NCBFAA Government Affairs Conference CBPs Security Programs Reviewing the Present and Looking to the

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NCBFAA Government Affairs ConferenceCBPs
Security Programs Reviewing the Present and
Looking to the FutureA Sea Carriers Perspective
Andy Lumley September 24, 2007
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Fundamentals

• Sea Carrier Initiative 1989
• Voluntary participation
• Collaborative interaction and compliance of all
  supply chain parties
• Take It Personally approach

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Fundamentals

• C S I Container Security Initiative
• CTPAT
• Security Filing (102)

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C S I

• Identify high risk containers
• Prescreen and evaluate containers before loaded
  to a vessel- do not load compliance
• Use technology to prescreen containers
  effectively and efficiently so as not to slow
  down the movement of goods in trade
• Development of smart and secure containers
• Seeks reciprocity with other customs authorities
• 52 ports world wide are CSI operational

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C-TPAT Security Criteria Sea Carriers

• Business Partner Requirements
• Includes customers, operating partners, service
  providers
• Security procedures for legitimacy and risk
  assessment
• Container Security
• Container inspection
• Container seals
• Container storage

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C-TPAT Security Criteria Sea Carriers

• Physical Access Controls
• Boarding and disembarking of vessels
• ISPS International Ship and Port Security Code
• MTSA Maritime Transportation Security Act
• Employees
• Visitors/vendors/service providers
• Challenging and removing unauthorized persons
• Personnel Security on land and at sea
• Pre-employment verification
• Background check
• Termination procedures
• Crewman control
• Deserter/absconder risk and notification

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C-TPAT Security Criteria Sea Carriers

• Procedural Security
• Passenger and crew
• Bill of lading and manifest procedures
• Baplie EDI file for vessel stowage 102 linkage
• Cargo exception alert
• Security Awareness Training
• Physical security
• Fencing, gates, parking, building structure,
  locking devices and key control, lighting, alarm
  systems and video surveillance

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C-TPAT Security Criteria Sea Carriers

• Validation Process
• Domestic (local office and facility)
• Vessel (one in port)
• Foreign (vessel and facility)
• 3 year re-validation (2008 for OOCL)
• Status Verification Interface (SVI) number and
  C-TPAT certificate are posted on www.oocl.com
  Security site

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OOCL Security Policy

• Recognition of corporate security
  responsibilities as an owner and/or operator of
  vessels, facilities and provider of supply chain
  services
• Ensure security measures are undertaken to
  protect the interest of customer, company, and
  staffs (shore and sea)
• Participate and support government, carrier and
  industry initiatives
• Commitment to strictly comply with IMO, SOLAS,
  ISPS and USCG codes
• Dedicated to continuous improvement of security
  measures, and related training and enforcement

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Conveyance Security

• Vessels
• Implemented International Ship and Port Facility
  Security Code (ISPS) requirements
• All OOCL Vessels and Grand Alliance partner
  vessels are ISPS certified, with ship security
  plans in place
• Exception reporting guidelines and clear line of
  authority
• Training programs designed for crew providing
  clear information regarding any security risks,
  related to cargo procedures, internal and
  external conspiracies
• Ongoing review and monitoring the effectiveness
  of the plan

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Conveyance Security

• Containers
• All loaded containers must be received with seals
  intact from shipper. Exceptions (missing or
  tampered seal) must be reported by facility
  operators to OOCL Regional Security Coordinator.
  Ongoing exceptions are addressed with accountable
  party within supply chain
• Visual inspection of empty containers at all
  depots and terminals upon in-gate

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Conveyance Security

• New Customers
• All new shippers must be contacted by Sales to
  insure a valid place of business prior to
  confirmation of booking
• All new importers must be contacted by Sales to
  insure valid place of business prior to delivery
  of cargo
• Suspicious activities must be reported to local
  authorities and OOCL Security Organization

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Access Controls

• Office
• All visitors must register and show valid
  picture ID
• Vessel
• Ship Security Plan
• Terminal
• North American Terminal Facilities C-TPAT/ISPS
  Compliant
• Grand Alliance Fareast/Europe Facilities ISPS
  Compliant
• Information
• Internally controlled via password
• Externally controlled via registration and
  password

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Manifests

• OOCL strictly complies with 24hour advance
  manifest requirementsfor USA Canada Mexico
  cargo
• OOCL is an AMS AES participating ocean carrier
• Manifest discrepancies are reported
  electronically to U S Customs and Border
  Protection. Verbal communication supplementation
  as required.
• OOCL monitors all developing requirements for U S
  Customs and Coast Guard, and actively
  participates in CESAC and other
  government/industry forums to remain aware of
  best practices and pending legal requirements

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Personnel

• Where legally permissible background checks are
  to be performed
• Employee history is to be verified by hiring
  manager
• A personal interview is required of the candidate
  by the hiring manager
• USA employee hiring requires criminal record
  search
• Any illegal activities (other than fixed penalty
  traffic offenses) are to be reported by the
  employee to Human Resources within 2 days
• Any employee who conducts himself/herself in an
  unsatisfactory manner shall be subject to
  disciplinary action, including summary dismissal
  in case of serious misconduct, in accordance with
  local law.

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Education Training

• Shipboard staff is covered under the Ship
  Security Plan
• All OOCL employees have completed an in-house
  developed security awareness training course
  including an exam, with a passing score required.
• The security awareness training emphasizes the
  legal requirements under which we operate, as
  well as company policies and reporting procedures
  of potential security incident.
• All new hires are required to take and pass the
  security awareness training
• Periodic updates on regulatory and security
  issues are provided to management distribution
  throughout the company.

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10 Plus 2 Initiative by CBP(Security Filing)

• Security Filing (SF) CBP proposal to require an
  additional set of data elements 24 hours prior to
  vessel loading.
• Goes beyond the current 14 advance manifest
  filing information items
• Definitions of the importer data elements
• Manufacturer name and address
• Seller name and address
• Container Stuffing location
• Consolidator name and address
• Buyer name and address
• Ship to name and address
• Importer of record number
• Consignee number
• Country of origin of the goods
• Commodity harmonized Tariff Schedule number (6
  digit)

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10 Plus 2 Initiative by CBP(Security Filing)

• CBP requires sea (ocean) carriers to provide two
  additional data sets
• Vessel Stow Plan
• Container Status Messages
• Responsible Parties
• 10 cargo related items Importer
• 2 activity related items Sea (Ocean) carrier
  via EDI
• Target date of implementation
• Not yet determined

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Future Outlook

• 100 inspection debate
• Radiation portal monitoring for all USA port
  handled imports by end 2007
• Extension to overseas load ports
• Overseas countries advance manifesting
• USA export advance manifesting
• TWIC implementation
• C-TPAT terminal and port criteria
• Electronic seal
• Container security device