International Freight Forwarder Association

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TIACA chair sees need to face challenges together

Saturday, July 28, 2012

Michael Steen, Chairman of The International Air Cargo Association (TIACA) warns against acting independently, and stresses the need to cooperate and consult one another in order to decrease security risks.

If there is anything positive to be gained from the challenges facing the world of aviation and air cargo, it has to be the opportunity to grasp the growing momentum for global co-operation among regulators and, most importantly, industry participation ahead of any business-changing decisions being taken.
Understandably, when it comes to aviation security, the only focus for national regulators is to protect their own countries from any risk. And, of course, that risk is considered to be much greater than for others. However, acting unilaterally is not always the most secure option and it can also harm already fragile economies.
One of TIACA’s prime objectives when it engages with government and regulatory bodies is to begin by explaining the vital role of the air cargo industry in terms of the global economy, employment and national economic development. For those prepared to listen, we have a compelling case for why our industry needs to be consulted and involved in any new laws that are directly aimed at the sector. I am pleased to say that a growing number of authorities are listening to us, such as the U.S Transportation Security Administration (TSA), the World Customs Organization (WCO) and the International Civil Aviation Organization (ICAO).
I sense a growing understanding of the value of co-operation. The industry TIACA represents is highly professional, strongly aware of the world we live in, and never complacent when it comes to security. We live with it every moment of every day. We understand and are committed to the highest possible levels of aviation security but by working with regulators, we can ensure that changes are viable, that they do actually deliver the desired level of improvement, and that they do not impede the pace of the air cargo supply chain.         
National authorities are starting to see the bigger picture.  A positive recent example of this is the action being taken by the US, the EU, Switzerland and Canada in concluding mutual recognition agreements for air cargo security. This is welcome and sensible progress towards the shared goals of maintaining the highest levels of air cargo security without impeding international air cargo supply chains.
We strongly support efforts to enhance security of the air cargo supply chain without unduly disrupting vital commercial flows. Mutual recognition of robust security regimes is an important way to further this goal so we commend the U.S., EU, Swiss and Canadian authorities and will continue to support additional efforts to mutually recognize security regimes and to implement global, harmonized standards.
By recognizing each other’s national air cargo security regimes, governments can eliminate duplication of security controls and the costs and time delays associated with this, while ensuring strict air cargo safety and security requirements continue to be met consistently.
We all clearly understand what is at stake. Speaking to delegates at TIACA’s latest Executive Summit in Moscow, Doug Brittin, Director, Air Cargo at the Transportation Security Administration, said the security threat ‘remains high for all of us’. “Our goal, which we know is shared by the industry, is to not lose a plane,” he added.
Brittin recognizes the important support the industry is giving to further enhancing air cargo security and stated: “Together we have made significant progress in enhancing air cargo security in the past few years and industry has risen to the challenge, both in the all-cargo and the passenger carrier segments. We are moving steadily toward closing all gaps. What we have put in place—a risk-based, intelligence-driven approach applying tiered screening protocols—could not have been accomplished without working through the numerous details with industry partnership. TIACA and GACAG (the Global Air Cargo Advisory Group) have played a key role in this partnership approach, and I am confident that by continuing to work together, we can resolve any outstanding and future security challenges.”
In 2010, to facilitate industry dialogue with bodies such as TSA, TIACA was one of the founders of the Global Air Cargo Advisory Group (GACAG) that Doug Brittin referred to, joining forces with the International Federation of Freight Forwarders Associations (FIATA), the International Air Transport Association (IATA), and the Global Shippers’ Forum (GSF) to provide the air cargo industry with a stronger, unified voice in its dealings with worldwide regulatory authorities and other bodies whose decisions directly impact on air cargo. This is designed to make the air cargo industry ‘easier to do business with’ for regulatory bodies. 

