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Contingency Planning
Both U.S. Customs and Border Protection and Canada Border Services recommend carriers develop contingency plans to address situations where they may not be able to prepare, submit, change, amend or verify the status of their ACE or ACI declaration(s).
Carriers can easily find themselves in these types of situations due to events within or beyond their control. Events like customs systems outages, utility failures, communication and network system failures, equipment / hardware failures, processing delays, denial of services attacks and software upgrades are just a few types of incidents which may occur. Pre-planned procedures should be created to ensure trucks can continue to cross the border with minimal delays since trucks which arrive at the border may be refused entry, turned back or may be issued customs penalties for failure to submit e-manifest declarations in advance.
CBSA has detailed procedures for carriers that can be found on the CBSA website. CBSA has published additional details related to System Outage Contingency Plan for all Trade Chain Partners on their website. CBP's has also published their Standard Guidelines for CBP/Trade Outages.
Carriers can keep abreast of CBSA an CBP system outages by subscribing to their e-mail distribution services. To subscribe to CBSA's e-mail notifications sign up for an e-mail notifications through the CBSA Stay Informed - EDI / Portal bulletins Tab on the CBSA website or request to Technical Commercial Client Unit at tccu-ustcc@cbsa-asfc.gc.ca and request to be included in the ACI Highway Carrier notices. Highway Carriers can also subscribe to CBP's Truck Manifest e-mail notifications through the following URL: https://www.cbp.gov/trade/automated/cargo-systems-messaging-service
Contingency plans vary in complexity. More elaborate plans are normally associated with carriers who submit a large volume of declarations in a time sensitive manner. These carriers may have back up communication / internet service providers, backup generators, IT staff on call etc. Many carriers will be able to develop less complex contingency plans based on the type and frequency of specific failures.
Fundamentally there is two methods a carrier can submit their eManifest declarations. Directly through government ACE and ACI portals or by using electronic data interchange (EDI) protocols. Carriers who use one method to submit their eManifest declarations should consider establishing and maintaining service using the alternative method to provide them with more flexibility and visibility during outages. Establishing service on the government ACE and ACI web portals is free although registration is required and may take a few weeks. Carriers who have established ACE and ACI Portal accounts should periodically log into their accounts to ensure the accounts remain active particularly if they may need to use them for back up purposes. Establishing EDI service can be a simple as signing up with an EDI service provider and completing a few forms to as complex as submitting applications and passing a number of predefined EDI tests.
Carriers who use the government eManifest ACE and ACI Portals should note during certain systems outages the eManifest Portals will not allow carriers to submit their declarations where as carriers using EDI will have their eManifest declarations queued for processing once the customs systems are restored. This provides carriers who use the EDI systems operational advantages over eManifest Portal users especially when considering after-hours staffing, access to the internet / web portals and potential customs penalties.
To improve your visibility when outages occur eManifest Express's software has the ability to send e-mails to users after receiving EDI message(s) from customs related to a specific manifest. Carrier's can use this capability to monitor when customs systems become operational.
Carriers who use both systems must always remember if the manifest / shipment information is changed, modified or deleted within the government ACE or ACI portal the information in the portal will normally supersede the information that was previously submitted using a EDI system and the information between both systems may not necessarily match. (This statement is based on that the latest changes made to the eManifest / shipment(s) were made in the government portal and the previous EDI submission / transmission was processed by Customs. Generally, carriers can check the current status of their eManifest within the government portal yet it is possible for the information to change especially if a carrier uses an EDI system and the EDI messages are delayed or may have not been processed by customs prior to making changes in the government portal.)
Carriers who communicate using EDI methodologies may have more options. They can have more than one EDI configuration with CBP and CBSA and depending on the type of failure they may be able to use an alternative provider. Carriers may also be able to use a web based eManifest declaration software or a eManifest declaration service provided by their existing or an alternative provider. (Caution must be taken when switching between EDI providers particularly on existing manifests. Carriers must take into consideration that subsequent or delayed EDI transmissions or EDI processing by customs and modifications made within the ACE and ACI Portals can change the manifest / shipment information. Duplicate manifest errors, rejects and other errors can be created. Troubleshooting and resolving these types of issues can be technical and involved and is beyond this posting. When these type of events occur it would be prudent for carriers to contact their service provider(s) for assistance.
Please note: CBP’s and CBSA’s EDI systems are configured differently so setting up new service with CBSA and CBP may take some time. Some service providers may be able to provide relatively immediate ACE eManifest declaration services yet it may take up to a few weeks to configure CBSA systems to accept ACI eManifest declarations.
CBP’s website indicate it can take between 3 and 5 days to set up an ACE Portal Account . Setting up a CBSA ACI Portal Account is multistep process.
eManifest Express offers carriers a full range of EDI solutions. We offer carriers a complementary back up account where once configured carriers can log into the system to perform their eManifest declarations. Carriers can also have staff prepare their eManifest declarations on their behalf. Standard rates apply. If you would like to subscribe to our service or obtain a complementary back account please contact us.
To assist carriers in developing their contingency plan please find a few examples of potential failures and other considerations.
a) Local hardware device failure (e.g. computer, fax machine, fax server, modem, network communication device etc.)
b) Internet Service Provider’s system outage
c) Utility failure (e.g. hydro, telephone, cellular provider)
d) Software or solution provider system upgrade / failure
e) System failures / outages due to weather / storms
f) Government software, hardware and communication system outages and delays.
Carriers should also consider what protocols to put in place if they cannot communicate with their drivers.
a) Is there a standard operating procedure in place to contact a third party for assistance?
b) Have arrangements been made with the third party in advance to provide the required service?
c) Do the drivers have the information they need to contact the third party?
