In 2018, as part of its sustainable ocean's management mandate, the National Oceanic and Atmospheric Administration (NOAA) imposed new reporting standards for the importing of 14 species of seafood. The program is called Seafood Import Monitoring Program or SIMP.
What is SIMP?
As a software provider of applications that support international supply chain execution and automated customs clearance programs, we need to provide the functionality to address a multitude of government and business data requirements. The reporting demands under SIMP at first blush do not look particularly onerous. But when you consider the implications for a large seafood importer, the demands take on a different cast.One can almost draw a straight line from the new regulations as they follow directly from the Food Safety Modernization Act (FSMA) which introduced provenance monitoring, reporting on all aspects of food handling, and supplier process validations, amongst a whole host of additional requirements.The implications of the new SIMP regulations are greater complexity and processing demands. The requirement is straight-forward enough: that the importer will need to provide for details of landing vessels for all imported seafood, by item by quantity. The data is to be provided as part of the customs entry and is administered by the FDA.
What does SIMP Require?
The requirement is quite simply stated. The practicalities are more complex. There are three levels to reporting under SIMP:a) Supplier Details: similar to those provided under the Import Security Filing (ISF)b) Item Details: a little bit more elaborate than what has been traditionally reported, andc) Vessel and Landing Details: including all vessel handling details and dates, and transshipments details (dates, vessel names, locations). This is for each of the regulated seafood items on the import shipmentThese details have to be provided as part of the import documentation process. Of course, the increased data handling and internal documentation load has cost and work implications for the overseas suppliers and the domestic importer/distributor. Additionally, customs brokers are increasing the direct cost of importing listed seafood items by charging (by line) in support of SIMP compliance.Seafood importers either need to pay this new increased cost, or get better at gathering, organizing, and provisioning the SIMP required data on its own.
What to do?
It sure seems evident that better systems and better supplier/distributor interactivity will enhance control, compliance efforts, and allow for better cost control. The requirements of SIMP would seem to be an obvious use case for a blockchain/distributed ledger implementation on a broader industry basis. In the absence of an industry initiative, the seafood suppliers and importers will have to bear an increase in paper burden and direct processing and importing costs.As time passes, one thing has become clear: compliance-related challenges will increase. Companies can take an approach to move to systems designed to address these new compliance issues on an ongoing basis. These systems integrate supplier data, improve the data entry process, and manage outcomes and reconciliations. As an added benefit, these systems provide an environment for continuous improvement and responsiveness to these external demands.While "Keep It Simple" is a great management mantra, SIMP makes meeting this objective just a little bit harder.
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