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Container Security: Is the Layered Approach Working?

Guest columnist Jim Giermanski says the government's five-layered approach to container security is on the right track, but needs significant improvements

By James Giermanski

June 25, 2008 —

On April 2, Deputy Commissioner of Customs and Border Protection Jayson P. Ahern made a statement before the Committee on Appropriations, Subcommittee on Homeland Security, U.S. House of Representatives. One of the topics included in his statement was an explanation of the layers of security used by Customs and Border Protection (CBP) to protect the nation against potential terrorism connected to commerce through U.S. ports.

"CBP uses a multi-layered approach to ensure the integrity of the supply chain from the point of stuffing through arrival at a U.S. port of entry," he said, citing five layers:

The 24-hour manifest;
Screening through the Automated Targeting System (ATS) and National Targeting Center (NTC);
Customs Trade Partnership Against Terrorism (C-TPAT);
The Container Security Initiative (CSI) the Security Freight Initiative (SFI); and
The Non-Intrusive Inspection (NII) program.

The goal of this layered approach, he said, is to combine each of the layers while limiting their combined affect on "hindering the movement of commerce through our ports."

Some of those in the trade community might take issue with this statement, believing that the layered approach has already hindered commerce. Others might take issue with the value of the layered approach in preventing a terrorist attack on a port of entry or interior target within the United States. I think that looking at each layer is important in appreciating this approach to security. Understanding the basics of each layer will indicate the knowledge CBP will likely have of the actual contents of containers reaching the United States.

Layer-1: The 24-hour Manifest
In general, a cargo manifest is a document that indicates the identity and description of the cargo contained in a shipment. There is certainly no problem using data from the manifest to determine contents. However, the manifest is made by vessel carriers, shipping lines that have no idea of actual contents. Therefore, any problem will always be linked to the person or firm that completes the manifest and their real knowledge of the contents of a container. CSI's 24-hour rule places the responsibility of sending the manifest to CBP with the shipping line, specifically the liner that loads the cargo into the vessel at the foreign port, carrying it to the United States, and discharging the cargo in the United States. "Carriers and/or automated NVOCC's will be required to submit a cargo declaration 24 hours before cargo is laden aboard the vessel at a foreign port for any vessel beginning the voyage on or after Dec. 2, 2002." Originally, there were 14 types of data placed on the manifest; today there are 21: