Excerpts of Remarks by U.S. Customs Commissioner Robert Bonner
[U.S. Customs' web site notes that Commissioner Bonner reserves the right to edit his written remarks during his oral presentation and speak extemporaneously. Thus, his actual remarks, as given, may vary slightly from the written text. Material below is excerpted by us to focus on cargo containers. Customs has undertaken a number of other homeland security measures, to which Commissioner Bonner referred in his remarks; the full text is posted on Customs' web site. Our deletions are indicated by elipses.]
January 17, 2002
Excerpted Remarks of Customs Commissioner Bonner Before the Center for Strategic and International Studies (CSIS)
...We are doing everything within our power to prevent terrorists and terrorist weapons from entering the United States.
...The fact is that we do currently employ a wide variety of means to sift out threats from the vast flows of legitimate travel and trade. But in the wake of September 11th, it is obvious that we must do more. We must do more to push our sphere of activities outward, from points of entry in the U.S. to points of origin abroad. And we must do a better and more accurate job of pinpointing the threats. That is why we are looking to develop and expand the techniques we currently use to manage risk at our national borders to customs operations outside the United States.
Much has been made recently of the fact that Customs manages to inspect only about 2% of the total volume of trade entering the country each year. Taken alone, this statistic sounds alarmingly low. But Customs inspections are not based on just a random selection -- say, one out of fifty. It is based upon a sophisticated targeting process.
The Customs Service employs a multi-layered strategy of risk management and targeting to sort out suspicious goods from legitimate trade. That strategy is focused on the use of good strategic and tactical intelligence in targeting incoming goods; intelligence which we are getting much more of from the intelligence community. Every day, I receive a CIA intelligence briefing at Customs Headquarters.
But we also rely heavily on the advance information we receive on incoming shipments to select cargo or containers for inspection, and we deploy of state-of-the-art inspection technology at our ports of entry. Risk targeting also involves the application of sophisticated computer systems to sort and analyze the mountains of data that accompany imports into the United States. We are building powerful new systems right not to do that better.
The fact is that Customs already engages in a great deal of prescreening of people and goods entering the country using these techniques. This cues us as to who and what are "high-risk" and who and what are not. But, given the threat from international terrorist organizations, I believe the prescreening we do is not enough, nor is it done early enough in the process of arrival at our borders.
Let me provide you with what I believe is one of the most compelling examples.
Last May 25th, Malcom McLean passed away at age 85. Probably not many of you know who he was. He died in relative obscurity, though he was arguably one of the greatest contributors to the growth of the world economy in the 20th century. In an editorial on his death, the Baltimore Sun stated that "he ranks next to Robert Fulton as the greatest revolutionary in the history of maritime trade." Forbes Magazine called him "one of the few men who changed the world."
You see, Malcom McLean invented the shipping container in the 1930s in New Jersey, while sitting at a dock waiting all day for cargo he had carried there in his truck to be reloaded onto a ship. He figured out a better way to pack goods and transport them by sea -- which was to secure them in large steel boxes that could be easily loaded onto ships. And in so doing he came up with an idea that changed the face of global trade.
McLean’s invention revolutionized the ease and efficiency of cargo shipping, as did his company, Sea-Land. He did for the ocean lines what highway construction in this country did for the U.S. trucking industry. Today, approximately 90% of cargo moves by container, much of it stacked dozens of stories high on huge transport ships that ply the sea lanes between the world’s mega-ports. Over 200 million containers per year are now moved between those ports, constituting the most critical component of the global trade. Oceangoing sea containers make up a vital artery of the U.S. economy as well. This chart shows the proportion of imports moved into the U.S. by ocean container, by dollar value. As you can see, vessel container traffic accounts for the vast majority -- 46% -- of the value of incoming cargo. Air cargo accounts for 23% of import value, while 31% arrives by other means -- chiefly by truck and by rail from Canada and Mexico.
As significant as sea container traffic is to the U.S. economy, we are less dependent on it than most other exporting nations, particularly those in Asia. That is because such a significant amount of U.S. trade is done over our land borders, with our NAFTA partners Canada and Mexico. But consider the example of South Korea, where it is estimated that 99.7% of the country’s trade by volume goes through its ports. In a country where merchandise exports and imports make up about 31% and 33% of GDP, respectively, the containerized shipping industry is absolutely critical to the national economy. Japan, Singapore, the EU, all industrialized nations, rely heavily on containerized shipping.
Thus, from both a logistics and economic perspective, we should be very concerned about the global trade and the ways it could be impacted by a catastrophic event involving sea containers. The effects would be far-reaching. Given the picture I just described, it is no wonder that one of the most lethal terrorist scenarios being discussed these days is the use of ocean-going container traffic as a means to smuggle terrorists and weapons of mass destruction into the United States. And it is by no means far-fetched.
Some of you may recall that last October, Italian authorities found a suspected Al Qaeda operative locked inside a shipping container bound for Canada. Inside the container were a bed and bathroom for the journey to Halifax, as well as airport maps, airport security passes and an airplane mechanic's certificate.
Of ever-greater concern are the possibilities that international terrorists such as Al Qaeda could smuggle a crude nuclear device in one of the more than fifty thousand containers that arrive in the U.S. each day. One can only imagine the devastation of a small nuclear explosion at one of our seaports.
As horrific as this damage would be, one must also consider what would become of the global shipping industry and global trade if a sea container were used to smuggle and then detonate a nuclear device. Simply put, the shipping of sea containers would stop. The American people, for one, would not likely permit one more sea container to enter the United States until there was a significantly greater assurance -- such as 100% inspections -- that no additional terrorist weapons would be smuggled into the country. Governments in other major industrial countries would no doubt adopt a similar policy, thus bringing the global economy to its knees.
Sound farfetched? One need only look to the fate of the airline industry after September 11 to speculate on how the detonation of a sea container would stop global sea container trade. What happened after September 11? All airline traffic in the United States stopped for almost a week, costing the airlines and the American economy billions of dollars. The airline industry still has not recovered from this loss, and the lingering reluctance of some Americans to travel by air.
And if anyone is wondering about the impact of a 100% inspection rate on our just-in-time economy, consider the situation in which the U.S. auto industry found itself in the days after the terrorist attacks. Ford, GM, and Daimler Chrysler, all of whom are dependent on a regular flow of auto parts from Canada and Mexico, could not get critical materials in time due to border back-ups, threatening a vital part of our economy. The fate of several major plants, and thousands of jobs, hinged on the delays cost by just two days of increased wait times.
The detonation of a nuclear device smuggled by way of a sea container would have a far greater impact upon global trade and the global economy. Even a two-week shutdown of global sea container traffic would be devastating, costing billions. But the shutdown would, in all likelihood, be much longer, as governments struggled to figure out how to build a security system that could find the other deadly needles in the massive haystack of global trade.
Obviously, such a shutdown would greatly impact the American economy, sending the prices of major imported products spiraling upwards. Cities and seaports dependent upon sea container trade would be crippled, as business would dry up -- resulting in massive layoffs. Indeed, the layoffs of airport workers at Reagan National Airport after September 11 would seem tiny compared to the layoffs associated with even a temporary shutdown of global trade.
