In comments filed with Customs Thursday, IMRA President Robert Verdisco said IMRA had “serious concerns” about the proposed regulation, which was posted on the Federal Register Aug. 8.
“IMRA believes that any approach to obtaining advance information should, at a minimum, not put containers at additional risk for either theft or tampering,” Verdisco said. “Second, IMRA believes that ships’ manifests — which are de facto public documents — are an inappropriate place to collect sensitive information for high-level risk assessment.
“Customs should be collecting cargo information to those in a position to provide the most accurate information'directly to U.S. Customs prior to arrival, not from carriers or others who have no ownership of the intended sales.”
IMRA added that the proposed rule is “misdirected,” relative to the new legislative requirements contained in Section 343 of the Trade Act of 2002, signed by President Bush on Aug. 6. The act directs the agency to develop a system for collecting risk assessment information over the next year with the help of the trade community.
IMRA said the proposed rule could force containers to wait for manifests to be created prior to lading,'and that a significant number of containers would have to sit before loading on a ship.
“The solution to obtaining early information lies in collecting it from those who actually have it early in the process — the importers of the cargo,” Verdisco said. He added that the early dissemination of information on manifests would give thieves, and possibly drug runners and terrorists “a leg up, as they would have the information they need to steal cargo or conceal contraband or weapons of mass destruction.”
IMRA suggested that a system to collect risk assessment information in a “real-time” manner is more practicable.
IMRA member retailers have facilities in all 50 states in the United States, as well as internationally, and it works to provide industry research and education to work for the benefit of consumers and the mass retail industry.
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The day before F3. Every compliance issue you face - fraud exposure, carrier liability, FMCSA rules, cargo theft, insurance gaps - navigated by attorneys and operators defining best practices in a changing industry.
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