Back to list

A Conversation with Scott Kirk

Executive Vice President, E.J. Brooks Company

:

LQ:Will North America continue to fortify security initiatives?
Scott Kirk: As you are aware the C-TPAT program requirements currently only cover imports into the U.S. I firmly believe that over the next two years, export requirements will also be added to the program. C-TPAT recently signed a reciprocity agreement with Canada (PIP). PIP members now are required to utilize ISO 17712 High Security seals on all cross border conveyances, containers, trucks, rail car doors and tanker hatches. From what I have read, the requirements of the agreement mirror both C-TPAT and the WCO/AEO (Authorized Economic Operator) programs, both of which require the use of ISO seals. Therefore, Canada’s imports become U.S. exports. This will be the beginning of fortification.
On the southern border,Mexican Customs has their own seal approval, which currently is not compliant with ISO 17712. But they are reviewing this standard for the future. Mexico is also piloting a new security initiative modeled after the WCO/AEO (Authorized Economic Operator) program called ACS. Once the security programs between the U.S. and Mexico are reconciled, a reciprocity agreement may also occur.When this happens all of North America will require ISO seals for both imports and export logistics, a further degree of fortification.
With regard to ocean carriers, the U.S. is being pressed at WCO meetings in Brussels to include the container sealing of U.S. exports. Expanding the C-TPAT program to include exports will facilitate a reciprocity agreement between the EU and the U.S.,which is targeted for 2009.
LQ: Can you explain what you see occurring in the air cargo security area within North America and how it is connected to C-TPAT?
Scott Kirk: In November 2007 C-TPAT issued recommended minimum security criteria covering air carriers, particularly on issues regarding the international supply chain activities. Both CBP and the TSA are members of the Department of Homeland Security (DHS). The goal of C-TPAT is to work closely with the TSA which has jurisdiction over airport security.There will be collaboration between the C-TPAT validation process and the TSA “known shipper program” to minimize duplication. Although the TSA has not fully announced all of the details of the Certified Cargo Screening Program (CCSP),the program will adopt many of the C-TPAT security elements and will partner closely with C-TPAT during the pilot phase.
This screening program relates to passenger aircraft that also carries cargo both domestic and internationally. Both the TSA cargo screening and C-TPAT programs are voluntary,but differ in terms of what becomes certified. C-TPAT certifies companies; TSA will certify screening facilities.
LQ: With regard to current government security initiatives, what is voluntary and what is mandated?
Scott Kirk: C-TPAT and the TSA cargo screening programs are voluntary.However,the U.S.Congress is demanding more progress on implementing the various security initiatives. In 2002, the 911 Commission was formed to recommend steps to avoid such a terrorist event in the future. Five years later, Congress concluded that laws should be passed to establish specific timetables.
The 911 Recommendations Implementation Act (H.R.10) was passed and it requires that 50% of all cargo being tendered for shipment on passenger aircraft must be screened by February 1, 2009 and 100% must be screened by August, 2010.This is a massive program involving 15 millions lbs. of U.S. cargo being shipped daily that must be screened and inspected to the piece level.
The SAFE Port Act (H.R. 4954) was also passed in 2007. It calls for the use of CSD’s (conveyance security devices) on 100% of the containers entering the U.S. in 2008 and 100% screening of containers by 2012,which is still under discussion.
Adding to the confusion, within the SAFE Port Act there was a requirement that if the CSD program could not be implemented by April 15, 2008, a letter was to be sent to Congress by DHS to confirm this. Then, six months later (October 15, 2008), the use of mechanical ISO 17712 complaint seals would be mandated to be used on all containers entering the U.S. This trigger date has passed, but this has not been well communicated. Please be aware that the 8,400 C-TPAT shipper members representing approximately 50% of the container volume, will now become 700,000 shippers that will be mandated to use mechanical seals.
The security initiative programs maybe voluntary, but the implementation of the programs are mandated such as the mandate for mechanical seals on October 15th.
LQ: There is some confusion about electronic seals. What are the differences between a Conveyance Security Devices (CSD’s) and E-seals (electronic seals)?