In addition, countries whose economies are particularly dependent upon robust sea container transit -- like the Netherlands, Singapore, Japan, or -- as noted before, South Korea -- would be profoundly impacted, and would teeter on the edge of economic collapse.
So, the stakes are high and the system is vulnerable, and we must do everything in our power to establish a means to protect the global sea container trade, and we must do it now -- before some devastating event occurs. We must devise and implement a system to detect and deter threats to this vital segment of our infrastructure.
For that reason, I am proposing a new Container Security Initiative that would establish a security architecture for the protection of global sea container trade. Despite the daunting size and scope of the container shipping industry, I believe this is a very feasible initiative and I believe we can make it work. How do we do that?
First and foremost, we concentrate our efforts on the "mega-ports" of the world, -- the largest container ports -- and specifically those ports that send the highest volumes of container traffic into the United States.
Container traffic flowing into the U.S. arrives from two predominant areas -- Asia and Europe. The mega-ports within those regions can easily be identified. What is extremely important to note here is that these top ten ports -- just ten ports -- account for nearly half of all the container traffic entering the U.S.
With the exception of Rotterdam at number five, the top half of the list is dominated by the Asian countries, as I’m sure you’re not surprised -- Hong Kong, Shanghai, Singapore and Kaohsiung in Taiwan. And just to show you where those goods are headed, we’ve listed the top ten U.S. ports at which they arrive.
Here are the numbers behind the mega-port list. This gives you a look at the annual "throughput" of the top ten mega-ports in terms of their exports, by number of containers, to the U.S. Hong Kong is at the top, with close to 350,000 container shipments in the first ten months of 2001.
We also have it broken out in terms of the overall percentages. The top ten ports account for almost half of containers coming into the United States. Again, Hong Kong is the top exporter of container traffic to the United States. It is responsible for approximately 10% of vessel containers coming into the U.S. Shanghai, Singapore, Kaohsiang, Rotterdam and Pusan all hover around five percent. The remaining four ports in the top ten send anywhere from two to four percent.
I believe the United States must work in partnership with the governments where these mega-ports are located to build a new international security standard sea containers. If we can begin by focusing at least on these top ten ports, we will go a long way towards securing almost half of all container traffic coming into the U.S. Moreover, I believe that if the largest mega-ports commit to this concept, others will follow. And if defending our global system of trade is not a compelling enough reason to join, we can offer further incentives, such as expediting the processing of containers "prescreened" at those mega-ports that participate in the Cargo Security Initiative. This would be similar to the benefits we have in mind for those companies who participate in the Customs-Trade Partnership against Terrorism.
At the same time, in providing such incentives Customs would not abdicate its right to conduct trade compliance exams. Those would still be conducted at the U.S. port of entry. But having your containers checked and pre-approved for security against the terrorist threat at a mega-port participating in this program should and likely will carry tangible benefits. For one thing, it is likely that more containers would be routed to and through those ports.
What are the core elements of the container security initiative? It includes prescreening of containers overseas. A first step in this direction begins by examining and comparing our targeting methods with those of our international partners. And we should consider dispatching teams of targeting experts to each other’s major seaports to benchmark targeting and to make sure that all high risk containers are inspected by the same technology that can detect anomalies requiring physical examination inside the container.
The crux of good targeting is advance information. Customs uses it every day in the extensive targeting that we do on vessel cargo that arrives in U.S. ports. We know what is in 98% of the containers that land on our shores, thanks to a system known as the Automated Manifest System, or AMS. Customs has developed an extensive database of information on the shipping industry, its patterns, and all who participate in it through the manifests that every shipper is required to submit. The Automated Manifest System sorts through that vast database and picks up all the anomalies and all the red flags. Whatever deviates from the norm or is otherwise high risk is scrutinized at the port of entry. That system has functioned as Customs’ main method of picking the needles out of the haystacks, and it has served us very well.
However, that works fine for seizing drugs and other contraband. But even if we select a container for inspection by x-ray technology at the port of entry on the suspicion that it contains a weapon of mass destruction, by that time it could be too late. And that is fundamentally why we need to push our zone of security back further in the importation process.
Along with that, we must enhance the quality and quantity of advance information we receive from shippers. Here in the U.S., we are attempting to get shippers and importers to provide more complete information up-front in the import process. While having the shipping manifest is certainly helpful, a complete set of data would include the entry form that is currently submitted by the importer once his or her cargo arrives. Legislation now pending before the Congress would require that information earlier, before arrival at the port of entry. For Customs, it would increase the amount of information we can input into our targeting systems, and thereby enhance our ability to spot the red flags.
In addition, I want to see that information made available to U.S. Customs not just before arrival at our own ports of entry, but before containers even arrive at the mega-ports from which they are transshipped to the U.S. For example, we should know all there is to know about a container that arrives in Rotterdam and is destined for the U.S. before it arrives in the Netherlands. And if an anomaly appears, we should inspect it at that port, the outbound port -- the port of origin; not the port of destination.
Such outbound inspections of containers at the mega-ports will be enhanced by making the latest x-ray inspection machines and radiation detectors available to or required by all who participate in the Container Security Initiative. The use of inspection technology is a major asset in our current efforts to inspect cargo coming inbound to our ports of entry, both in terms of our ability to expedite trade and to detect security breaches in containerized cargo. I am talking about devices such as mobile, truck and seaport container x-ray systems that obviate the need for physical inspection of containers and provide us a picture of what is inside the container. I envision the mega-ports being able to exchange images obtained through the use of such equipment electronically, and to have the capacity to consult with one another on any anomalies detected prior to the release of the cargo for its destination overseas.
Other technology we are exploring includes a crane-mounted radiation detection system to detect radiological materials in containers. This system would supplement the four thousand radiation pagers currently in use by Customs officers that I alluded to earlier.
We’re also moving ahead on the development of electronic seals that would alert us to cargo tampering while in transit. Here is a version of an electronic seal that’s being used right now. Though this isn’t exactly what Customs would use, you can get the idea from this seal. It functions like a padlock, with a transponder attached. It fits over the holes on the handle of a container. Anyone seeking to breach the container would have to remove the pin, like so. But once that happens, a signal goes out to alert the shipper, the importer, or Customs. And you can guarantee that container will be intercepted and examined well before its arrival.
Thanks to President Bush’s Terrorism Supplemental Bill, which he signed last week, U.S. Customs will be able to acquire more non-intrusive technology to protect America. The bill provides substantial funding for additional inspection technology. We plan to make very good use of it, and I would like to see the mega-ports acquire more of this technology as well, to conduct outbound inspections of containers headed for the U.S.
I’ve made an effort to sketch out a few core pillars in the Container Security Initiative. This is a concept that we are still busy refining. However, I believe it is the logical "next step" to the Customs-Trade Partnership Against Terrorism. It brings us up to another level in our layered security framework, from the factory floor to a major choke-point in the global trading system.
