!0+2 Requirements

Understanding 10+2 Requirements By Deborah Catalano Ruriani The Customs and Border Protection (CBP) agency's Importer Security Filing (ISF) regulation has become commonly known as the 10+2 initiative because it requires importers and vessel-operating carriers to provide trade data (10 elements and two elements each, respectively) for non-bulk cargo shipments arriving into the United States via ocean. Melissa Irmen, vice president, products and strategy, at Charlotte, N.C.-based trade solutions provider Integration Point, offers these tips for complying with the new regulations.
1.		Remember that 10+2 pertains to goods transiting through the United States, not just imports. Carriers must file data for goods moving through the country for export and for freight remaining on board the vessel.
2.		Be aware of the "flexible enforcement" loophole. CBP will not assess liquidated damages for failure to meet the new requirements until Jan. 26, 2010. In the interim, the agency expects importers to make a good faith effort to comply.
3.		Understand who is responsible for filing the data. The ISF importer bears responsibility for ensuring all 10 data elements are filed correctly, even if the information originates from another trading partner.
4.		Engage your carriers. Carriers must file the container's status message and stow plan. You do not have to tie these elements to the importer data; CBP will make that correlation.
5.		Don't wait until the last minute. Filings must be submitted 24 hours prior to the shipment's arrival in a U.S. port, or upon lading at a foreign port that is less than a 24-hour voyage to the closest U.S. port. To prevent delays, you can send ISFs in advance, even without the two most difficult to obtain data elements -- container stuffing location and consolidator -- as long as you provide these two remaining elements 24 hours prior to arrival.
6.		Know what data can be amended. "Flexibility in interpretation" was introduced for data elements that cause the most concern for compliance, such as country of origin, ship-to party, and manufacturer. You can submit an initial response based on the best available data 24 hours prior to lading, but you must ensure that CBP receives the final data on time.
7.		Learn how to file electronically, or engage a partner to do it for you. All ISF filings must be submitted via the Automated Manifest System (AMS) or the Automated Broker Interface (ABI). You may be a self-filer or you can choose to use an agent. If you don't have electronic submission capability, you'll need to engage a partner to handle it.
8.		Transition now toward electronic filing. Some importers are meeting the 10+2 requirements with manual data entry using commercially available documents. This allows you to test each channel in the supply chain while the electronic data integration is being built.
9.		Know the penalties for compliance failure. The fine for failure to meet ISF requirements was reduced from the value of the shipment to $5,000 per shipment. However, the statement of what constitutes a violation -- such as a misreported shipment or incorrectly stated line items on a filing -- has not been issued yet.
10.		Get help. Consult the CBP Web site (www.cbp.gov/xp/cgov/trade/cargo_security/carriers/security_filing/) for the most current information on the 10+2 regulations.

Refrigerated Transportation

Refrigerated Transport: Really Remote Control

Poultry distributor Simmons Foods is clucking over its remote monitoring solution that helps prevent costly spoiled food loads.

by Dan Calabrese

A truckload of refrigerated and frozen chicken travels from factory to warehouse. The trip takes only a few hours, and the truck arrives at the warehouse at the scheduled time.

SO FAR, SO GOOD.

But it's Friday, and by the time the truck arrives, warehouse operations are winding down for the weekend. Workers keep their eyes on the clock, and wrap up their daily activities. The truck ends up sitting at the receiving dock through the weekend -- with its refrigerated cargo still on board.

As long as the refrigeration unit continues to operate during the next two days, no serious problems will ensue. But if the refrigeration unit fails, a truckload of poultry products will spoil. And that could cost the poultry company upwards of $75,000.

That's just what was happening to Simmons Foods, Siloam Springs, Ark. After experiencing these types of serious losses over time, the company began seeking a solution. It wanted to address its inability to monitor the location or operational status of trailers when they were in route.

Simmons, which distributes poultry products to mass merchandisers and restaurant chains via 10 warehouses in northwest Arkansas, southwest Missouri, and northeast Oklahoma, runs 146 trailers throughout that 100-mile radius -- typically hauling between 65 and 70 loads per day.

"Our trailers might arrive at a warehouse that does not have enough controls to check the units," says Dick Bolen, director of fleet operations for Simmons Foods. "If we drop a trailer at a freezer on Friday afternoon, and the warehouse can't unload it until Monday morning, we face some potential liability. Most warehouses monitor all the trailers on their logs, but if human error occurs, we lose a trailerload of poultry."

After some research and due diligence, Simmons Foods chose a tracking and monitoring software solution developed by Star Trak, Morris Plains, N.J. In addition to tracking the location of a trailer at any given time, Star Trak also allows Simmons to both monitor and control each trailer's refrigeration unit remotely.

SOUNDING THE ALARM

In the event of a refrigeration unit malfunction, the software sounds an alarm at Simmons offices. This allows dispatchers to remotely take control of the unit and either restart it or adjust it as necessary.