Scott Kirk: A CSD and an E-Seal are not the same, except that they are both electronic. A CSD is a container door sensor similar to the way a home alarm system works on windows and doors at home.When the contacts separate, the alarm sounds alerting the owner that there is an intruder.The only problem is when used in a harsh environment on a container, the contacts can easily send out a false alarm. An E-seal is placed on an outside container door hasp and will alert only when it is physically breached; it will not be activated simply shaking a container in-transit.
A CSD uses active RFID technology. E-seals can use both active and passive RFID as well as a wireless technology called Zigbee which connects to a GPS system.
A CSD is normally fixed to a container system and can only be read point-to point (port-to-port). An E-seal can be connected by wireless connection to a GPS system giving it 24/7 visibility.You can activate an E-seal at the manufacturing level in Asia, for example, and visually track in “real time” to the final destination, such as a distribution center in Chicago.
A CSD is usually tied to a system, which uses fixed readers and an infrastructure that can be very expensive.
An E-seal can be part of a system that doesn’t need an infrastructure, but it is web-based with no infrastructure costs.
LQ: When will electronic seals (Eseals) become more accepted in the market?
Scott Kirk: Electronic seals are the future that is fast approaching.First, it is very important that international standards be established and that has occurred. Brooks has been working on electronic seals for over eight years and has developed a variety of patents for protection.We are currently selling E-seals on an OEM basis.As more logistics and security e-processes are introduced by government and industry, Eseals must be adapted. E-seal reading is essential for validation while not slowing down cargo acceptance.
What has held up the mass market of E-seals so far has been the decision about what technology to use; The ROI associated with the high cost of infrastructure and the per unit cost of the system itself. A few years ago every Eseal was active RFID. Today other technologies such as the internet, passive RFID, GPS cellular are being introduced, which is reducing costs. Including the reusable feature as part of product design has also assisted in establishing a positive ROI.
Another change is the value proposition being provided today. In the past, the value of the E-seal only related to the security of the cargo. However, today’s E-seal, when connected to a web based GPS tracking system, can provide cost effective 24/7 visibility of the goods,which can increase logistics efficiency. Also, Brooks has a GPS system that will also allow the shipper/logistics partner to monitor conditions within the container by using sensors (temperature, humidity, acoustics and light) and monitor it all on a laptop with a browser, using an ID and password. If there is a problem they will be notified by email.
So today the value propositions are tracing and tracking, container monitoring and security 24/7. The least expensive part is adding the E-seal for security. In addition, we are providing our interested parties with a leasing program when lowering internal capital is a requirement.
This broader value proposition appears to be accelerating the adaptation of E-seals on a global basis.
LQ: With all of these standards and mandates are shippers/seal manufacturers complying?
Scott Kirk: E.J. Brooks Company bases its total marketing program on compliance. We also believe that compliance companies provide compliance seals. With this in mind, Brooks has established a leadership role within the International Seal Manufacturer’s Association (ISMA) along with other members to establish compliance rules and regulations that are strictly enforced.
The first criterion was to insist that the ISMA membership, which represents approximately 80% of high security seal sales globally, be ISO 9001:2000 compliant. This requires that all business practices from the product design to customer service processes are efficient and must be annually audited by a third party,not only at the manufacturing level, but also at the headquarters as well. My opinion is that any seal purchaser should demand to see an ISO 9001 certificate from their seal supplier.
ISMA also mandates that all members must test their high security seals according to the performance criteria of ISO 17712 by a certified ISO 17025 independent testing lab. This requirement is consistent with the ISO 17712 standard and is called out in C-TPAT and the WCO /AEO program CBP is begining to request ISO test results during their C-TPAT validations, which will also help develop market compliance.

Back to list