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Expert Insight: Guest Contribution

By James Giermanski,

President

Powers International, LLC

Date: July 13, 2012

Global Supply Chain Comment: "Doors-Only" - A Dangerous Container Security Concept, yet Still the Policy

Doors-Only, while Still the US Standard for Container Security, is Fatally Flawed and Constitutes a Serious Vulnerability to our National Security

In 2007, I said the following when referring to the Department of Homeland Security (DHS) and Customs and Border Protection's (CBP) policy on container security: "Perhaps, the dumbest policy, model, or standard of all is the sealed-door standard."

Five years later, despite technological advances and use by the private sector and military, CBP is still focused on container "doors" as a security measure. CBP has still not developed an alternative.



History of "Door-Only" Security


The history of "door-only" security began in November 2005, by virtue of DHS's Request for Information (RFI), an information-gathering and planning vehicle used by DHS in support of CBP. The purpose of this request was to gather information to identify and evaluate available state-of-the-art container and trailer tracking devices suitable for in-bond shipments. The level of sophistication needed and stated in the RFI seemed clear: "Sensing -- (a) The container and trailer security device must be able to electronically detect closing and opening of either door of the container/trailer. Monitoring the door status must be continuous from time of arming to disarming by authorized personnel."


The former Commissioner of CBP, Ralph Basham, diverged from his predecessor and said in 2007 that "… any device developed to monitor the security of a shipping container must be able to detect unauthorized intrusions anywhere on the container, not just through the doors,(emphasis added) to be part of a layered defense strategy in securing the global supply chain...I'm saying that just because you have a device that secures the doors does not mean that the container is secure. It just means that the doors are secure and not the whole container. If technology is being developed it should be toward making sure the entire container is tamper proof."

But, on December 12 of the same year, Basham's boss, Homeland Security Secretary Michael Chertoff went to the other extreme by stating, "Therefore, effective Oct. 15, 2008, we expect to have the requirement in place mandating that all containers be secured with a standard bolt seal."


Or, in my words, let's just bolt the doors. And, one week before Chertoff's deadbolt-the-doors statement, CBP released an RFI describing its Conveyance Security Device (CSD) requirements. This RFI, like the one two years before, still focused on "doors only," in spite of Commissioner Basham's statement on the need to secure the whole container.


It is also interesting to note that the 2007 RFI still referenced the old "in-bond" shipment problem, known to it and acknowledged in 2005, essentially admitting that for two years CBP had failed to address the in-bond security issue. Therefore, it was ignorant of how many in-bond shipments were accessed during their travel through the U.S., or for that matter what was really placed in the in-bond containers at their foreign origin or during its movement.

 

With respect to in-bond container security, it wasn't until 2012 that CBP requested comments on how to secure and monitor in-bond shipments, admitting that it had done nothing to control access into or monitoring the location of in-bond containers moving through the U.S.

 

Government Refused to Act


In the face of clear direction contained in the SAFE Port Act of 2006, DHS and CBP failed to move at the pace specified in the law with respect to container security. Their knowledge of -- or control over -- container security has been inconsistent with, and lags behind, the progress of the private sector in moving away from doors-only detection and reporting.


At the time of this writing, and with knowledge of private sector advancements well beyond door seals, and in light of videos and Immigration and Customs Enforcement's (ICE) own Power Point presentation (both of which this writer possesses), CBP knows how easy it is to bypass door seals. Yet, DHS continues to develop a doors-only system to be demonstrated in 2012 in a southern-border security pilot called the APEX Secure Transit Corridor Technology (Apex-STC) Demonstration.


The demonstration is to test the integrity of "doors-only" container/trailer security. Specifically, it is a project in partnership with CBP to develop a secure transit corridor for goods shipped between Mexico, the U.S. and Canada. Although set forth in 2011, as of June 2012, DHS has still not been able to initiate this project, even though potential private sector participants have offered to cooperate by offering their technology and processes that surpass DHS's weak "doors-only" mentality.


One of those companies, called ConSearch, has sensors that were demonstrated in 2011 under the authority of DHS at the DHS Container Security Test Bed facility at the Transportation Security Laboratory in Atlantic City, NJ. Those sensors can detect radiation, chemicals, explosives, humans and even cigarettes in a container. Through chemical analysis, they can detect whether a container breach has taken place through any part of the container, including an opened door.

 

While DHS continues to claim that seals along with their electronic seal component constitute a layered security mechanism, they know that the seals can be bypassed. What is worse is that DHS knows about -- and has tested -- technology that can today provide security by detecting a breach into the container through any of its construction.

 

DHS also knows that standard shipping-size containers, which have no doors to breach, could also be tested. Yet, DHS is stuck in its out-of-date, ignorant perception of container security. Its vacuous level of understanding and competence in the area of container security is breathtaking, especially in light of private sector advances and the availability of alternative container security devices and processes.


Summing It Up


Three important observations that impact our national security need to be emphasized. First, statements by former CBP Commissioner Basham reveal that CBP knows that the doors-only concept is flawed and unworkable. Second, CBP has ICE evidence showing that door seals, even electronic door seals, can be bypassed without the knowledge of CBP.

 

Third, DHS has current test data proving the capacity of internal sensors to detect breaches through any part of the container, including doors. Doors-only, while still the U.S. standard for container security, is fatally flawed and constitutes a serious vulnerability to our national security. Finally, one must ask: Who is in charge? And why are they still in charge?


Agree or disagree with with our guest contributor's perspective? What would you add? Let us know your thoughts for publication in the SCDigest newsletter Feedback section, and on the website. Upon request, comments will be posted with the respondent's name or company withheld.

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About the Author

Dr. James Giermanski is the Chairman of Powers Global Holdings, Inc. and President of Powers International, LLC, an international transportation security company.  He served as Regents Professor at Texas A&M International University, and as an adjunct graduate faculty member at the University of North Carolina at Charlotte.  He was Director of Transportation and Logistics Studies, Center for the Study of Western Hemispheric Trade at Texas A&M International University.

He has authored over 150 articles, books, and monographs with most focusing on container and supply chain security, international transportation and trade issues.


 

Giermanski Says:


Statements by former CBP Commissioner Basham reveal that CBP knows that the doors-only concept is flawed and unworkable. 


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