Hi Chris, and thanks for agreeing to join CBRA Interview. Can you first tell a bit about yourself, your background, where you work and so forth?
Sure thing. For those that don’t know me, I’m an ex Customs official and a mediocre hockey player from Canada. I worked at Canada Customs for about 17 years. In 2006, I joined a firm called GreenLine Systems as a Vice President and went to work on contract as a resident subject matter expert for US Customs and Border Protection in their Office of Anti-Terrorism. In Canada I was awarded a Government of Canada Technology Award gold medal and the Canadian Public Service Award of Excellence for leading the design and development teams responsible for the TITAN automated risk assessment system.
I am a co-author – along with you, Juha, and other colleagues - of the World Customs Organization’s Customs Risk Management Study, the Inter-American Development Bank’s Knowledge and Capacity Product on Risk Management of Cargo and Passengers, and the WCO’s "Global Container Security and Identification of High Risk Indicators" that served as a core input to the General High Risk Indicator document.
GreenLine was acquired by A-TS in 2013 and then PAE in 2015. Over the last 10 years, I’ve been responsible for leading the development and providing guidance to internal and external clients and stakeholders for solutions that provide a customized risk management solution to support screening and facilitation of cargo, passengers, and conveyances. I also just completed my Master’s degree in International Customs Administration from the Charles Sturt University in Australia.
It’s great to be here Juha and nice to see you again!
Thanks Chris for the comprehensive background notes, and great to see you too again, since quite some while! In 2015, the Barbados Government initiated an Electronic Single Window project sponsored and funded by the InterAmerican Development Bank. Can you provide an overview of this project?
The Barbados Government recently initiated a major project to modernize Barbados with an Electronic Single Window, or, ESW. Sponsored and funded by the InterAmerican Development Bank, the ESW initiative intends to optimize the management of trade facilitation and border security through the use of new border management technologies to be developed by my firm, A-T Solutions and its partner, a Canadian-based commodity classification specialist, 3CE Technologies. The ESW intends to provide a Single interface for the exchange of trade-related documents between the trading community, customs, and other government agencies with a stake hold in border processing. The ESW will also provide a public one stop user-friendly repository for comprehensive tariff and regulatory trade information, government advisories, and training materials.
Ultimately, the ESW project intends to reduce business costs involved in the movement of goods for export and import, international trade, particularly to maximize the efficiency of Customs and trading processes and improve integration with related agencies that involve legal and business partners in the trading community.
Our ESW seeks to establish an integrated solution for commercial trade processing that addresses both the needs of the Barbados Customs mandate and those of 30 other government agencies, OGAs. It is believed that this initiative will expand the number of OGA programs that interact with Customs commercial processing and deliver a more advanced electronic approach to the collection, consolidation and dissemination of commercial trade data for both the trade community and regulating programs.
Which other government agencies, OGAs – next to Customs – will benefit from the ESW?
At this stage we are working directly with 30 OGAs, including, but not limited to, the following ones: Ministry of Agriculture - Animal Health, Food Safety, Plant Health; Barbados Defense Force; Barbados Drug Service; Barbados Licensing Authority; Barbados Investment and Development Corporation; Barbados Police Service; Barbados Port Incorporated; Barbados Postal Service; Barbados Revenue Authority; Department of Commerce And Consumer Affairs; Department of Corporate Affairs and Intellectual Property Office; Ministry of Finance; Data Processing Department; Department of Economic Affairs - Research and Planning Unit; Immigration Department; Ministry of Health; Port Authority; and, Statistical Service.
We ‘ve learned that some OGA mandates add an additional layer of operational complexity for risk based border management methodologies. In one example, the Ministry of Health in Barbados, MoH, requires a 100% visual or physical inspection for all their regulated commodities. The MoH does not have access to the ASYCUDA – the system developed by the United Nations Conference on Trade and Development, or, UNCTAD, used to record declarations - and therefore the Ministry doesn’t have visibility for what will be arriving until they receive a notification from the consignee or importer, usually done by fax. They also lack access to a historical repository of enforcement data in order to analyze and develop recurring profiles that could be used as a risk management resource. In this sense, the ESW project can help the MoH by giving them access to earlier and updated information of the cargo data when initially reported to begin the decision making process under their protection mandate.
In many cases, our ESW is providing visibility into border processing that the OGAs never had in the past. The ESW does not intend to replicate information that is already collected by the ASYCUDA. However, ESW can monitor controlled goods that enter and leave the country for permit and control purposes.