As with any new proposal, implementation of this initiative will not be easy. But the size and scope of the task pales in comparison with what is at stake. And that is nothing less than the integrity of our global trading system upon which the world economy depends.
Even before September 11th, with our world becoming more and more interconnected in so many ways, this was the direction we were heading with our efforts to create seamless borders for global commerce. Now, after that fateful day, our agenda has taken on a much greater security dimension, and an indisputable sense of urgency.
And as I have discussed today, our twin goals of facilitation and enforcement are more tightly bound than ever. In protecting America against a terrorist threat, we are looking not only to save lives; we are looking to save livelihoods.
Of course, this is not just Customs’ challenge. It is the challenge of everyone in this room, of everyone who serves the cause of maintaining America’s freedom and security, as CSIS has done for the past forty years.
Together, we must strive, as Tom Friedman put it so well the other day in the New York Times, "to maintain a free and open society while being a little less open, a little less trusting, a little more vigilant and a little more risk-averse."
If history is any guide, I know we will succeed.
Excerpted Remarks of Customs Commissioner Bonner to the American Association of Port Authorities
March 19, 2002
...The modern seaports of today, like the ones you represent, are truly a marvel of mankind's ingenuity and drive. And for those of you responsible for operating them, If I could borrow a phrase from Dickens -- it is the "best of times and the worst of times."
It is the best of times because international trade has never been more robust. Trade volumes have grown substantially almost every year in the past decade despite short-term blips. It is a trend that is expected to continue. Major shipping lines are building more and bigger ships to handle this trade, and many of you are moving ahead with plans to build the infrastructure at your ports needed to handle them.
But it is also the worst of times, because, as most of you already know, our ports are vulnerable. Terrorist groups are not bent on killing Americans; they want to cripple our economy as well. One way for them to do this would be to use the principal means of international trade -- sea containers -- to deliver a weapon of mass destruction, including a nuclear device, to the U.S. And as you know all too well, our global trading system have been designed over the years for processing cargo, not for securing it.
Some might ask, how real is this threat? Besides what you already know about the terrorist attacks on 9/11, I'm sure you've heard the claims that have been made by Osama bin Laden himself that the al Qaeda: They say that they already have a nuclear device. Now, I'm not one to take them at their word, and I don't know if they have a nuclear device or not.
But one thing I do know - Bin Laden and his Al Qaeda have been negotiating over the last five to seven years trying to acquire components and critical materials for nuclear devices as well as other weapons of mass destruction.
I also know this -- I cannot sit in my office and presume they do not have weapons of mass destruction. And I certainly cannot wait until they attack us to find out. I have a duty, and the men and women of the U.S. Customs Service have a duty to take the steps necessary to prevent terrorists from carrying out an attack that could kill many people and disrupt the flow of global commerce through our seaports.
On September 11th, we saw how the heinous and brazen acts of just a handful of terrorists can cause tremendous loss of life and wreak havoc on our economy and our way of life. On that day, the unimaginable became real.
If terrorists used a cargo container to carry out an attack at a seaport, and if you were fortunate enough that it wasn't your seaport, I want you to imagine the pressure you would feel to close your own port. Think of your obligation to protect the citizens in your local community, to protect the huge investment in your piers, cranes, terminal equipment and ship channels, to reassure your workers and political leaders that the containers in your port were safe. Think about it for a moment...because
I just thought about it because I share these same obligations. I've thought about what might happen if such an event occurred. And I've thought about what can we do to prevent it from happening in the first instance.
I want to share those thoughts with you today.
Today, approximately 90% of cargo moves by container, much of it stacked several stories high on huge container ships that transport those containers between the world's mega-ports. Over 200 million containers per year are now moved between those ports, constituting the most critical component of global trade.
Oceangoing sea containers are a vital artery of the U.S. economy. Indeed, 46% of all goods imported into the U.S. -- by value -- arrive at our nation's seaports, mostly in containers. But as significant as sea container traffic is to the U.S. Economy, they are even more important to other trading nations, like Japan, Singapore, and the countries of the EU. The fact is: all industrialized nations rely heavily on containerized shipping.
From both a logistics point of view and an economic perspective -- all trading nations -- should be concerned about the ways global trade would be impacted by a catastrophic event involving sea containers -- to be specific, by the use of a container as a means to smuggle a weapon of mass destruction into the United States. And it is by no means farfetched.
Some of you may recall that last October, Italian authorities found a suspected Al Qaeda terrorist -- an Egyptian national -- inside a shipping container bound for Canada. Inside the container were a bed and bathroom for the journey to Halifax, as well as airport maps, airport security passes and even more ominously an airplane mechanic's certificate.
Of ever-greater concern are the possibilities that international terrorists such as Al Qaeda would attempt to conceal and smuggle a nuclear device -- crude or otherwise -- in one of the more than 15,000 sea containers that arrive at U.S. seaports each day -- the "nuke-in-the-box" scenario. None of us want to imagine the devastation that would follow from the detonation of even a small nuclear device at one of our seaports.
As horrid as the immediate damage would be, consider what would become of our nation's seaports and global trade if a sea container were used to conceal and then detonate a nuclear device. Simply put, the shipping of sea containers would stop. Cold! The American people, for one, would not permit one more sea container to enter the United States until there was a significantly greater assurance that no additional terrorist weapons would be smuggled into our country. This would quickly bring the global economy to its knees.
Before 9/11, not even fiction writers like Tom Clancy dreamed of a scenario where all commercial and private aircraft would be ordered out of the skies. But it happened. In fact, all commercial airline traffic in the United States stopped for nearly a week, costing the airlines and the American economy billions of dollars. The airline industry still has not recovered from this loss.
I don't have to tell you that even a two-week shutdown of global sea container traffic would be devastating, costing billions. But the shutdown would, in all likelihood, be much longer, as governments struggled to figure out how to build a security system that could find the other deadly needles in the massive haystack of global trade -- that could deter the system from being used in the first instance.
So, the system is vulnerable and the stakes are high. We should do everything in our power to establish a means to protect global sea container trade, and we must do it now -- before a devastating event occurs. We must implement a system to detect and deter threats to our global trading system.
For that reason, I have proposed a container security initiative -- or CSI, as we call it -- which would establish a security architecture for the protection of global sea container trade. CSI is designed to build a defense against terrorist smuggling, using a combination of government resources both here and abroad, and an unprecedented level of information sharing between Customs administrations and between government and industry.
Despite the daunting size and scope of the container shipping industry, we can make it work.
CSI is comprised of four core elements:
First, establish criteria for identifying high-risk containers based on advance information risk targeting.
Second, pre-screen containers before they are shipped to the U.S.
Third, use technology to prescreen high risk containers, and
Fourth, use smart and secure containers.
The main principle behind this program is to push the cargo screening process outward - to make our border or seaport the last line of defense, not the first line of defense. U.S. Customs can no longer wait for a ship to discharge its cargo to decide what we want to examine. By then, it could be too late.
For starters, I am concentrating our efforts on the "mega-ports" of the world -- the largest foreign container ports -- and specifically those ports that send the highest volumes of containers to the United States.