Since its formation, the Group has conducted work on a wide range of issues, including:
·         a standard Consignment Security Declaration
·         advance electronic data for air cargo shipments, secure supply chain programs, U.S. and EU security protocols
·         co-operation with U.S. Customs and Border Protection (CBP)
·         targets for e-freight and other e-commerce initiatives
·         the EU Emissions Trading Scheme (ETS), calling for ICAO to create a global industry standard of emissions.
On the issue of advance data for air cargo shipments, we see a further opportunity for constructive, global co-operation. The issuing of ad hoc directives and potentially impractical rules by national regulatory bodies seeking to implement advance electronic information would have an adverse and costly impact on air cargo security and that is why we have called for regulators to work closely with our industry to develop rules in this area. GACAG has also called for broad industry participation in the ongoing Air Cargo Advance Screening (ACAS) pilot under way in the United States, and for all parties to consider the results of that pilot in developing global standards.
As a global industry, we believe it is critical that we work with regulators to develop a global, harmonized approach in this area. We believe there will be great value from our industry members’ participation in the ACAS pilot in the U.S., and on drawing lessons from that pilot towards a globalized and harmonized outcome.
In its position paper on Air Cargo Advance Electronic Information for Security Purposes, GACAG fully endorses efforts to constantly improve security in the international air cargo supply chain and supports the use of advance electronic information for risk assessment purposes in accordance with the World Customs Organization’s SAFE Framework of Standards and other applicable international security standards. The Group supports the use of Regulator-Industry consultation, collaboration and pilot programs as the means of developing these programs, such as the ACAS initiative in the United States led by U.S Customs and Border Protection and the Transportation Security Administration.  

However, we have warned against national authorities taking a non-uniform approach to the implementation of advance electronic data requirements for security because this  could result in added bureaucracy, additional costs and less predictability for the aviation sector. Consultation and collaboration between regulators and the industry are key to finding a workable approach. 
We cannot over emphasize the importance of co-operation. There has been a significant increase in the number of countries seeking to implement advance electronic information but as some countries may not be following the advance electronic information standards published in the WCO SAFE Framework, it is creating confusion and additional costs to the aviation sector. In their respective efforts to further secure the air cargo supply chain, some countries have been releasing ad hoc directives - including consideration of advance electronic information prior to loading - without adequate time for discussion, resulting in regulations that the industry may be unable to fulfill.

TIACA has recommended a series of measures that need to be addressed in order to achieve an orderly rollout of advance electronic information requirements for security purposes. These include a call for authorities to recognize that different segments of the air cargo industry have very different business models such as integrators, consolidation through freight forwarders, and so on. Advance data requirements for security risk assessment purposes should allow for multiple originators of filings based on the availability of the information, while also limiting multiple submissions of the same information. We also believe importers, exporters or their agents should provide authorities with goods declarations (e.g. house waybill information) for security risk assessment purposes as early as possible and that authorities should provide electronic notification of a security concern, where possible, in order to coordinate containment.

Brittin outlined the challenge facing the regulators when he spoke to TIACA delegates in Moscow. Talking about the ongoing ACAS pilot program and the need to provde data flows and timelines, he said: “Can DHS (U.S. Department of Homeland Security) looking at this data quickly analyze, determine risk and get information on which screening method to use to the proper place at the proper time? … the key part of this is moving that trusted shipper concept to a data driven analysis. We want to be able to make a determination based on historical data about the shippers plus incorporate the trusted shipper rule sets into ACAS.” He urged forwarders to be part of this process, stating: “The sooner the data is transmitted the better … we suggest freight forwarders and carriers conduct active discussions with all parties in the supply chain as soon as possible to help determine the outcome and help design the process overall.”
I find his words ‘to help determine the outcome and help design the process overall’ particularly encouraging because it is indicative of the attitude we believe regulatory authorities need to be taking and also demonstrates that the TSA is getting on to same wavelength as the air cargo industry.

We believe this will continue and benefit everyone that shares the goal of protecting the air cargo supply chain and we are ready to play a full and active role in this critical process.  
TIACA is a not for profit trade association for the air cargo industry, pledged to support and assist progressive liberalization of the global market, and easier, enhanced trade between developing and developed economies.  It is a worldwide organization that serves a membership which includes all major segments of the air cargo and logistics industry; airlines, forwarders, airports, ground handlers, all-cargo carriers, general sales agents, road carriers, customs brokers, third party logistics companies, integrators, technology and equipment providers, shippers, and educational institutions. To accomplish its mission and role, TIACA engages in activities that are geared to improve industry cooperation, promote innovation, share knowledge, enhance quality and efficiency, and develop educational programs. TIACA’s activities are aimed to inform both the public and its membership about the role and importance of air cargo, industry developments and technical trends. TIACA is committed to representing and advocating the interests of the air cargo industry at meetings of relevant regulatory bodies including the WCO, ICAO, UNCTAD, OECD and others that are open to trade observers.