trade Act) have been very helpful in improving the data and intelligence received by DHS. In addition, the Trade Act's requirement that manifest information be transmitted earlier has ensured that DHS receives this information farther in advance.

Goal 2 - Continued deployment of key cargo security programs

BTS' second goal for improving cargo security calls for the continued deployment of the following key programs:

CSI. With respect to the Container Security Initiative (CSI), DHS' initial goal was to enter into bilateral agreements with governments of the 20 ports handling the most cargo volume, which would account for 2/3 of containers shipped to the U.S. So far, governments for 19 of these 20 ports have signed onto CSI. (See ITT's Online Archives or 03/09/04 news, 04030920, for BP summary of the most recent CSI implementation, which was with Malaysia.)

C-TPAT. 51% of companies participating in the Customs-Trade Partnership Against Terrorism (C-TPAT) program are certified. Certification is a process which involves submitting a supply chain security profile based on a company's self-assessment. BTS believes C-TPAT certification demonstrates a standard of excellence and notes that some companies are requiring it in order to do business.

For 2004, BTS' major goal for C-TPAT is to complete as many validations of submitted security profiles as possible. CBP explains that validation is an on-site review of the participant's C-TPAT supply chain security profile. Such on-site validations are currently underway and involve visiting both foreign and domestic facilities.

OSC. Another key program is Operation Safe Commerce's (OSC's) Cooperative Agreement Program, an interagency grant program. The purpose of OSC grant program is to follow the supply chain from the point of origin to its U.S. destination(s). The Director explains that the OSC grant program is intended to be intermodal in scope and currently has 18 approved and fully funded projects for load centers.

Smart Box. CBP Commissioner Bonner has called for the Smart Box (also referred to as Smart Container) program to be incorporated into C-TPAT. CBP sources have previously stated that five C-TPAT partners are working with CBP on this initiative. These sources further stated that at least 500 containers are expected to have moved under the Smart Box initiative by early April 2004. (See ITT's Online Archives or 02/12/04 news, 04021205, for BP summary of Smart Box update.)

According to the Director, Smart Box currently has two requirements: 1) the container must be securely sealed and 2) the container must be tamper evident. The Director stated that additional criteria for sealed containers under this program are still being developed but noted that BTS would probably not require the use of any high-tech products in the future.

Goal 3 - Identifying and filing in remaining gaps in security

A BTS internal working group including representatives from CBP, TSA, and Coast Guard is working on a cargo security "gap analysis". This gap analysis shows where the government's interest needs to be focused.

This working group was formed partly for meeting the requirements of the Marine Transportation Security Act (MTSA) and is also focused on "filling in" any security gaps identified. The Director stated that this working group is looking at the possibility of fully launching Smart Box.

With respect to filling in remaining security gaps, BTS has proposed a subcommittee under the Departmental Advisory Committee on Commercial Operations of CBP (COAC) which will bring representatives of trade and government together to make tough decisions on which security requirements will be voluntary and which will be mandatory. This subcommittee will likely be formalized at the next COAC meeting and will include a mix of COAC members and other representatives from industries that are affected by cargo security requirements.