World Shipping Council backs “10+2”
World Shipping Council backs “10+2”
The World Shipping Council has submitted comments to the docket in favor of the proposed “10+2” rulemaking that seeks to gain more advance data on the commercial parties involved in producing, packing, shipping and receiving international ocean shipments.
Importers or foreign exporters would be responsible for submitting 10 types of information.
Liner carriers, represented by the WSC, would be required to submit two pieces of information about the shipment’s status and location on the vessel. U.S. Customs and Border Protection wants to plug the data into its automated targeting system to prescreen containers for potential security risks before they are loaded on a vessel at a foreign port. The new information is widely considered to be an upgrade over the manifest data submitted by ocean carriers 24 hours prior to vessel loading, but many international businesses question whether the extra data will actually improve security enough to justify the information technology and logistics costs.
“The strategy and rationale behind this security enhancement proposal are sound and should be supported. If risk assessment is to continue to be a foundation of the government's strategy to protect its maritime commerce, then we fully understand why the government needs better and more complete risk assessment information,” WSC President Christopher Koch said in a statement released in conjunction with the formal comments.
Ocean carriers prefer the current plan over recent congressional directives for 100-percent inspection of containers overseas using large-scale X-ray and radiation detection machines because of the potential disruption to cargo handling operations in ports, many of which lack the infrastructure, space and technical means to support such a function.
The WSC made several recommendations on to improve the final rule. It asked CBP to send timely “Do Not Load” messages to carriers via the Automated Manifest System when a security filing is incomplete or has not been submitted. CBP should rely on the “Do Not Load” message or order a hold in the discharge port, but avoid issuing orders not to unload a container because it would create “operational and commercial chaos.”
The best way to let importers know that their security filing has been received and their cargo is eligible for loading is to assign a unique reference number to an electronic message and that importers be able to view what their foreign agent submitted on their behalf, the WSC said.
The liner group also asked that CBP clarify that the carrier operating the vessel in a space-sharing arrangement be the one required to file a stow plan. It reiterated its preference for transmitting the stow plan 96 hours prior to vessel arrival rather than 48 hours after departure because carriers are dependent on stevedores that load the containers for the actual data. Operational, technology, data integrity, communications factors and weekend work schedules could effect how quickly the carrier receives the information and whether it is accurate. A 96-hour rule would provide more time for the vessel operator to review and correct errors in the stow plan and thus require fewer amendments later on, the WSC said.
Other WSC recommendations touched on bill of lading requirements, freight-remaining-on-board, in-bond moves, container status messages, bonds for parties filing the data, penalties and issuance of an effective date for the rule.
CBP is accepting comments on “10+2” through March 18. ' Eric Kulisch