From a security standpoint, it would make little sense to start this initiative anywhere else. That being said, the CSI will not be, and should not be, limited, to these mega-ports. It should include all the ports of the world.
Container traffic flowing into the U.S. arrives from two predominant areas - Asia and Europe. The mega-ports are easily identified. What is extremely important to note here is that the top ten ports exporting to the U.S. -- just ten ports -- account for nearly half of all the container traffic entering the U.S.
The top ten ports include Hong Kong, Singapore, Rotterdam, Pusan, Bremerhaven, Tokyo and Genoa.
I believe, the United States must move quickly in partnership with the governments in the countries where these mega-ports are located to build a new international security standard for sea containers. If we can begin by focusing at least on these top ten ports, we can secure half of all container traffic coming into the U.S. Moreover, I believe that if the largest mega-ports commit to this concept, others will follow. As Shakespeare said, "as the night follows the day."
Under CSI, we want to know all there is to know about a container that arrives in a foreign port destined for the U.S., before it arrives in that port. And if an anomaly appears, we should inspect it at that port, the outbound port -- the port of origin, not the port of destination.
To do this, we need far better, and far more timely manifest information from carriers. The Hollings/Graham Seaport Security Bill, Senate Bill 1214, for example, would give us the ability to get that information. As I'm sure you already know, the bill has passed the Senate and is awaiting action in the House.
This legislation would give me the ability to mandate complete manifest information before a vessel arrives in the United States. But even that's not soon enough. We need that information before the container is loaded on board the ship bound for the United States.
And as I did with air passenger manifest information, once I have the legal authority to obtain timely and complete cargo manifest information, I will move swiftly to get that information. The manifest description "Freight all Kinds", for instance, will quickly be a relic of the past, just like sailing ships and sextants. This kind of vague description on cargo manifests is no longer acceptable in the post 9/11 world.
Using the latest x-ray and gamma ray inspection machines and radiation detectors will permit rapid screening of outbound containers from their mega-ports. This technology allows us to quickly detect potential security breaches in containerized cargo. I am talking about devices such as mobile container x-ray machines that obviate the need for physical inspection of containers to determine a security risk and provide us an image of what is inside the container. I am talking about radiation detection devices. U.S. Customs already uses this equipment to screen containers that pose a risk on arrival.
We're also moving ahead on the development of electronic seals that would alert us to tampering of a container after it has been screened. Here is a version of an electronic seal that's being used right now. [shows seal] It functions like a padlock, with an electronic chip that can alert us to any tampering.
But this would be only one part of a "smart box." Motion detectors or light detectors should also be used to warn of any attempt to penetrate the container by bypassing the seal. Some containers in use today already contain devices to make them smarter. Refrigerated containers, for instance, keep track of the temperature inside the container during its entire voyage, to be certain that the meat isn't spoiled.
The Container Security Initiative is not just a theoretical program. And the Customs Service has already taken the first steps to make CSI a reality.
Last month, three U.S. Customs inspectors began working at the port of Vancouver. They are using U.S. Customs computer systems and databases to target high-risk containers that are being off-loaded in that port for rail or truck shipment to the United States by truck or rail. These inspectors are working side-by-side with Canadian Customs inspectors. When U.S. Customs inspectors identify high-risk containers, they work with Canadian Customs inspectors to inspect them using gamma ray imaging technology. This is the same type of inspection we are currently performing domestically at our seaports, but it is now being done before these containers move toward the U.S.
Beginning next week, U.S. Customs inspectors will also be stationed at Halifax and Montreal, and Canadian Customs inspectors will be stationed at the port of Newark and the port of Seattle.
These steps are part of the 30-point "Smart Border Accord" signed by Governor Ridge and Deputy Prime Minister Manley in Ottawa last December.
Soon, we will prescreen all 500,000 containers that arrive at these three ports heading for the U.S., so that we can wave them through the fast lane when they ultimately arrive at the U.S. border. That is 500,000 containers that no longer will clog our already congested U.S.-Canadian border crossings. But these containers must and will receive the same scrutiny in Canada that they would if they had first arrived at a U.S. seaport.
This program with Canada is the cornerstone of the larger CSI. We are already talking with port officials in Europe and Asia, laying the rest of the foundation for the initiative. In our meetings thus far, officials have been very receptive to this strategy. They know it is in their own self-interest to take steps to protect their people, their ports and their economies.
Here in the United States, we are also working on another critical part of our strategy to push security beyond our physical borders: We are partnering with large importers and other members of the trade who see tight supply chain security as in their best interest. We are designing programs with them. And companies are lining up to join.
This government-industry program, which we call the Customs-Trade Partnership Against Terrorism, or C-TPAT, has been developed in partnership with international businesses and major trade associations. We told them our needs, and they told us their needs. Together, we've come up with a plan that is a template for any company to follow. Under the C-TPAT program, importers have voluntarily agreed to take steps to increase security of their cargo from the foreign loading dock to the U.S. Border And, in return for their efforts, we will reduce their inspections and other Customs compliance burdens. In fact, we intend to give companies that partner with us THE FAST LANE across the border.
Most of the steps importers have agreed to take under the program are common sense. Under C-TPAT, they will conduct a comprehensive self-assessment of their own supply chain security and take steps to substantially improve physical security, personnel security, access controls and other actions, that together strengthen the overall supply chain and improve ultimately the security of our borders.
Most importantly, C-TPAT participants communicate their security guidelines to their business partners and suppliers both here and overseas. This leverage extends the reach of our efforts to businesses in all aspects of the supply chain.
We realize that we must also partner with out U.S. ports. To this end, I have instructed the Office of Field Operations to convene a working group of ports, just as we have done with importers, carriers and brokers, so we can identify our needs together. We will appreciate your participation in this effort.
Let me tell you know these new programs can also greatly benefit U.S. Ports authority as well.
The program I've outlined - C-TPAT and the Container Security Initiative - are not merely security programs. These programs provide supply chain security, yes, but they also provide important benefits for importers and ultimately, for port operators like you.
Some of the benefits to the importer are clear: fewer Customs examinations, more predictable deliveries, reduced inventory needs, less risk of theft, lower transportation costs, and, of course, no weapons of mass destruction in the container.
No importer, or carrier for that matter, wants to be the company that brought a weapon of mass destruction into the United States.
The benefits to ports should be even more profound: more efficient container movements, greater predictability, freed up terminal storage space, and shorter waits at terminal exits.
Many containers today are released by Customs before a vessel arrives if we are certain about the reliability of the manifest information and, we've determined that the importer is low risk.
Under these programs, we will be able to greatly increase the number of containers we prerelease. If a container has been prescreened and sealed under CSI, we will not, except in rare cases, need to inspect it again when it reaches the U.S. Similarly, if a container has been imported by a company participating in C-TPAT, it is unlikely to be inspected upon arrival in the U.S.
At the same time, we are taking steps to ensure that we are able to inspect every high-risk container that reaches our shores. This year, Customs will purchase 36 additional VACIS machines, to augment the 70 we already use today. Next year we plan to purchase several dozen more. These mobile machines will allow Customs inspectors to look inside a cargo container using Gamma Ray technology. Using them, inspectors can screen a full 40-foot cargo container in about 90 seconds. Once in place, I can assure you that these machines will not gather dust. We will use these machines to inspect inbound containers, and we're going to use them to inspect outbound containers destined for countries that partner with us in CSI.
