COAC Makes Recommendations for DHS Global Supply Chain Security Strategy
During a July 15, 2010 teleconference, the Advisory Committee on Commercial Operations of U.S. Customs and Border Protection (COAC) adopted 17 pages of recommendations and comments for the Department of Homeland Security’s final 2010 “National Strategy to Secure the Flow of Commerce in the Global Supply Chain1.”
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Final Strategy Expected to be Broader than Mandated, Address All Modes
Since early 2010, DHS has been working on developing a final version of its initial supply chain strategy report that was issued in 20072. According to a DHS official, the final version of the report will reflect a much broader viewpoint than the Security and Accountability for Every (SAFE) Port Act mandates. For example, the final report will address all modes of transportation, rather than just the maritime environment, and will reflect a significant amount of inter-agency collaboration.
DHS Expects to Complete Drafting Final Strategy in Fall 2010
As COAC has made its recommendations to DHS, drafting of the final report is expected to begin. A DHS official stated that the drafting process is expected to be completed in fall 2010.
COAC Recommendations include Regulatory and Other Changes
The COAC recommendations, findings, and comments discussed at the teleconference include:
Legislative, regulatory, and policy improvements needed. According to COAC, the following legislative, regulatory, and policy improvements could help supply chain security efforts:
Reevaluate 100% scanning, screening -- the 100% scanning mandate for maritime containers and the requirement for 100% screening in the air environment should be reevaluated in favor of risked-based measures that target high risk shipments.
Sensitive cargo manifest information should be confidential - COAC asserts that 19 CFR 103.31 should be modified to protect certain sensitive cargo manifest information from being released to the public.
More consultation with private sector during rulemakings - COAC challenges CBP and DHS to put in place protocols to allow U.S. government officials to consult with the private sector after comments are received in a proposed rulemaking.
Coordination among agencies is critical - Coordinating the supply chain protocol both inside and outside DHS should be a strategic priority.
Private sector should be leveraged to increase security. The government should use the private sector as a force multiplier in protecting the supply chain and leverage the information available from the private sector to increase security.
Security exercises should be increased - Increasing the number of large and small security exercises is a key to improving and measuring resiliency.
Government-private collaboration on C-TPAT criteria should continue. Government-private sector collaboration on Customs-Trade Partnership Against Terrorism (C-TPAT) minimum security criteria should continue through COAC and other industry organizations to ensure the C-TPAT remains efficient and reflects the changing threats being faced.
1Previously referred to as the National Strategy for Global Supply Chain Security.
2Required by the Security and Accountability for Every (SAFE) Port Act (Public Law 109-347). (See ITT’s Online Archives or 11/06/06 news, 06110625, for BP summary.)
(See ITT’s Online Archives or 06/28/10 news, 10062816, for BP summary of CBP’s notice announcing this teleconference.
See ITT’s Online Archives or 07/24/07 news, 07072405, for BP summary of the initial report, including COAC’s May 2007 reactions to the draft version of the initial report. COAC had expressed a number of concerns regarding the initial draft. COAC had noted that the strategy was not actionable, was too focused on the maritime environment, did not specify who is in charge at each level, did not provide trade with intelligence on port conditions, did not address programs such as C-TPAT, etc.)