TT Talk - Mitigating risks of clandestine migration
The smuggling of people has unfortunately become a major issue in certain parts of the world. Political imperatives in target countries have led stricter immigration restrictions and increased government action. International clandestine migration has become a persistent threat to the unitised supply chain.Criminal organisations are often the facilitators of this clandestine movement. They know that the simplest way to move people across international borders is to hide them in legitimate freight transport. In order to combat the criminal threat and the aspirations of the migrant or stowaway, all stakeholders in the supply chain need to be constantly vigilant.
For stakeholders in the international supply chain, the risk exposures are varied in nature:
- Risk to life – both workers and migrants
- Physical damage to cargo, including soiling and contamination
- Additional freight costs
- Vehicle, equipment and cargo detention
- Fines and penalties
- Reputational damage
Those stakeholders who regularly undertake cross border freight movements, consideration should be given to engaging with the preventative guidance governmental authorities produce. TT Club has collaborated with BSI to publish a StopLoss briefing ‘Clandestine Migration’ as guidance to supports their activities and allows each stakeholder to implement increasingly robust defences appropriate to the threats presented.
Risks to the integrity of cargo
Where migrants are discovered within packed CTUs, there are frequently concerns over the condition of the cargo, which are especially sensitive when it is intended for human consumption. The addition of contamination to damage may give rise to large exposures.
In such circumstances, appointing an independent expert at the earliest opportunity may avoid cargo being declared a total loss, with the resultant disposal costs. Where expert distressed cargo inspections are undertaken, it can often be evidenced that damage and contamination is restricted to a very small proportion of the cargo.
Road haulage requires specific attention
No mode of transport can be considered exempt from clandestine movement of people, however the risk is greatly heightened during the road modality.
In Europe, 86% of recorded incidents involve movement of cargo by road.
By nature, road transport provides a range of relatively low-risk entry points for stowaways. Road vehicles use publicly accessible spaces and necessarily are stationary at various points during the intended journey.
Three steps are fundamental in mitigating the risks:
- Provide adequate training for drivers on how to avoid becoming involved with clandestine migrants. This should involve producing written security procedures, including vehicle security checklists;
- Deploy robust security devices to secure the vehicle, goods and cargo space. Ensure that drivers are fully briefed on their use; and
- Monitor compliance with all procedures.
Once procedures are set, there are practical measures to be implemented before packing, during the packing process and finally, in transit.
Before packing takes place, ensure that the condition of the unit – particularly curtain-sided trailers – is such that unauthorised entry is prevented.
As far as possible, ensure that no persons gain entry during packing and instruct the driver only to sign a clean packing receipt when a proper check of the consignment is possible. Check the entirety of the seal cord (TIR Cord), in particular its ends and the seal strip, to ensure that it is intact and free from cracks, and has not been cut and put back together.
During transit it is inevitable that the trailer or unit will be left unattended - for example during meals, overnight or at terminals. Drivers should be instructed to check for signs of any tampering on return to the vehicle and to complete a security check list. For accompanied movements, deploying something as simple as a baby alarm in the trailer, with the control unit in the driver's cab, will provide an alert and security equipment, such as cameras, may also assist in detecting activity.
If, despite following the above recommendations, there is the slightest suspicion that someone has gained access to the trailer, irrespective of the location, the driver should immediately alert the local authorities (police, customs, ferry operator, etc.), but not seek to confront any clandestine migrants.
Whilst owners, hirers or drivers may contract with third parties to conduct the required checks on their behalf, they are likely to remain liable to any penalty incurred in the event of failure to have an effective system in place or to operate it properly. Due diligence in the selection of such contractors is therefore critical.
Be mindful of the risk
Constant vigilance and awareness is the only way to combat stowaways in this type of transport. Vehicles should be checked regularly en route to ensure that they have not been entered, particularly after stops when left unattended. Documentation detailing the system operated to prevent unauthorised entry must be carried with the vehicle, so that it may be produced immediately to an immigration officer on demand. Checklists should be used rigorously and carried with the vehicle, particularly where endorsed by an independent third party who witnessed checks, as such checklists will carry greater evidential value.
We hope that you have found the above interesting. If you would like further information, or have any comments, please email us, or take this opportunity to forward to any colleagues who you may feel would be interested.
We look forward to hearing from you.
Risk Management Director, TT Club