This could have an impact on your ports. We may need to work with you to identify inspection areas and facilities, as envisioned in the Seaport Security Act. I know terminal space is already at a premium, but I know that if we work together we can find creative ways to accomplish this with minimal impact on the flow of cargo across your piers. In fact, CSI and C-TPAT can potentially save you space at your terminals and increase their efficiency.
For instance, if you know with certainty that most containers on a vessel are cleared by Customs and will not be inspected, you can move those containers off your pier immediately on arrival. That means you can plan your intermodal movements earlier in the process and move more containers directly from the vessel to truck or rail with greater predictability -- both a cost savings to you, and a service to your customers.
With the programs I've outlined, and new technology we are purchasing, I envision a world in the not too distant future where cargo will be segregated into two categories -- low risk and high risk.
Low risk cargo will be prescreened overseas and secured against tampering. It will be cargo controlled by companies who are our partners with U.S. Customs in C-TPAT and shipped through ports that adopt CSI standards. It will be cargo that comes into the United States with hardly a second glance from U.S. Customs when it arrives. It will be cargo on the "fast lane" through your ports.
High-risk cargo, on the other hand -- everything else -- will receive extensive scrutiny. We will thoroughly scrub the manifest information for each shipment before the vessel arrives and screen each container with a VACIS-type machine as soon as it's unladen. Because these VACIS exams will undoubtedly reveal anomalies on occasion, some of these high-risk containers will receive a time-consuming physical inspection as well.
I would encourage you to talk to your customers about C-TPAT and CSI. They are programs that not only benefit the global trading system by securing it against terrorism, but they are programs that directly benefit your ports and your customers as well, as well as the security of our country.
Now, I don't necessarily want to make a bold faced pitch to get you to help us sign up more participants in these programs. But I know if I were in your shoes, I might be taking a few notes to go back home and talk to a few of my best customers. These are truly win-win programs.
The Container Security Initiative and the Customs-Trade Partnership Against Terrorism are part of the layered security framework I envision for the global trading systems of the future.
As with any new proposals, implementation of these initiatives will not be easy. But the size and scope of the task pale in comparison with what is at stake.
And that is nothing less than the integrity of our global trading system upon which the world economy depends.
Even before September 11th, with our world becoming more and more interconnected, this was the direction we were heading with our efforts to create a seamless border for global commerce. Now, after that fateful day last September, our agenda has taken on a much greater security dimension, and a much greater sense of urgency.
And as I have discussed today, our twin goals of increased security against the terrorist threat and trade facilitation are more tightly bound than ever. In protecting America against the terrorist threat, we are looking not only to save lives; we are looking to save livelihoods. Working together, I know we can and will succeed.
Of that I have no doubt.
August 26, 2002
Excerpted Remarks of Customs Commissioner Bonner Before the Center for Strategic and International Studies (CSIS)
...It was just last January - seven months ago - that I spoke here and proposed the Container Security Initiative, "CSI," a revolutionary initiative designed to push our zone of security outward, an initiative designed to protect and secure the global trading system.
I am pleased to be back at the Center to tell you where we are on CSI, and to discuss some of the other Homeland Security initiatives of the United States Customs Service to protect America from the threat of international terrorism...
...In the months since I unveiled CSI here at the CSIS in January, the Container Security Initiative has moved to the forefront of our government's effort to secure the Nation from the potential terrorist threat using cargo containers. Indeed, the CSI concept is now a major piece of the President's National Strategy for Homeland Security, issued last month.
For those of you who weren't here in January, and as a quick recap for those who were, let me briefly describe what CSI is and what we are trying to accomplish with it.
CSI is a plan to secure an indispensable, but vulnerable link in the chain of global trade: containerized shipping.
Approximately 90% of world cargo moves by container, much of it stacked many stories high on huge transport ships. 200 million cargo containers are transported between the world's seaports each year, constituting the most critical component of global trade. Nearly half of all incoming trade to the United States (by value) - about 46% - arrives by ship, and most of that is in sea containers.
That means that annually nearly 6 million cargo containers - 5.7 million last year, to be precise - arrive and are offloaded at U.S. seaports. Other countries, such as the U.K., Japan, and Singapore, for example, are even more dependent on sea container traffic.
The fact is, all trading nations depend on containerized shipping.
The problem is: there is virtually no security for what is the primary system to transport global trade. And the consequences of a terrorist incident using a container would be profound.
As experts like Stephen Flynn have pointed out repeatedly, if terrorists used a sea container to conceal a weapon of mass destruction and detonated it on arrival at a port, the impact on global trade and the global economy could be immediate and devastating - all nations would be affected. No container ships would be permitted to unload at U.S. ports after such an event. They would not be permitted to enter U.S. Ports until a security system, like CSI, was established and put in place.
This is not a situation where you want to wait until it happens before taking action. We don't want to wait for the "nuke in the box."
Al Qaeda is still a threat. All those thousands of terrorists trained in Bin Laden's training camps are still a threat. And the threat is not just to harm and kill American citizens, it is a threat to damage and destroy the U.S. and the world economy - to attack not just the World Trade Center, but world trade.
To address this threat, I proposed CSI last January. With CSI, the U.S. Customs Service has and is entering into partnerships with other governments to identify high-risk cargo containers and prescreen those containers at the foreign ports before they are shipped to the U.S.
CSI has four core elements:
First, identify "high-risk" containers. In this regard, U.S. Customs has already established criteria and automated targeting tools for determining what is "high risk" based on advance information and strategic intelligence, which permits us to identify "high-risk" containers - and by that I mean containers that could be used by international terrorists to conceal terrorist weapons or even terrorists.
Second, prescreen containers before they are shipped. Do the security screening at the port of departure, not the port of arrival. In Rotterdam or Singapore, rather than Newark or Los Angeles.
Third, use technology to prescreen high-risk containers. Why? So that the screening can be done rapidly without slowing down the movement of trade. This technology includes large scale x-ray and gamma ray machines and radiation detection devices.
As this next visual shows, these machines can detect even lead-shielded materials, or even people illegally concealed inside these steel containers.
Fourth, use smarter, more secure containers. With these, U.S. Customs officers at the U.S. Ports of arrival will be able to tell immediately if a prescreened container has been tampered with. We are already using tamperproof seals as part of CSI, but to develop even smarter containers, Customs is partnering with the Department of Transportation to explore new technologies. Under Operation Safe Commerce, we are looking for even better ways to secure containers, but at a reasonable and appropriate cost.
The way CSI works is that U.S. Customs inspectors work side-by-side with officials from our partner customs agencies at foreign ports - at "CSI" ports. A small group of U.S. Customs personnel target high-risk cargo containers, and they observe security inspections of that cargo, performed by the host nation personnel. These containers are then secured against tampering.
It is a cooperative effort to detect potential terrorist threats to legitimate maritime commerce before the cargo leaves outbound for the United States.
