Your editorial, "Costly Customs Mandate," (JofC, Oct. 28) used the proper adjective, "relentless," to describe Customs' efforts to automate its operations.

U.S. Customs has been at the task since about 1968 and the cost of the false starts since that time could substantially reduce the national debt.Customs' latest effort, ACS, the Automated Commercial System, has cost the trading community substantially. Customs first wooed the customs broker as a primary interface, promising five years ago immediate electronic release of merchandise. This was the carrot. Since then all we have seen is the stick. The release module is just now coming on stream. Customs' main thrust early in the development of the system was to secure input of entry data, duty computations and the preparation of the 7501 entry form itself. But because of constant re-evaluations, ACS has become a moving target. Deadlines are not met for the implementation of existing modules, new modules are added, specifications are modified and the brokerage community, which has committed itself to the success of the program, is bearing the brunt of these changes. Personnel shuffling at Customs headquarters and the desire on their part to add "might as wells" to whatever module is being developed has continued to frustrate thoseentities interfacing with the government. Such ambitious programs as trying to build a database of every exporter of every commodity in the world being imported into the United States, identified by telex or telephone number, is but one example.

In the midst of all of this development for which customs brokers were the guinea pigs, Customs started actively soliciting importers by means of an expensive multicolor brochure, contravening a promise that had been made to the brokers not to do so until the system was up and running. Next, it was the port authorities' turn. Because of Customs' warning that one must "automate or perish," ports started climbing all over themselves trying to interface with the government. But the module that linked them to Customs, the Automated

Manifest System, requires steamship lines all over the world to adhere to one format and one bill of lading numbering system in preparing their manifests in order to avoid the necessity of manifest input at the port of arrival.

Customs' problems arose at the outset of its efforts to automate. It still uses the same archaic 80-character format, based on an old punch-card system that grew out of its early efforts in the 1960's. While this system may be old, it is tried and true and is easy to maintain. But it is also slow - requiring batch processing. At this late juncture, Customs is reluctant to change to a more modern communication system since the brokers who are interfacing with it have spent substantial sums to conform to the old one. But change is inevitable.

As more participants climb on the ACS bandwagon, all tied into the mainframe computer at Franconia, Va., glitches are appearing in the system. There has recently been a breakdown of transmission back to the brokers and the system is only handling transactions in cue, one at a time, instead of as multiple transactions. Customs has been forced to put all of its resources toward correcting this situation, and many brokers who are in the process of interfacing have thrown up their hands in disgust.

Customs needs an interactive process operating on a satellite basis, allowing individual ports to interface with the user rather than have everyone call in to Franconia. Perhaps the recent purchases of a substantial amount of

updated equipment is a hint that we will soon see them utilize more modern techniques. The result of this, of course, will be that a great del of the investment that brokers have put into the present system will be lost. Another setback.

In the meantime, the commissioner is proudly announcing the era of the paperless transaction. He has described even further modifications, more modules and more enhancements to a system that isn't yet working properly on a nationwide basis.

The government seems to forget that the customs broker's role is multifaceted. True, the presentation of information to the Customs Service in proper form is primary. But the broker has other functions, not the least of which is to move the cargo to the receiver, make sure the merchandise complies with the requirements of other agencies, the freight is paid, the shipment is insured, claims are handled and he gets reimbursed for outlays - all the while avoiding demurrage charges. The computer tail is beginning to wag the dog, however, and brokers are becoming obsessed with a system that is more trouble than a manual one.

A computer can only do so much. It does not have the tactile sense or reasoning ability of a properly trained customs officer in the field. Ultimately human beings examine and release cargo. The General Accounting Office has just criticized the Customs Service for not performing this task adequately.

It's about time the government re-evaluated its commercial operations and stopped trying to make the computer the entire U.S. Customs Service.

Sigmund Shapiro President Samuel Shapiro & Co. Inc. Baltimore, Md.

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