Opinion
Container Security: Is the Layered Approach Working?
Guest columnist Jim Giermanski says the government's five-layered approach to container security is on the right track, but needs significant improvements
By James Giermanski
However, like most of the layered approach, the center does not have active "boots on the ground" collecting intelligence. Instead, it analyzes the same and similar data obtained from the 24-hr. manifest and from its numerous other Customs Forms. If the paper is wrong or incomplete, however, targeting can also be wrong or incomplete. In other words, while this NTC is very important, it still is a data center, relying on data, and not knowing what is really in any container coming to the United States.
Layer-3: Customs Trade Partnership Against Terrorism (C-TPAT)
In this layer, electronic data and paper data are also essential elements of CBP's security. However, the C-TPAT layer is different. C-TPAT, as announced in 2001, "is an import-oriented program that provides incentives to shippers, such as reduced cargo exams and first-in-line priority for inspections, in exchange for adopting tight internal shipment processes for themselves and overseas business partners to prevent terrorists or criminals from slipping contraband or weapons into a container. CBP checks that companies follow approved security plans that meet minimum guidelines by visiting a company's headquarters and conducting sample audits of some foreign suppliers and transport providers." It was and is a voluntary program for industry, initially focused on large U.S. importers and exporters, ports/terminal operators, and carriers. Other participants were added, and today it has 12 different categories of participants. It began with only seven major importers. In 2008 it has over 8,000 certified members. In the beginning, it had only seven security areas of concern with respect to the supply chain: business partner requirements, physical access security, personnel security, procedural security, personnel security, container security, and education/training security. Now it has more.
With C-TPAT, CBP accepts as true the data furnished by its participating entity unless it learns or knows otherwise. Like the ATS/NTC layer, and to some degree the CSI/SFI layer, information provided is only as good as the providers' knowledge or integrity. With C-TPAT, there are clear and mandated physical requirements for the C-TPAT participants, which, if followed, can and do contribute to the security of this nation. Additionally, in C-TPAT there are auditors who review actual participant procedures at real locations around the world. With C-TPAT there are "boots on the ground" actions, not only data acceptance.
Layer-4: Container Security Initiative (CSI); the Security Freight Initiative (SFI)
CSI addresses the threat to border security and global trade posed by the potential for terrorist's use of a maritime container to deliver a weapon. CSI proposes a security regime to ensure that all containers that pose a potential risk for terrorism are identified and inspected at foreign ports before they are placed on vessels destined for the United States. Its core elements are:
container security
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