And the program is reciprocal: we send our Customs officers to their ports, and we welcome customs officers from CSI-participating countries to our ports, if a country wishes to send customs officers here.
When I first proposed CSI here last January, I said that our goal was to start the program in the top ten or 20 ports that ship to the United States - in terms of volume of cargo containers shipped to the U.S. Why start with the top 20? Because those 20 ports account for nearly 70%, over two-thirds, of all the containers shipped to U.S. Seaports. That's why.
So, seven months later, where are we regarding CSI? So far, six nations have adopted and agreed to implement the Container Security Initiative. In addition to Canada, with whom we pioneered the CSI concept, they include The Netherlands, Belgium, France, and Germany. Singapore has also indicated that it will participate in CSI.
This represents 6 of the top 20 ports - the Ports of Rotterdam, Antwerp, Le Havre, Bremerhaven, Hamburg, and Singapore.
So, CSI is not just an interesting policy idea. It is a reality. And the agreements we have with other countries are not just concepts on paper that are years away from actually being implemented. We are already putting them into action.
In fact, I am pleased to announce that the first team of U.S. Customs personnel are being deployed today in the Port of Rotterdam. That means U.S. Customs targeting personnel, working alongside Dutch Customs, will be targeting and screening cargo outbound from Rotterdam to U.S. Ports CSI will now become operational in Rotterdam - Europe's largest seaport. And I expect that CSI will be operational in Le Havre, Antwerp, Bremerhaven, Hamburg, and Singapore soon.
This is truly remarkable - being able to implement CSI as quickly as we have. Placing U.S. officials in a foreign country is usually a slow and difficult process. Weve accomplished this at lightening speed - from concept to implementation in a matter of months.
And the Netherlands was the first, outside of Canada, to help us make it happen. I am deeply grateful to a number of people for this - especially Cliff Sobel, the U.S. Ambassador to The Netherlands, and Helma Nepperus, of the Tax and Customs Administration of The Netherlands' Ministry of Finance.
Let me also say: This is exactly the kind of "Smarter Border" that Governor Ridge has envisioned, and he has supported CSI all the way. It would not have been possible without his leadership and the leadership of President Bush.
We have been developing CSI on a bilateral basis, an approach that unquestionably has permitted us to obtain agreements and implement CSI quickly, far more quickly than would have been possible working solely through multinational forums. But we have also been promoting the Container Security Initiative in multinational forums, such as the G-8, the World Customs Organization, and the International Maritime Organization.
At the summit in Kananaskis, Canada in June, the G-8 issued an action initiative, the Cooperative G-8 Action on Transport Security, that strongly endorsed CSI principles and recommended implementation of CSI between ports within the G-8 nations and ports of non-G-8 nations as well.
Also in June, I made a joint presentation on container security with Commissioner Rob Wright of the Canadian Customs and Revenue Agency to the World Customs Organization in Brussels. After the presentation, the 161-member nations of the WCO unanimously adopted a resolution on container security that also strongly supports CSI.
With excellent assistance from the U.S. Coast Guard, the International Maritime Organization is also supporting the need for this container security regime.
The reasons why many countries are signing up to participate in CSI are fairly straightforward. First, the bottom line is that CSI offers real protection, on a day-to-day basis, for the primary system of international trade - a system on which all national economies of the world depend.
Second, in the event of an attack using a cargo container, the CSI network of ports will be able to remain operational, because those ports will already have an effective security system in place -one that will deter and prevent terrorists from using it. So joining CSI is a relatively inexpensive "insurance policy against terrorism" that will provide CSI ports with protection from shutdown if an attack occurs.
In other words, the shipping lanes between Rotterdam or Singapore - between CSI ports - and U.S. Ports would remain open. They would not need to be shut down.
Not only does this protect the economy of the Netherlands, or Singapore - every nation that joins CSI - but it protects that nation's principal ports from severe disruption from both an economic and security perspective.
Greater security does not have to mean slowing down or choking off the flow of trade.
In providing security for a transportation system, we ought not kill the system, or make it so inefficient or cumbersome or expensive that the system is hurt.
In thinking about security, what we wanted to achieve with CSI is a system that not only provides a substantial increase in security, but one that also facilitates trade, allows it to move more efficiently and quickly than before 9-11.
And CSI does this.
CSI actually facilitates the flow of trade. When a container has been prescreened and sealed under CSI, U.S. Customs will not, except in rare cases, need to inspect it again when it reaches the U.S.
You only have to do the security screening once. If a container has been screened before it arrives in the U.S., it will not be screened after it arrives at a U.S. port. Currently, every container identified as high risk is being screened on arrival to the U.S. With CSI, it will be unnecessary to do this screening here, if it has been done - "there" - at a CSI port.
The screening at a CSI port takes place during the "down time" at the outbound port. Most containers sit on a terminal - on average - for several days waiting for the vessel to arrive and be loaded. We can use this window of "down time" to screen the container for security. On arrival at the U.S. seaport, the CSI-screened container can be released immediately by U.S. Customs and be on its way. High-risk containers that have not come through a CSI port will be delayed until U.S. Customs can do a security screening here in the U.S.
CSI therefore increases the speed and predictability for the movement of cargo containers shipped to the U.S.
I want to make it clear that our CSI efforts will not stop at the top 20 ports; they were simply the logical place for us to start. As soon as we get CSI in place in many of the top 20 ports - and we are close to doing so - we will expand CSI to other strategic ports. In fact, we are already in discussions with several of the countries with such ports.
Our objective is to have CSI in place at all ports that ship a significant volume to the United States, or that are strategically significant, such as Dubai, Karachi, and Port Kelang in Malaysia. The more ports that sign on, the greater the protection of the global trading system - containerized shipping.
In order for CSI to work most effectively, there must be good targeting - the ability to identify high-risk containers. And good targeting depends on complete, accurate, and timely information about containers being shipped - what is in it, who is shipping the goods, where it originated, and so on. Such information is essential to U.S. Customs' Automated Targeting System.
It is for that reason that three weeks ago, on August 8th, U.S. Customs published a proposed regulation in the Federal Register that requires advance manifest information - and it requires transmission of that information 24 hours before lading at the foreign port.
The proposed regulation will also eliminate incomplete or vague descriptions of cargo, such as FAK (Freight of All Kinds) and STC (Said to Contain). In the era of international terrorism, these kinds of vague manifest descriptions are no longer acceptable.
Analysis of the complete and accurate manifest information before lading will enable overseas Customs personnel to identify high-risk containers effectively and efficiently, while ensuring prompt processing of lower risk containers.
The proposed regulation is essential for CSI to succeed.
I want to emphasize, though, that the regulation is not something that would apply only to cargo shipped from CSI ports; rather, it will apply to all cargo shipped to the United States from all seaports.
We will analyze the information we receive at U.S. Customs, using our Office of Border Security, to better target containers in advance of their arrival from non-CSI ports. Indeed, having the data in advance of lading - or loading - will permit, when exceptional circumstances demand it, "load, no load" directions to carriers of containers to be shipped to the U.S. from non-CSI ports.
