may be too small to be measured precisely, so the results may be less useful for reforming policy. Institutional issues for coordinated border management
In a coordinated border management approach it is necessary to address the relations among SPS agencies, other border agencies, and private stakeholders.
16 4 Sanitary and phytosanitary measures and border management
SPS agencies and customs agencies. It may be cost effective for customs agencies to perform certain general tasks for SPS agencies—tasks such as checking conformity between goods and documents, deciding whether goods should be checked by quarantine officers on referral, and checking expiration dates on food labels. Indeed, some countries formally delegate these powers to customs. Yet SPS agencies generally see such cooperation with customs as a mixed blessing, if not as a direct threat. Regularly heard from SPS agencies are the complaints that customs is interested only in taxation, not in health protection; that customs officials have no expertise in SPS issues; and that delegating SPS tasks to customs results (allegedly) in the release of goods that need SPS checking. Accordingly, SPS agencies frequently expend much political energy protecting their existing mandates and administrative competence. (It is also fair to say that many customs agencies are not eager to take on additional tasks.) Similar arguments arose in turf struggles between customs and immigration authorities. But the successful delegation models used for many years by customs and immigration in Australia—and more recently in the United States—suggest that customs can perform routine tasks, such as immigration processing, without lowering standards. With effective information technology, and with a dataset based on harmonized system codes, it should be possible for customs to ensure that goods subject to SPS inspection are sent to the proper quarantine officials. However, the experience of one middle income country with extensive international trade shows that, despite many years of talks, customs and SPS agencies have not been able to agree on information sharing procedures for control and risk management. That is why many SPS agencies still collect their own information—failing to make
progress in e-commerce and to establish a national single window (chapter 8). To be sure, more product and process information may be required for SPS control than for customs control. For SPS there may be more product details, as well as seasonality information, so a shared database using harmonized system codes might require additions beyond those codes. The problem is not insurmountable with effectively deployed information technology, developed in cooperation with all users. At present SPS agencies typically are behind in their adoption of such technology. The typical SPS agency is also behind in using risk management techniques effectively. One reason why cooperation between customs and SPS agencies may be difficult is that risk assessment generally seems more complex for SPS than for customs. Causes of complexity include: • The range of products, hazards, and ecological conditions related to SPS. • The cost of collecting data on health hazards. • The varying SPS control requirements imposed by importing and exporting countries. Because of this technical complexity and the gap in capacities, involving SPS agencies actively in collaborative border management will require prolonged capacity building as a precondition. At present there is apparently little understanding of the differences between customs agencies and SPS agencies in risk parameters, risk assessment, and risk management. This lack of understanding can lead to the mistaken belief that the goal is to establish a single integrated risk management system for both agencies. In fact, the most that is possible is some coordination in selecting shipments for physical inspections. What is needed is not one risk management system but, instead, one comprehensive risk management framework. Such a framework should use proven disciplines to meet the risks faced by both customs and SPS agencies. Coordination among SPS agencies. Overlapping jurisdictions and rivalry among SPS agencies are common—especially between agencies in agriculture ministries and public health ministries. Overlapping responsibilities may be functional (animal product safety and human health), or they may arise from agency responsibilities for different parts of the B O R D E R M A N A G E M E N T M O D E R N I Z AT I O N
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