NCBFAA Government Affairs Conference CBP ’ s Security Programs – Reviewing the Present and Looking to the Future A Sea Carrier ’ s Perspective Andy Lumley.

NCBFAA Government Affairs ConferenceNCBFAA Government Affairs ConferenceCBP’s Security Programs – Reviewing the CBP’s Security Programs – Reviewing the

Present and Looking to the FuturePresent and Looking to the FutureA Sea Carrier’s PerspectiveA Sea Carrier’s Perspective

Andy LumleySeptember 24, 2007

FundamentalsFundamentals

Sea Carrier Initiative 1989

Voluntary participation

Collaborative interaction and compliance of all supply chain parties

Take It Personally approach

FundamentalsFundamentals

C S I – Container Security Initiative

C–TPAT

Security Filing (10+2)

C S IC S I

Identify high risk containers

Prescreen and evaluate containers before loaded to a vessel- do not load compliance

Use technology to prescreen containers effectively and efficiently so as not to slow down the movement of goods in trade

Development of “smart” and secure containers

Seeks reciprocity with other customs authorities

52 ports world wide are CSI operational

C-TPAT Security Criteria C-TPAT Security Criteria Sea CarriersSea Carriers

Business Partner Requirements– Includes customers, operating partners, service

providers

– Security procedures for legitimacy and risk assessment

Container Security– Container inspection

– Container seals

– Container storage

C-TPAT Security Criteria C-TPAT Security Criteria Sea CarriersSea Carriers

Physical Access Controls– Boarding and disembarking of vessels

– ISPS – International Ship and Port Security Code

– MTSA – Maritime Transportation Security Act

– Employees

– Visitors/vendors/service providers

– Challenging and removing unauthorized persons

Personnel Security – on land and at sea– Pre-employment verification

– Background check

– Termination procedures

– Crewman control

– Deserter/absconder risk and notification

C-TPAT Security Criteria C-TPAT Security Criteria Sea CarriersSea Carriers

Procedural Security– Passenger and crew

– Bill of lading and manifest procedures

– Baplie EDI file for vessel stowage – 10+2 linkage

– Cargo exception alert

Security Awareness Training

Physical security– Fencing, gates, parking, building structure, locking

devices and key control, lighting, alarm systems and video surveillance

C-TPAT Security Criteria C-TPAT Security Criteria Sea CarriersSea Carriers

Validation Process– Domestic (local office and facility)

– Vessel (one in port)

– Foreign (vessel and facility)

– 3 year re-validation (2008 for OOCL)

– Status Verification Interface (SVI) number and C-TPAT certificate are posted on www.oocl.com Security site

OOCL Security PolicyOOCL Security PolicyRecognition of corporate security responsibilities as an owner and/or operator of vessels, facilities and provider of supply chain services

Ensure security measures are undertaken to protect the interest of customer, company, and staffs (shore and sea)

Participate and support government, carrier and industry initiatives

Commitment to strictly comply with IMO, SOLAS, ISPS and USCG codes

Dedicated to continuous improvement of security measures, and related training and enforcement

Conveyance SecurityConveyance Security

Vessels– Implemented International Ship and Port Facility Implemented International Ship and Port Facility

Security Code (ISPS) requirementsSecurity Code (ISPS) requirements

– All OOCL Vessels and Grand Alliance partner vessels All OOCL Vessels and Grand Alliance partner vessels are ISPS certified, with ship security plans in placeare ISPS certified, with ship security plans in place

– Exception reporting guidelines and clear line of Exception reporting guidelines and clear line of authorityauthority

– Training programs designed for crew providing clear Training programs designed for crew providing clear information regarding any security risks, related to information regarding any security risks, related to cargo procedures, internal and external conspiraciescargo procedures, internal and external conspiracies

– Ongoing review and monitoring the effectiveness of the Ongoing review and monitoring the effectiveness of the planplan