I hope to be able to put out a final regulation within about two to three weeks.
In addition to implementing CSI, and developing the regulation that is essential to CSI's success, we're also working on the next logical extension of CSI - applying that program's targeting and pre-screening principles and methods beyond sea containers to air cargo. With the Department of Transportation, we are developing an Air Cargo Security Initiative - Air CSI - so stay tuned.
As U.S. Customs takes steps to improve security, we need to keep in mind that the private sector can play a big role in these efforts - a role that will complement, but not substitute for, the steps that Customs is taking.
And through the Customs-Trade Partnership Against Terrorism, "C-TPAT," private industry is helping us take steps to improve security throughout the entire supply chain.
C-TPAT is a partnership I proposed last November between U.S. Customs and the private sector. In fact, it is the only significant government-private sector partnership formed in the aftermath of 9/11 to improve security against the terrorist threat.
Through C-TPAT, Customs works closely with the trade community - U.S. importers, carriers, customs brokers, and others. The companies agree to take steps to improve the security of their shipments and the security of the supply chain from foreign loading docks to the U.S. border and seaports. In return, the companies that partner with U.S. Customs - that meet security standards regarding their shipments - will be given the "fast lane" through our land border crossings, and through our seaports.
Having companies provide security for their shipments allows U.S. Customs to concentrate its resources on the high-risk cargo - cargo that poses a potential risk for terrorism.
Because it also improves security along the entire supply chain, while simultaneously expediting the flow of legitimate commerce into the United States, C-TPAT is a "win-win" program - a program through which businesses win and, most importantly, the American people win.
In the short time since we officially launched C-TPAT, the program has already made great progress. To date, nearly 400 companies have signed up and are participating as C-TPAT partners with the United States Customs Service. And those numbers continue to grow every day.
That to me is an astounding response by corporate America. At a time when American business is getting a black eye from a small number of corporate scandals, many, many honest and ethical businesses are stepping forward to invest in the security of cargo systems, without a great deal of fanfare...
...Combating terrorism is, and for the foreseeable future will continue to be, the number one priority of our country and of U.S. Customs. It has to be our number one priority, because the threat of another attack remains very real.
So, as we rapidly approach the one-year anniversary of 9/11, we must not let down our guard. We must continue to do all that we can to thwart future attacks.
For U.S. Customs, this means continuing to implement the President's National Homeland Security Strategy.
It means making better use of data and risk-management principles to identify high-risk goods, vehicles, and people.
It means continuing tightening security at the actual border, but without choking off legitimate trade and travel.
It means pushing our "zone of security" out away from our borders so that the physical borders are not our first line of defense, but our last line of defense.
It means developing and deploying better detection technology and equipment.
President Bush said we shouldn't just be satisfied with things the way they were before September 11th. Our systems should be more secure, and they should also be better and more efficient than they were before September 11. CSI, C-TPAT, NEXUS, and our other counterterrorism initiatives do exactly that.
But even with all that we've done so far, I'm still not satisfied. There's much more that can be done. And I can tell you that I, and all the men and women of the U.S. Customs Service, are continuing to do more - we are more determined than ever in our mission to protect our borders and keep America safe.
October 26, 2002
Excerpted Remarks of Customs Commissioner Bonner At Western Cargo Conference (WESCCON)
...The U.S. Customs Service has an important role to play, indeed, a responsibility for helping to keep our borders and our nation safe from international terrorism, and, let me tell you, we are doing everything we can to protect our nation from further terrorist attacks - to keep terrorists and terrorist weapons from getting into our country.
But at U.S. Customs, we also know that we have an important role to play in making sure that legitimate goods and people continue moving through our borders as efficiently as possible. In fact, this is part of our charge to protect our nation and our nation's economy.
The U.S. Customs Service has twin goals: increasing security and facilitating trade. We know that we must protect American livelihoods as well as American lives. And I reject the notion that these goals are mutually exclusive. They aren't!
In the past year, U.S. Customs has taken steps to expedite clearance at and through the border - at a time when increased security measures could have hindered such expedited clearances. We are doing this through several measures, including, among others, our Free and Secure Trade program, or "FAST," which I expect to be operational at six Northern Border locations by later this year - by this winter - and the Customs-Trade Partnership Against Terrorism, "C-TPAT," which over 900 companies have signed up for so far.
That's an incredible response to the only significant government-private sector partnership designed to improve security in the wake of the 9/11 terrorist attacks. As you may know, the vetted members of C-TPAT are already receiving benefits from the program, including reduced inspections. That's important to us - we want to make sure companies that partner with us and improve security of their supply chains see and receive tangible benefits from the program.
Good Information - Good Targeting
One of the most important keys to us achieving our twin goals of increasing security and facilitating trade is information. Good information - information that is accurate, complete, and received in time for us to use it most effectively - is an essential component of effective risk management and targeting.
This is common sense: good information enables us to more accurately identify what is "high risk" - what may be a potential threat. And what isn't.
And it thereby enables us to facilitate the processing of what is low risk, or absolutely no risk whatsoever.
Proposed Regulation And this brings me to the main focus of my talk today - the advance manifest regulation, or so-called "24-hour" rule I proposed in early August. That regulation, as you know, would require ocean carriers to provide information 24 hours in advance of lading at the foreign port, for cargo being shipped to the U.S.
The proposed regulation also requires carriers to obtain and provide more complete information on the contents of that cargo. It would eliminate incomplete or vague descriptions of cargo, such as FAK (Freight of All Kinds) - descriptions that are incompatible with our need to target and secure containers that pose a potential high risk for terrorism.
I proposed this regulation in an effort to improve our risk management and targeting capabilities - and to improve them in a meaningful way. Good targeting and good information go hand in hand. And, as I said before good information not only means information that is accurate and complete, but also information received in time for us to use it most effectively.
Analysis of the complete and accurate manifest information before lading, as proposed in the Customs regulation, will give us the opportunity to identify high-risk containers before they leave outbound for U.S. ports. We would be able to locate a potential threat, and make sure that whatever needs to be done to eliminate that threat is done before the vessel sails, not after it arrives - which, in the age of potential nuclear terrorism, would be too late.
CSI and the Proposed Regulation
This is the same principle underlying our Container Security Initiative, or CSI. CSI is based on one simple, and unassailable, premise - the American people, and the global trading system, are more secure if we screen cargo containers that present a high risk for terrorism as early as possible, and certainly before they reach U.S. shores. As many of you know, CSI involves targeting and screening high-risk containers before they are loaded and shipped to U.S. ports - in Singapore or Rotterdam instead of when they reach Newark or Los Angeles or Seattle. This provides improved security for our nation, for our seaports, and for the primary system of global trade itself - containerized shipping.
It also makes trade more efficient. The screenings can be done at the CSI ports during periods of down time - the time period where containers sit on the docks waiting to be loaded on a vessel.
And, once the screening is done "there" - at a CSI port - it will not ordinarily need to be done again here in the U.S. You do not need to do the security screening twice. Nearly all CSI-screened cargo will speed right through on arrival in the U.S. It will get the fast lane into U.S. commerce.
