POTENTIAL IMPACT/ AFFECTED INDUSTRY SEGMENT:
Passenger, all-cargo, charter operators;
Pre-loading advance cargo information (PLACI) is the term used to describe a limited data set drawn from consignment data provided by freight forwarders, air carriers, postal operators, integrators, or others to regulators in a pre-load timeframe (i.e. prior to loading of cargo on aircraft at the last point of departure for the state requesting PLACI).
The main objective of providing PLACI is for the receiving or intermediate transit state or state of arrival to identify potential high-risk cargo that represents a threat to the aircraft (often referred to as the “bomb in a box”) by analyzing consignment data, which is provided by industry to customs and aviation security authorities early in the air cargo supply chain, and to require any necessary follow up actions.
PLACI provides an initial set of information which is consistently available early in the supply chain and can be reviewed by regulators for indications of potential risk to aviation security. Targeters use this data to perform a risk assessment on cargo shipments, [which will either then enable the shipment to proceed, or indicate a need for additional actions, such as high risk cargo screening - SHR.]
The development of PLACI initiatives was given added impetus by the October 2010 incidents whereby IEDs were placed on aircraft concealed in computer printers. This incident led to the establishment of the US ACAS (Air Cargo Advance Screening), followed by the EU PRECISE (Pre-load consignment information for secure entry) and the Canada PACT (Pre-Load Air Cargo Targeting) pilots.
These pilot projects have sought to test the feasibility of using PLACI for air cargo security risk assessment and mitigation purposes as an additional layer to current cargo security regimes. The pilots have tested different air cargo supply chain business models each of which have had varying degrees of industry participation including those for the express, general cargo and mail segments of the business. Some pilots have included the Regulated Agent/forwarder community.
The (ACAS) pilot is the most completely tested system, having evaluated over 220,000,000 shipments since early 2011. In the ACAS system, carriers and/or forwarders may link directly to the US CBP system and submit a subset of data elements (shipper name and address, consignee name and address, pieces, weight, commodity as listed on the HAWB). These elements, plus the HAWB number it, are known as “7+1”.
Messages describing shipments are sent to DHS in advance of the cargo departure for the United States. This data is reviewed jointly by Customs and Border Protection and Transportation Security Administration personnel to identify threats. ACAS will return message acknowledgements to the submitter, as well as any holds on the shipment. While there is no stated requirement for timing, participants are encouraged to send data as early as possible to avoid disruptions to cargo movement should action be needed. When the program becomes regulated, the requirement will be to submit the data prior to loading the shipment onto an aircraft at the last point of departure (LPD).
PACT: EU (DG TAXUD) is finalizing its UC to include pre-filing PRECISE information beginning in June 2016, with full implementation expected by 2020
ACAS: US CBP must first file a Notice of Public Rulemaking (NPRM), and industry may comment on this document. The filing is expected in early 2016. Subsequent to any modification and adjudication of the NPRM, CBP may implement the pre-filing requirement as part of the SAFE Act. After this is in place, it is expected that US TSA will then update all of its Security Programs to provide the proper procedures for screening and reporting by the civil aviation parties. No time frame has yet been established for this
PACT: No timeline has yet been established by Transport Canada or Canada Border Services Agency (CBSA)
ACTIONS/RESULTS TO DATE:
ICAO and WCO have established a joint working group to establish standards for countries who wish to establish PLACI regimes. TIACA is a member of the group. To date, we have been successful in limiting the data elements , which will be in the upcoming WCO UCC, to “7+1”, as there was regulatory pressure to leave the submission of data “open ended”, which would have required a high degree of cost and effort. The group is currently working on additional standards for filing formats, return messages, and definition of terms.
-no standards have been set for return messages to filers (forwarder or carrier)
-no resolution has been set for addressing “confirmation of screening” vs. industry having to provide details of screening results
-no standards have been set for screening protocols for shipments deemed “SHR”
-no standards have been set for risk analysis algorithms, putting shipments moving through multiple PLACI regimes at risk of receiving different screening instruction resulting in delays
-limited data transmission testing across forwarder and carrier industry other than to ACAS will require greater data accuracy from industry
-while ACAS files into a single system, EU will utilize each country’s customs portal, requiring multiple filings or links for transit shipments
-high cost of direct link to file. Independent portals for industry are necessary.***
-limited testing of “dual filing” (forwarder files before tendering cargo to carrier)
Delays at transit/transfer hubs
High IT costs
Training for multiple PLACI regime procedures
Cost to maintain multiple SHR screening programs in system
Cost of multiple direct filing links
Pre-file with carrier or risk consolidation delays if carrier files upon receipt
Possible elimination of consolidation benefits
If pre-file, but not authorized to screen cargo, may need to segregate SHR shipments to carrier
Downstream delays at transit hubs
Cost of multiple training programs for screening
- Closely engaged with ICAO and WCO on high level principles. Next JWGACI meeting in Brussels, Oct 20-22.
- Work with TSA, CBP, EU, Transport Canada, and CBSA on currently developing programs ACAS, PRECISE, PACT. Ongoing activity. Hosted industry meeting with TSA/CBP in Washington DC to promote awareness and address concerns.
- Promoting Govt sponsored and or neutral*** filing platform to enable industry to file direct w/o cost of linking to destination regulators
*** RESOURCE LINK
(Potential link to resources such as CHAMP, Descartes, etc.)