COAC Subcommittee Creates Data Matrix to Identity Air Cargo Security Redundancies
During the August 5, 2009 Departmental Advisory Committee on Commercial Operations of U.S. Customs and Border Protection and Related Homeland Security Functions (COAC) meeting, COAC's Air Cargo Security Subcommittee provided an update on its efforts to identify areas of possible redundancy and/or areas that could be leveraged to improve and streamline domestic and international air cargo security.
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Draft Matrix to Help Identify Areas of Redundancy, Areas to Leverage
The Air Cargo Security Subcommittee has created a draft table (referred to as a "matrix") on the various cargo security-related programs that affect trade participants in the air cargo supply chain.
The matrix will help identify areas of possible redundancy and/or areas that could be leveraged to improve and streamline air cargo security.
Public Version of Draft Matrix Available
Following the August 5, 2009 COAC meeting, CBP posted a "public" (i.e., without any sensitive security information) version of the Subcommittee's draft matrix on its Web site.
The public version outlines the various cargo security requirements (e.g., employee/supplier background checks, training, facility physical security, shipment data, physical screening, merchandise protection, and additional measures at foreign countries) for the various business entities in the air cargo supply chain.
The business entities and the requirements, regulations, programs, initiatives, or standards that could apply to such entities that are listed in the public version are:
customs brokers (CBP's regulations for licensed brokers and employees)
importers (responsible care program, U.S. Department of Agriculture/Food and Drug Administration Good Importer Practices, Customs-Trade Partnership Against Terrorism (C-TPAT) requirements, European Union Authorized Economic Operator Certification )
truckers (Transportation Security Administration's Transportation Worker Identification Credential (TWIC), TSA's Security Identification Display Area), C-TPAT requirements, CBP's Free and Secure Trade (FAST) Program, U.S.-Mexico cross-border trucking pilot (not currently operational), CBP requirements for bonded carriers)
Independent Cargo Screening Facilities (TSA's CCSP program)
exporters (TSA's Certified Cargo Screening Program, Technology Asset Protection Association (TAPA) Freight Security Requirements Program)
freight forwarders (TSA's Indirect Air Carrier Standards Security Program (IACSSP), Customs-Trade Partnership Against Terrorism (C-TPAT) requirements)
bonded facilities (3PL requirements, CBP's bonded warehouse regulations)
Matrix Will Provide Greater Transparency, Regulatory Changes May be Needed
According to a CBP official, once completed, the matrix will provide greater transparency, and help identify potential areas of overlap that would benefit from streamlining, identify areas that can be leveraged, identify potential enhancements, and help recommend harmonization in areas that may benefit from it.
A government official also noted that streamlining and making efficient the various air cargo security program requirements has proven to be complex and that regulatory changes may have to be made.
CBP and TSA Are Already Working on Leveraging Security Programs
According to a government official, the analysis being done by COAC is also being done by the government. TSA and CBP have been talking for some time about how their programs/systems can be leveraged to provide a more unified government approach to the various government cargo security programs.
Subcommittee's Next Step is to List its Action Priorities
The next step for the Subcommittee is to identify the top priorities from the trade perspective to recommend that COAC look at more closely. The Subcommittee will be looking for areas that can have the highest impact for streamlining CBP, TSA, and DHS processes. The Subcommittee's goal is to bring a list of recommendations to the November 2009 COAC meeting.
Subcommittee matrix (dated 08/03/09) available at http://www.cbp.gov/linkhandler/cgov/trade/trade_outreach/coac/subcommittee_activities/air_cargo_security/air_cargo_matrix.ctt/air_cargo_matrix.doc.