We started implementing CSI with Canada last spring. And several countries in Europe and Asia are now part of the CSI program. In fact, just yesterday President Bush and President Jiang Zemin of China announced that China has agreed to join CSI in principle, bringing the number of ports that are part of CSI to 13 - that's 13 of the top 20 ports in terms of cargo shipments to the U.S. And CSIs momentum continues to grow. Nearly one half of all containers shipped to the United States come from these thirteen ports.
So CSI provides greater security as well as efficiency benefits for trade. It helps us achieve our twin goals. The proposed Advance Manifest regulation would do the same - the regulation is in fact essential to CSI's success. Without the advance information sought in the proposed regulation, we could not effectively target and identify high risk containers and we could not provide the added measure of security that comes from CSI. Nor could we provide the benefits of CSI to the trade, such as the "fast lane" through U.S. ports upon arrival.
Comments on the Proposed Regulation
I think it would be fair to say that the proposed regulation has generated a lot of comment. That is understandable, and that is as it should be.
Because the proposed regulation would bring some changes to the way some people in the trade community do business, it is important for us to hear from the various participants of the trade community about it. And we are hearing from them. And we will work with them to address their concerns.
I was impressed by the thoughtfulness of the comments we received - most of which posed operational concerns. The comments also included questions about whether bulk and break bulk cargo should be included, and whether Customs should take steps to protect the confidentiality of certain types of manifest information.
I note, though, that most of the comments recognized the need for better information about containerized cargo. Indeed, I was heartened by the nearly unanimous recognition in the comments that something must be done to improve security within the system. And that is absolutely right. Something must be done to make our system more secure against terrorism, including nuclear terrorism. The status quo is not an option.
We must face up to the frightening reality that, in the post 9/11 world, the United States and the global economy, are targets for further terrorist attacks. Earlier this month, Al Jazeera broadcast audio tapes of Osama Bin Laden and his No.#1 man, Al Zawahiri, in which they vowed to strike again at the economic system of the U.S. and civilized trading nations. And there is a real risk that one of the many cargo containers that enter the United States could be used as the means of delivering such a blow.
I recognize, however, that there are different views on how to implement a regulation to get manifest information farther in advance, and on how quickly such a regulation can be implemented or phased in.
As we move forward with the regulation, we are eager to work with the trade community, taking into account valid concerns raised about the regulation - even after a final regulation is implemented, so that we can continually assess practical operational issues.
Those in the trade community hold an important key to the security of the global trading system and homeland security, and the U.S. Customs Service is committed to working together with the trade to develop a system that works well for those involved.
We have a proven track record. We have already done this with the airline industry, who, like the trade community, hold an important information key for homeland security. Starting last Fall, after 9/11, we worked closely with the airlines to acquire the necessary information for our Advanced Passenger Information System, APIS, which helps us target and evaluate passengers heading to the U.S. who pose potential security risks. We implemented APIS requirements with sensitivity toward the airlines' concerns. We listened to them throughout the process, even amending the implementation timetable and milestones for compliance as necessary. And, I'm happy to say, we have achieved a 99% compliance rate on the critical required data elements.
We want to do the same thing with those involved in oceangoing trade, working with you throughout the process, but keeping in mind the need to put in place a long-term security strategy to protect oceangoing trade. Long-term strategies require small investments today. The airlines have demonstrated that they understand that, as have the companies that have partnered with us in C-TPAT and the countries that have partnered with us on CSI.
We also must keep in mind the need to implement a new regulation in a timely manner. We cannot drag our feet on this. The terrorist threat continues today, and the maritime trading system is vulnerable - unacceptably vulnerable. Frankly speaking, I would suggest that the threat of potential terrorism on the global trading system is the biggest business risk that you and your customers face. It requires that level of attention.
The recent West Coast port shutdown illustrated the dramatic impact even a very temporary port shutdown can have. That shutdown was only 10 days, and as you all know, we are still feeling the effects. You can imagine how much more catastrophic the ramifications of a terrorist attack using shipping containers would be on the global trading system.
Time is our enemy, so, although we know that businesses will need some time to alter some business practices, we also know that all of us must act as quickly as we can.
We have heard a lot of feedback from the brokers and the freight forwarding community about the proposed regulation, including some alternative proposals. There are good ideas out there, and we will continue to listen to them. But as Commissioner, I have the job of determining how we can act now, which we simply must do. That is one reason why we decided not to wait for the legislation ultimately passed in the Trade Act. We appreciate Congress' enactment of the Trade Act, which provides another recognition of the importance of this advanced manifest data and permits Customs to require it in electronic form. But the Trade Act seeks advanced manifest data on all modes, both inbound and outbound, and we're not yet ready to absorb and use that information. So we wrote a regulation that supports what Customs is ready and able to do right now.
Some have suggested that, to implement our proposed regulation, Customs would have to take time to build a system to process the information we are seeking, or that, right now, we may be unable to use the information effectively when we receive it.
Well, let me tell you, we don't have to build a system. We already have a system - the Automated Manifest System, AMS. It is fully operational. We are using it right now, and it enables us to effectively use all advance information we currently receive and that we are seeking in the proposed regulation. In the proposed regulation, we're not asking for anything we can't effectively use. We're doing the responsible thing, only asking for what we can put to use immediately.
In June, we started a domestic targeting initiative that is now operational at all U.S. seaports. It involves use of the U.S. Customs Automated Targeting System, ATS, through which we process manifest information. ATS is a sophisticated rules-based system, capable of sorting and processing vast quantities of information very rapidly, to help us determine which containers entering the U.S. are high risk.
For the vast majority of these 6 million cargo containers entering the U.S. - approximately 97% of them - we already receive some form of advance manifest information. All of that information is currently being run through ATS.
The information is scored and a risk assessment is made in a very short time frame - within a few seconds - and this is done before the vessel carrying the container arrives at the U.S. port. We are now doing our targeting on a national basis, as opposed to on a port-by-port basis, because uniformity is good for the trade, and it is good for us.
What we have proposed to do in the regulation is the same process we are already implementing - we simply proposed completing the process before the vessel leaves the foreign port, instead of before it arrives at the U.S. port. We can accept and use this information slightly earlier, and having it earlier will improve the risk management process - it will provide enormous security as well as greater efficiency and predictability.
Protection and Facilitation of Trade Remain our Twin Goals As the Customs Service presses forward with initiatives we have already developed - initiatives like C-TPAT, CSI, FAST, NEXUS, the National Targeting Center and the proposed Advance Manifest regulation - and as we continue to develop other initiatives that will help us do our jobs better, I want you to remember this: both the protection and the facilitation of trade remain important twin goals of our mission.
It is true that combating terrorism is the number one priority of the U.S. Customs Service - and it will be our number one priority for the foreseeable future. The threat of international terrorism is real and ongoing, and, like it or not, we must adapt our systems to address the new threat we face.
But as we do this - as we adapt our systems - we will continue to work with the trade to make sure that we preserve, and whenever possible, even improve the efficient movement of legitimate trade.
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