"The system provides the ability to turn the refrigeration unit on and off, change the temperature setting, and switch the controls from stop/start to constant run," Bolen says. "Anything a worker can do standing next to the trailer, we can now do remotely from our desktops."

Simmons no longer needs to allocate labor hours to have people walk parking lots checking trailers and their refrigeration units. Bolen is confident the investment has already paid for itself, although he says the actual dollar amount saved is hard to quantify because it involves incidents that probably would have happened but never did.

"System alarms give us a heads-up that a unit has a potential problem, so we can service it before it causes further damage," Bolen says. "We save a lot of money by not letting trailers run out of fuel or oil, for example."

Run out of fuel? Don't drivers pay attention to their fuel gauges?

Well, yes. But Simmons trucks regularly ran out of fuel before the company implemented Star Trak because the units run while they're idling in order to keep the refrigeration running.

"Drivers have access to fuel level information, but they don't always know when a trailer runs unattended for an extreme period of time," Bolen says. "That's why we monitor fuel levels from our desktops. If a unit runs out of fuel, it's an expensive job to bring fuel to the unit, prime it, and re-start it."

ROOTS IN RAIL

The Star Trak technology was first developed about one decade ago, in response to the needs of companies running refrigerated railcars.

"They wanted the ability to adjust temperatures and turn refrigeration on and off regardless of where the switch was," says Jerry Neuner, director of sales and marketing for Star Track. "We had to give customers the power to perform a task that would otherwise be out of their hands for days at a time."

Rail and intermodal carriers were early adopters of the technology, and they relied mainly on satellite connectivity to run the system. But when cellular technology grew more widespread and reliable, it became possible for Star Track to offer a less-expensive, cellular-based version of the system -- generating wide interest from over-the-road food distributors operating within a 100-mile radius, such as Simmons.

"More truckload carriers involved with intermodal transport are choosing the cellular version as the coverage improves," Neuner says. "But it's a foregone conclusion on the rail side; if you're doing refrigerated transport, it's a must-have."

But it was not refrigeration that generated the biggest buzz about Star Trak, Neuner acknowledges. Interest in the product spiked along with fuel prices in 2008 because the system allows carriers to better monitor the location of their trucks and communicate with drivers.

"When diesel fuel prices hit $4.50 a gallon, we saw a big uptick in interest from carriers, and it hasn't gone away," Neuner says. "Many private fleets may not have onboard systems in the cab that allow them to communicate and watch over the load."

DIFFERENT APPROACHES

While Bolen prizes the ability to remotely control the refrigeration unit, others say they get the value they need from systems that report information but don't provide remote control capabilities.

One example: 3S Transportation, Bismarck, N.Dak., which serves Midwest and West Coast refrigerated food wholesalers, uses the GlobalWave system offered by TransCore, based in Ottawa, Ontario, Canada. The system alerts 3S Transportation to any operational issues with its refrigeration units, and the carrier doesn't need remote operational control because the trucks typically aren't left alone.

"We don't have trailers that are running in yards other than our own," explains company consultant Mitch Saville. "When a trailer is off our premises, we have a driver with it."

3S uses the GlobalWave system to do a check-in call, monitoring details such as trailer temperature. If the system turns up anything unusual, 3S dispatch simply directs the driver, who is already on the scene, to check and address the problem.

LEAVE IT TO THE DRIVER

There is also still a school of thought within the refrigerated transport industry that driver vigilance is the best weapon against system malfunctions and spoiled goods.

Judy Turano, general manager of University Park, Ill.-based Dynamic Transportation, says the company's network of 30 independent owner/operators doesn't need a remote monitoring system to protect the frozen foods, boxed meat, and produce they haul to grocers and wholesalers.

"Because the tractors and trailers belong to our owner/operators, it behooves them not to spoil their loads," Turano says.

But the flip side of human vigilance is human error, and enough human error -- in addition to mechanical failure -- boosts demand for remote monitoring systems in the refrigerated transport market.

"Shippers can see the benefit themselves," Neuner says. "Refrigerated transport used to be out of sight, out of their hands. It was a helpless feeling for them. People could walk up and shut off a railcar full of frozen potatoes, and it would be days before anyone could do anything about it."

By offering the ability to monitor and control trailers remotely, solutions such as Star Trax put the power back in shippers' hands.

Business Startups

My project: Start a business

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Starting a business, step by step Step 1 - Assessment Generate or develop your ideas, evaluate their business potential, and find out if running a business is for you. Step 2 - Your business plan An essential tool to plan and finance your business; includes a marketing plan. Step 3 - Starting up Choosing a name, hiring an accountant / lawyer, legal obligations (registration, taxes, etc) Step 4 - Financing Find financing for your business: tips and links Step 5 - First year More on managing day-to-day operations and planning your company's growth