opportunity for agencies to work together to identify areas for cooperation and to reduce burden on industry. Agriculture’s current Export Meat Program, and particularly Tier two arrangements, is a good example where such cooperation would offer a benefit to each agency and to industry. The Export Meat Program is underpinned by legislative requirements and processes to ensure the safety, suitability and integrity of Australian meat and meat products. As a result of these requirements and processes the meat supply chain is very secure. Agriculture’s Export Meat Program provides inspection, verification and certification services to the export meat industry in Australia. The services provided include: The provision of export certification acceptable to Australia’s trading partners; A scientifically-based inspection system that underpins the production of wholesome meat and meat products; A capacity for scientific review of the inspection system; The supply of inspection services and veterinary oversight as required to all establishments registered for export with the Department of Agriculture; Audit activities that verify industry compliance with the Export Control Act 1982 and subordinate orders, including overseas market access requirements and establishments’ Approved Arrangements. A comparison of Tier two registered establishments with the SAFE Framework, which underpins the Trusted Trader Programme, shows strong similarities between requirements. Most of the physical and procedural security requirements of the SAFE Framework would be covered, limiting the number of additional SAFE Framework requirements these establishments would have to demonstrate compliance with to join the Trusted Trader Programme. There are a number of areas where meat export Programme requirements clearly meet SAFE framework requirements, particularly in relation to physical security. For example, the SAFE framework guidance requires written procedures be developed and utilised stipulating how seals are to be controlled and affixed. These procedures are detailed in the Approved Arrangement of registered establishments and are subject to Agriculture audit. There are a number of areas where there are some differences between SAFE framework and meat export Programme requirements. For example, in the area of personnel security, the SAFE framework guidance requires all reasonable precautions to be undertaken when recruiting new staff to verify that they are not previously convicted of security-related, Customs or other criminal offences. Under section 4.05 of the Export Control (Prescribed Goods – General) Order 2005, key personnel of influence must meet a fit and proper person test. This requirement aligns with the SAFE guidance, but only extends to management and not to general employees. There are no obligations to vet general employees in the same way. At least some of these elements are likely to also be met by Tier two meat exporters outside of Agriculture’s regulatory framework. For example, the SAFE
Option of Customs offices for declarations for Customs. New Zealand Secure Exports Scheme Export Exporters – operates from pack to port of loading. Exporters are also responsible for their thrid party operators and logistics includes transporters and brokers. The SES is designed to give New Zealand exporters greater certainty at international borders by minimising Customs delays and by giving exporters priority in trade recovery situations. The scheme is a voluntary agreement between Customs and exporters. It is open to all regardless of the goods exported and the methods to export. The purpose of the scheme is to protect exported goods from being tampered with, sabotaged, smuggled, or subjected to other trans-national crimes. SES partners must maintain an agreed level of security and data integrity in their day to day operations. This includes a commitment to have measures in place to protect goods from the moment they are packed in the container to their delivery at the point of export. This commitment ensures packed containers are secured with a seal or marking. This signals that it is under Customs control and can be considered secure by overseas customs administrations. To become an SES member, exporters must supply Customs with a security plan which is physically validated by NZ Customs. A security plan documents the policies, processes and procedures that a company has in place to ensure that goods for export are securely packed, accurately accounted for and securely The following benefits to the SES scheme participants are offered: Approved secure supply chain from point of pack to port of loading. Predictability of the supply chain because of less government intervention; this means minimal disruption and fewer compliance costs. Discounted Customs transaction fees. Enhanced supply security means minimised trade disruption.
