Notes of Working Group discussing - Itco.be

ATTACHMENT 9Notes of Working Group discussing- C-TPAT and the application to ITCO members1 General discussion by all within group to gain a better understanding of C-TPAT andat the same time to measure understanding by members.2 The main areas within C-TPAT were identified, and discussion took place on howITCO as a body should apply this regulation.3 A pack explaining C-TPAT was distributed (this being from SCS a company based inthe US that can provide packs/procedures to anyone that would assist with C-TPATcompliance. E-mail address www.supplychainsecurity.bizAt the same time there is a US government web site customs.gov that also explainsC-TPAT in some detail and at the same time explaining the US government position.From this point the group were able to formulate an action plan that in the first instance wouldgo some way towards the initial stage of complying with C-TPAT.ACTION POINTS1 ITCO Member approach US Customs re Can a general application be made andcertificate issued to a body such as ITCOAction J Silver2 The SCS document to be de-briefed and contents circulated to working groupmembers for comment prior to sending to main body of ITCOAction C V Humphrey3 On receipt of information and subject to 1 and 2 above, then formulate genericprocedures for use by ITCO members.Action C V Humphrey4 If 1,2,3, above is acceptable to US Customs then submit to US Customs for approvaland certificationAction J Silver5 If No 4 above is not permitted then individual applications will be necessary based onthe individual companies interpretation of the de-briefed document mentioned in 2aboveAction ALL ITCO Members

6 SEALS – Discussion centred around what type of seal is required by US Customstaking into consideration TC 104 WG. At the same time to ascertain what areasrequire sealing ITCO would look for minimumThe WG decided that a meeting should be held with US Customs to explain ITCOposition and the difference between freight containers and Tankcontainers re Sealing.Action J Silver7 A further area looked by the WG was the condition reporting of tanks required byISO/TC 104 596A sub group looked at the ITCO ACC booklet and compared this against the abovestandard, the opinion was that the ITCO booklet exceeded the requirement of thestandard and no further action would be required by ITCO8 It was the considered opinion of the WG that an approach would be required toConsignors to have input on documentation, this should be undertaken throughofficial bodies such as CEFIC for Europe and the ACC USA and others around theworld.Jim Silver advised that the full range of C-TPAT info, as it applies to rail, sea & air for shippers,forwarders, Intermediaries and NVOCC's, is available on-line.http://www.customs.gov/xp/cgov/import/commercial_enforcement/ctpat/others/other_security.xml Jimalso provided the 4 separate files that are available off their site. Jim indicated further that the info requestedfrom Customs is company specific and didn't think we can implement the full program via ITCO but we couldoffer the info to our members for their use as needed. As said, the program applies to shippers, freight forwarders,NVOCC's and Intermediaries (and will be of little impact to lessors, investors, manufacturers and surveyors).Depots that provide trucking should also review the documents to determine applicability to their operations.The Customs site "Custom-Trade Partnership Against Terrorism (C-TPAT)"includes the following documents (attached in html).1.) Recommendations2.) Instructions3.) Agreement/Contract to Voluntarily Participate4.) Security Chain Profile Questionaire9. CSC and ISOJim Silver advised he recently spoke with ISO/TC104 Committee Chairman regarding issues expected to bediscused at upcoming meetings held in St. Petersberg, Florida in May.Issues include:(a) mechanical seals (including security, high security and indicative seals) have been defined as they apply tofreight containers , however sealing arrangements have not been specified (further discussed in C-TPAT notes).b) Consideration of Dynamic testing of tanks to replace static tests; and finalisation of rail impact testingprocedural requirements.c) Guidance on container structural integrity as addressed by Spain to IMO due to poor condition of containersnoted in their study. Spain suggested revising CSC to include minimum safe operating condition standards.International Chamber of Shipping replied that their guidelines have been used with good results for many years.Spain now proposes revising Article V of CSC to address modifications to containers, particularly tanks that havebeen modified to the extend where mods may affect the results of the original prototype test . This proposal wouldrequire owners or mfgs to submit modification plans to a Competent Authority (or approved bodies) to determineif original CSC approval can be extended to modified design or if new tests are warranted.Based on (a,b & c) above, Silver recommended ITCO attend the TC104 working group (and related)committee meetings to influence the proposed standards as they will affect tankcontainers. JDBvolunteered Silver to pursue and attend TC 104 meetings on behalf of ITCO (Silver agreed).WG see benefits as :-1 Fast tracking through customs in the US2 Allocation of Own Account Manager by Customs to company3 Reduced delays4 Better utilizatio