Still waiting

Still waiting

The Department of Home-land Security's much-anticipated strategy for managing trade in the face of heightened maritime security levels or after a transportation security incident was sent to Congress on July 10.

The DHS was required by the SAFE Port Act to develop a strategic plan, in consultation with public- and private-sector stakeholders, to enhance international supply-chain security. Many in the trade community anticipated an operational plan that would clearly set out the roles and responsibilities of government officials who would manage a trade security incident. What they received was a 128-page plan that would receive a high grade as a research project for a graduate school class in international logistics, but which lacks any operational grounding.

The trade community has been asked to invest considerable amounts of money to make their supply chains more secure. Under the Customs-Trade Partnership Against Terrorism and now under its inspired programs adopted by other nations following the recommendations of the World Customs Organization, companies are asked to invest in physical, procedural and IT improvements to enhance security from the point goods are made ready for shipment to their point of distribution in the U.S. or other country.

So far, the benefits have been reduced scores in Customs' targeting system and access to special trade-facilitation programs - benefits that many chief financial officers consider insufficient return on their firm's investments in supply-chain security.

For many companies, the real value of C-TPAT membership lies in their presumed ability to move imports through ports of entry when the Homeland Security Advisory System or MARSEC (set by the Coast Guard) security levels are raised because of an attack against the maritime system or the threat of one.

A C-TPAT company validated as operating at the third tier and having a supply chain with documented security - with the foreign supplier and foreign logistics provider meeting C-TPAT-equivalent standards, shipping full containerloads through a Container Security Initiative port on a C-TPAT ocean carrier into a C-TPAT terminal - presumably would have a high probability that its imports would be the first to be released after emergency shipments.

Key requirements of the DHS strategy under the SAFE Port Act are that it identify a prudent and measured response in the event of a transportation security incident involving the supply chain; that it provide protocols for the expeditious resumption of trade after an incident; and that it consider the impact of supply-chain security rules on small and midsize companies. This latter feature was of particular interest to small companies, which comprise the vast majority of the nearly 500,000 U.S. importers and lack a seat at the table when the trade community is consulted.

What emerged was a dense description of the existing laws, homeland-security directives and governmental policies that taken together comprise the totality of the U.S. approach to supply-chain security. No one should attempt to read this document without access to their preferred search engine to cope with the acronyms - three full pages of which are listed in an appendix - that stud the document. That is not to say that an operational supply-chain security strategy does not exist somewhere within the authorities cited, but that it is not evident in this document alone.

There are nevertheless important kernels of information that provide guidance for supply-chain managers and corporate executives. The Nation-al Incident Management System provides the framework for responses to supply-chain security incidents.

A key question has been, "Who will be in charge?" While the National Recovery Plan envisions the designation of a "principal federal official" to oversee management of the response to the incident, it appears that the Coast Guard captain of the port will fill that role during a maritime incident. The Area Maritime Security Committees established under the Marine Transportation Security Act and led by the Coast Guard appear to be the key venue for securing information on response protocols.

If we assume that a "strategy" is the art of deploying resources to accomplish overarching objectives - in this case, protecting global supply chains and describing the deployment of resources toward the recovery of trade - the "Strategy to Enhance International Supply Chain Security" leaves us still waiting for answers.