transported to the point of export from New Zealand. Potential SES members must also supply a process map illustrating the flow of and documentation/information from receipt of order to the point of export, a site plan, and a security plan prepared in conjunction with their transport operator. United States Partnership against Terrorism (C-TPAT) Import Whole supply chain Excludes warehouse operators Includes ports and foreign manufacturers C‐TPAT to safeguard the world's vibrant trade industry from terrorists, maintaining the economic health of the US and its neighbors. The partnership develops and adopts measures that add security but do not have a chilling effect on trade, a difficult balancing act. When they join the anti‐terror partnership, companies sign an agreement to work with the US Customs and Border Protection (CBP) to protect the supply chain, identify security gaps, and implement specific security measures and best practices. Partners provide CBP with a security profile outlining the specific security measures the company has in place. Applicants must address a range of security topics and present security profiles that list action plans to align security throughout their supply chain. C‐TPAT members are considered low‐risk and are therefore less likely to be examined. This designation is based on a company's past compliance history, The following benefits to the C-TPAT participants are offered: Reduced Examination Rates for C-TPAT Importers Access to the Free and Secure (FAST) Lanes Stratified Exam Benefit for Importer Partners Front of the Line Processing Business Resumption Expedited Trade Processing Access to a Supply Chain Security Specialist (SCSS) Access to the C-TPAT Portal System
ATTACHMENT B –ALIGNMENT WITH INTERNATIONAL STANDARDS Self Validation Ongoing self-management Ongoing management SAFE Framework The trusted trader will “establish a self-assessment process to manage and monitor performance.” While this requires a trusted trader to establish internal processes, it does not stipulate whether the Customs administration should impose a self-assessment as a part of the accreditation process. The conditions and requirements of the programme “must be fulfilled within prescribed time limits determined by the authorizing Customs administration. The time periods may vary according to the particular role played by the applicant and other specifications that will be determined by the complexity and nature of the trade being undertaken.” The trusted trader may, “in conformance with the criteria set out in the” programme, “be requested by the Customs administration to complete periodic reports capturing the information” in accordance with identified supply security and trade compliance standards. There is no standard period under the WCO SAFE Framework for revalidation. “The monitoring process may consist of audits based on risk or cause and, where appropriate, random spot checks by Customs.” Australia - proposed Option 2(A) Includes a self assessment Timeframe determined by the role of the Trusted Trader and nature of the trade being undertaken. Annual certification by a Trusted Trader that they continue to meet the standards established by the Programme. Requirement to notify of relevant changes to their business operations. Revalidation after specified period or following the Voluntary disclosure of any supply chain security or trade compliance incidents or irregularities.
To account for these uncertainties, the following assumptions have been made to estimate per business costs. These estimates assume all Trusted Traders will be required to meet the security training requirement. Depending on the design of the security training requirement, it may be possible that some Trusted Traders may already satisfy the requirement through their existing training practices, and thus would not incur any regulatory costs associated with the requirement. Assumption Source Value Developing a new training program, and embedding this in operational procedures Staff time required to develop and embed PwC (2012) Chemical Security Regulation Impact Statement: Precursors to homemade explosives. 22.5 Hourly staff cost OBPR (2014) Regulatory Burden Measurement Framework: Guidance Note. $59.85 Total cost per business (on year of joining) $829.95 Providing training to current staff Total number of Australians employed, June 2013 ABS (2014), Labour Force Australia, cat no 6202.0 11,476,586 Percentage of employment accounted for by medium/large businesses ABS (2012), Small Business: An economic overview 53% number of medium/large businesses, June 2013 ABS (2014), Counts of Australian Businesses, including entries and exits, cat no 8165.0 54,128 Average number of employees per business Calculation 112 Percentage of employees that would be required to undergo training ABS (2012), Employee hours and earnings, cat no 6306.0 10% Length of training (in hours) Approximation 1 Total number of training hours Calculation 11 Cost per hour OBPR (2014) Regulatory Burden Measurement Framework: Guidance Note. $59.85 Total cost per business (on year of joining) $415 Providing training to new staff Average number of employees per medium/large business See above 112 Average annual turnover RBA (2012), Labour Market Turnover and Mobility 20% Percentage of employees that would be required to undergo training See above 10% Number of new employees that would be required to undergo training Calculation 2 Length of training (in hours) See above 1 Total number of training hours Calculation 2 Cost per hour OBPR (2014) Regulatory Burden Measurement $59.85