Shipping is is one of the oldest businesses in the world. It was not too long ago that a ship's captain would carry the documents as well as the cargo the documents covered. Upon arrival the every detail would be a surprise, such as the cargo shipped, the cargo that arrived undamaged, damaged and or pilfered. Nothing was known for certain ahead time and thusly shipper's required agents who would work the details out as best as they could on the spot. This process I call packets.
Today we have high speed communication via the internet that also sends out information in packets, but these packages are small so that when received they appear continuous. The recent implementation by U. S. Customs of the 10 + 2 regulation requiring an ISF (Importer Security Filing) 72 hours before a ship's sailing from a foreign port is the first that requires a more continuous flow of information from all the parties involved in the shipment.
One of the biggest changes for steamship companies is to learn how to issue bills of lading numbers before they know the sailing vessel and the cargo that will be shipped. The idea of issuing a blank BL number that will later be matched up to a vessel and its cargo is an alien concept to an old and traditional business such as ocean transport. But this continuous need for information cuts through other traditionalists, such as shippers, receivers, customs brokers, customs agencies and banks to name a few. This blog will observe and discuss processes as we transition from packets to continuous information giving and receiving.
"Over the past 30 years, we have detailed problems with the current fragemented federal food safety system. A total of about 15 federal agencies share some responsibility for food safety, and we have reported that the system has caused inconsistent oversight, ineffective coordination, and inefficient use of resources" said the GAO's background on the report. Our principal complaint is that each regulation is developed as it's own silo within each of those departments.
Years ago the Food and Drug required a Low Acid Canned Food (LACF) process to be filed for those products requiring a high degree of sophistication and technical expertise to safely make. The FCE (Food Canning Establishment) number to register the facility's address filing the process was developed. After the 2002 Bio Terrorism Act was enacted the Food and Drug developed th Facility Registration number program for Prior Notice purposes. The registration effort requires all food facilities to register. Never in the past eight years have I seen any attempt to reconcile the FCE and Facility registration numbers. Some FCE numbers are quite old. I have witnessed entry filing's declaring a modern address for a new factory yet it's process filing listed an obsolete discontinued facility. Apparently no thought was given to cross check when the numbering system was developed and now it is too hard to do so. As it stands today, FDA has the data inhouse to show many violations on a prima facia basis if they could somehow get the two silos to talk to each other. Presently they can't and they appeared to be so disolusioned with the information they get from prior notice that they igonore it and ask CBP for their entry data, which they have trouble reading as well. I say this as an observer with many contact in the food import who has never heard of a single violation of prior notice among my peer group. Not one. Either we are superhuman or FDA is just filing into the ether with no thought of using it or how to use it.
CBP is just as guilty of making a silo out of their 10+2 regulation. Why can't they think of ISF as being a partial entry? Custom's has this arcane rule about entries filed no sooner than five days prior to the arrival of a foreign vessel on U. S. soil. Why not sooner? I can see late entry deadlines, but too soon? CBP is obviously thinking in patches. Get the ISF done. Two weeks later get the entry done. How about one filing for both? Open the file when the ISF is declared overseas and close it when the entry into the U.S. passes 10 days. What, Custom's IT can't handle that many open entries? Give me a break. We file a complete entry dcoument wih our broker three days before the vessel ships from overseas. This document has it all; ISF, Prior Notice and the complete 7501 entry values. Everything! Last August one entry was late because it slipped through the cracks at our broker's while they waited for the 5 days prior to vessel's arrival date. The penalty should have been lodged against CBP for not being able to receive data prior to the vessel's sailing!
At this juncture it looks like the ISF is solidifying into a silo separate from the entry process principally because CBP has given no consideration to getting rid of the five (5) days before arrival as the earliest entry time. Our government at work.