Conveyance SecurityConveyance Security

Containers– All loaded containers must be received with seals intact All loaded containers must be received with seals intact

from shipper. Exceptions (missing or tampered seal) from shipper. Exceptions (missing or tampered seal) must be reported by facility operators to OOCL must be reported by facility operators to OOCL Regional Security Coordinator. Ongoing exceptions Regional Security Coordinator. Ongoing exceptions are addressed with accountable party within supply are addressed with accountable party within supply chainchain

– Visual inspection of empty containers at all depots and Visual inspection of empty containers at all depots and terminals upon in-gateterminals upon in-gate

Conveyance SecurityConveyance Security

New Customers– All new shippers must be contacted by Sales to insure a All new shippers must be contacted by Sales to insure a

valid place of business prior to confirmation of bookingvalid place of business prior to confirmation of booking

– All new importers must be contacted by Sales to insure All new importers must be contacted by Sales to insure valid place of business prior to delivery of cargovalid place of business prior to delivery of cargo

– Suspicious activities must be reported to local Suspicious activities must be reported to local authorities and OOCL Security Organizationauthorities and OOCL Security Organization

Access ControlsAccess Controls

Office– All visitors must register

and show valid picture ID

Vessel– Ship Security Plan

Terminal– North American Terminal Facilities C-TPAT/ISPS Compliant

– Grand Alliance Fareast/Europe Facilities ISPS Compliant

Information– Internally controlled via password

– Externally controlled via registration and password

ManifestsManifests

OOCL strictly complies with 24hour advance manifest requirementsfor USA & Canada & Mexico cargo

OOCL is an AMS & AES participating ocean carrier

Manifest discrepancies are reported electronically to U S Customs and Border Protection. Verbal communication supplementation as required.

OOCL monitors all developing requirements for U S Customs and Coast Guard, and actively participates in CESAC and other government/industry forums to remain aware of best practices and pending legal requirements

PersonnelPersonnel

Where legally permissible background checks are to be performedEmployee history is to be verified by hiring managerA personal interview is required of the candidate by the hiring managerUSA employee hiring requires criminal record searchAny illegal activities (other than fixed penalty traffic offenses) are to be reported by the employee to Human Resources within 2 daysAny employee who conducts himself/herself in an unsatisfactory manner shall be subject to disciplinary action, including summary dismissal in case of serious misconduct, in accordance with local law.

Education & TrainingEducation & Training

Shipboard staff is covered under the Ship Security PlanAll OOCL employees have completed an in-house developed security awareness training course including an exam, with a passing score required.The security awareness training emphasizes the legal requirements under which we operate, as well as company policies and reporting procedures of potential security incident.All new hires are required to take and pass the security awareness trainingPeriodic updates on regulatory and security issues are provided to management distribution throughout the company.

10 Plus 2 Initiative by CBP10 Plus 2 Initiative by CBP(Security Filing)(Security Filing)

Security Filing (SF): CBP proposal to require an additional set of data elements 24 hours prior to vessel loading. Goes beyond the current 14 advance manifest filing information itemsDefinitions of the importer data elements– Manufacturer name and address– Seller name and address– Container Stuffing location– Consolidator name and address– Buyer name and address– Ship to name and address– Importer of record number– Consignee number– Country of origin of the goods– Commodity harmonized Tariff Schedule number (6 digit)

10 Plus 2 Initiative by CBP10 Plus 2 Initiative by CBP(Security Filing)(Security Filing)

CBP requires sea (ocean) carriers to provide two additional data sets– Vessel Stow Plan

– Container Status Messages

Responsible Parties– 10 cargo related items – Importer

– 2 activity related items – Sea (Ocean) carrier via EDI

Target date of implementation– Not yet determined

Future OutlookFuture Outlook

100% inspection debateRadiation portal monitoring for all USA port handled imports by end 2007Extension to overseas load portsOverseas countries advance manifestingUSA export advance manifestingTWIC implementationC-TPAT terminal and port criteriaElectronic sealContainer security device