World Shipping Council gives views to U.S. Customs on “smart container”
World Shipping Council gives views to U.S. Customs on “smart container”
The U.S. Bureau of Customs and Border Protection should separate electronic devices related to container security and those related to supply chain cargo management, the Washington-based World Shipping Council carrier group said in a comment to the agency this week about the proposed “smart and secure container” technology.
To further reduce the risk of containers being used for potential terrorist attacks, Customs and Border Protection requested industry comments on using technology such as radio-frequency identification and sensors for maritime containers on Dec. 16.
In November, Bureau of Customs and Border Protection Commissioner Robert
Bonner also told members of the trade that companies that use electronic seals and sensor technology to secure international containers and monitor tampering would receive expedited clearance of their goods.
In a five-page comment to the agency, the World Shipping Council group recommended a framework for how RFID technology used in electronic seals and in cargo shipment tags should be analyzed and applied in “smart container” initiatives.
Specifically, the council’s paper proposes what the security characteristics for RFID e-seals should be, and it advocates that container security objectives and devices and supply chain cargo management objectives and devices need to be analytically and physically separated.
“A failure to clearly distinguish between security objectives and commercial applications will create confusion and ambiguity, will impede progress on these issues and, in fact, may create security vulnerabilities,” the council stated.
The carrier group recommended that three separate devices could be used to meet security or supply chain objectives:
* A passive, read-only RFID container tag, affixed permanently by the container owner on the container, would only contain “license plate” information such as container number, owner code and other information elements.
* A “semi-passive,” read-only, non-reusable electronic seal, affixed to the container door by the shipper for a particular shipment immediately upon stuffing of the container, would record the date and time of when the seal was activated and when it was opened or breached.
* An active, read/write non-reusable RFID cargo shipment tag for a particular shipment may be affixed by the shipper on the container upon stuffing to serve the shipper’s or importer’s supply chain management requirements, if desired by the shipper.
Passive electronic tags, which have no power source, cost much less than active ones like those produced by Savi for the “smart and secure tradelanes” voluntary program of P&O Ports, Hutchison and PSA Corp.
The World Shipping Council encouraged Customs to carry out a pilot program of e-seals with officials of other countries and a small number of shippers.
The council also stressed that requirements of smart container technologies must fit into the operating environment of international trade without impeding trade flows or operations.
The carrier group believes that the objective of any future Customs regulation on RFID use for containers must be to build a more secure operating system that will work more efficiently. “Concepts and proposals that do not reflect a commonly understood and shared set of objectives are not likely to produce progress,” it warned. “Proposals that do not attempt to address how the proposals would actually be applied to the operating conditions of international commerce are deficient.”
The council also asked questions about the cost of the electronic technology, who will pay for it, who will have to read the information and who will operate the supporting technology infrastructure.
The shipping industry is expected to focus its attention on who will have to read the security information and operate the reading devices before the goods are loaded on ships.
Customs has already identified the cost of possible technologies as a consideration, a point that the World Shipping Council said is “obvious and unarguable.” The carrier group also urged the authorities to take into consideration several cost factors:
* When non-security features are added to electronic devices, the cost of the device, the cost of the supporting infrastructure, and the cost of its use increase.
* Cost analysis must include not only the cost of a device, but its administration and use (including maintenance and repair), the number and cost of “false positives,” the infrastructure needed to properly utilize the device, and the protocols resulting from the use of whatever information is produced by the device.
* Unless the device is permanently affixed to the container, “it should be designed for a single usage.” Recycling devices from one shipment to another not only raises significant logistics and security issues, but also the cost and complexities of such recycling “is likely to be unacceptable.”
* The cost of deploying whatever technology is determined most appropriate to the international trade network “will be substantial.” Accordingly, there needs to be confidence that the government will not want to switch technologies soon after establishing what is desired, the carrier group said.
The council asked whether the objective is to develop and deploy technology that can be used for security screening before vessel loading at non-U.S. ports, and thus integrated into the 24-hour rule and the Container Security Initiative, or whether the objective is to use technology for security screening “upon arrival at the ports of entry,” as stated in Customs’ request for information.
“The answer to this question will obviously have a substantial impact upon the scope of application and the number of entities in the global supply chain who would be involved,” the World Shipping Council stressed.
The World Shipping Council represents 44 liner shipping companies which carry more than 90 percent of U.S. containerized imports and exports.
After gathering industry comments through its request for information, Customs and Border Protection is expected to issue a more detailed request for proposal before adopting rules on technology for smart containers.