The ESW can also give an OGA a regular count of “License, Permit, Certificate, Other document”, LPCOs, by commodity or goods within identified periods of time. We essentially are providing the core OGA/LPCO management capability where ASYCUDA does not – in other words, we are closing this gap. However, this is not a knock at ASYCUDA. ASYCUDA is a great system for declaration processing and accounting, but it was never designed to do all things. ESW functions are really not part of its true capability. This project is a great example of how ASYCUDA can work hand in hand with a parallel and complimentary system. Here’s an analogy to consider: I see ASYCUDA as an iPhone. We are a vendor building apps for that iPhone where the app adds large value for developing and modernizing nations. I believe this is a framework for modernization that should be fostered internationally and replicated. I would like to see UNCTAD agree and endorse this type of approach and methodology. It’s time for all of us to collaborate and offer larger value.
Interesting! What do you consider as the most important lessons learned from the Barbados ESW-case, so far?
Well, there are a few I might highlight that I personally think are important:
First, in principle, information visibility for Customs and OGAs is important in order to efficiently apply risk management techniques, reduce release times, and improve physical inspections. OGAs should have access to the declarations made through ASYCUDA in order to find specific threats and create Risk Assessment modules according to the protection mandate of an institution.
Second, there should be greater coherence between different IT systems. ASYCUDA, the ESW and other IT systems of Barbados should work together without any task redundancy. This is where the time savings are found associated with the release of goods. I can’t underestimate how important change management and business transformation is on a project of this nature. I still struggle with this in my own company trying to convince others how important this is. We’ve made sure to include Change Management and Business Transformation Architects on our delivery team in this instance and it has paid off in dividends. Our Barbadian clients praise this approach.
Third, I’d certainly recommend that OGAs use a common risk assessment decision support system. This will guide OGAs through a data exploitation framework using risk-based principles tailored to their mandate and mission. In Barbados, Customs actually has access to an Automated Risk Management System. I seriously think they should consider sharing access with the OGAs. By distributing access to the other OGAs, each agency would have full visibility into all declaration filings, and an ability to scan this information and seek out inspections that could be in violation of their controls or mandate. If this access can be provided, I see this as the greatest single step forward to having OGAs endorse and adopt risk based decisions at the border. This would help lead to interoperability with Customs. Until that happens, we will continue to see conflicting mandates where one agency endorses risk management and the other endorses risk aversion. That’s a real problem.
And fourth, I’d also recommend that when two or more inspections must be done, the inspections should be executed at the same time and location with both Customs and OGAs present. This will reduce redundancy and unnecessary cost for the trade community.
Thanks Chris for sharing these insights! Any final comment or greetings you would like to send to CBRA Interview readers?
Yes, one important thing to take away. There have been many time release studies that have taken place over the years in this region and in Barbados. Current release times sit at approximately eight days for import and export. Now think about that: eight days to import your goods into the country! I believe this timeline is unacceptable in any modern nation or a country that seeks to endorse trade facilitation. Our ESW solution will ideally eliminate many of the redundant tasks that exist today and improve on the time release of import and export shipments significantly and extensively.
Here is an example: Today, an importer or their broker has to file an electronic declaration in ASYCUDA. If the goods are controlled, commonly done for example with meat products, then the importer or the broker has to travel across Bridgetown to the Department of Agriculture and Veterinary Services to apply and pay for a paper permit. Once approved and obtained, they then have to travel back to Customs, and submit the paper permit along with a paper copy of their declaration as a release package. Once duties and taxes are paid, the customs officer stamps up the release and re-releases the shipment in ASYCUDA. A paper delivery authority is provided. The importer makes arrangements to pull their container or shipment out of the terminal or sufferance warehouse and provides the delivery authority to the terminal operator or warehouse keeper. Only then can the goods enter the economy.
If you can appreciate how long that might take – that is currently eight days on average - think about what happens when you have other controlled goods in your shipment, requiring additional visits to OGAS, and possible offload inspections at the port or inland. It’s no wonder the release time sits at around eight days! I have a strong belief this is where all the time savings are. We are automating much of this process in the ESW and will reduce the redundancy of tasks and visits to Customs and OGAs.
The solution to an ESW is in the workflow and approval process. It’s not about scanning paper permits to attach to a declaration. The solution is about interoperability. I’m excited about this. Just think about reducing a release time from eight days to a number of hours. That will be quite the story to tell!
Great! Let’s be soon in touch about writing a joint journal paper on this highly topical project. Thanks Chris for the interview, Juha.
We should! It’s an important topic for the community of WCO and WTO members, donor agencies etc. Talk soon.