CBP Posts COAC Recommendations on DHS Global Supply Chain Security Strategy
On July 20, 2010, U.S. Customs and Border Protection posted 17 pages of recommendations from COAC’s Global Supply Chain Security Subcommittee that will be considered by the Department of Homeland Security in its development of a final version of its 2010 “National Strategy for Global Supply Chain Security.”
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The Subcommittee’s recommendations were adopted by the full COAC during a teleconference on July 15, 2010. (See ITT”s Online Archives or 07/16/10 news, 10071627, for BP summary.)
Since early 2010, DHS has been working on developing a final version of its initial supply chain strategy report that was issued in 2007. The strategy is required by the Security and Accountability for Every (SAFE) Port Act (Public Law 109-347).
In its comments, the COAC Subcommittee:
reviewed the 2007 Strategy to Enhance International Supply Chain Security;
responded to 5 questions directed by the SAFE Port Act;
responded to 11 additional questions posed by DHS; and
identified 8 questions to be considered by DHS.
DHS Expects to Finish 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 has previously stated that the drafting process is expected to be completed in fall 2010.
Key Subcommittee Findings and Recommendations
The COAC Subcommittee’s key findings and recommendations are identified as:
More play for air & surface.The Strategy should focus more attention on air and surface transportation.
Govt intelligence sharing. Timely sharing of actionable intelligence among government agencies and the private sector should be a strategic priority.
More security exercises. Increasing the number of large and small scale security exercises is key to improving and measuring resiliency.
Collaborate with C-TPAT. Collaboration on the U.S. Customs-Trade Partnership Against Terrorism (C-TPAT) minimum security criteria should continue to help ensure C-TPAT remains efficient and reflects the ever-changing threats.
Favor high-risk instead of 100% mandate. The mandate for 100% scanning of maritime containers (in 2012) and the 100% screening of air cargo on passenger aircraft (in August 2010) contained within the 9/11 Commission Recommendations Act should be reevaluated in favor of risk-based measures that target high-risk shipments for physical inspections. Further the requirement to scan 100% of maritime containers prior to vessel load should be repealed.
Coordinate supply chain. Coordinating supply chain security protocols both inside and outside of DHS should be a priority.
Protect sensitive manifest info. 19 CFR 103.31 should be modified to protect certain sensitive information from being released to the public too early, creating security vulnerabilities and negating effectiveness of some C-TPAT minimum security criteria.
Be less container focused. Container-centric technology solutions present little hope of reduce the risk of terrorists using containers as Weapons of Mass Destruction (WMD) delivery tools.
2007 comments valid. COAC’s comments on the Strategy made in 2007 are still valid.
(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.)
Minutes from Subcommittee’s April 16, 2010 through July 2, 2010 meetings available here.