CSMS Message: 99-000407

Title:TEST OF CONTINUITY OF BUSINESS
Date:1999-05-25
To:abi
Links:previous, next

TO : ALL ABI BROKERS.

FROM : RAY JANISZEWSKI

SUBJECT : Test of Continuity of Business

iTE : 05/24/1999

DEPARTMENT OF THE TREASURY
CUSTOMS SERVICE

TEST OF CONTINUITY OF BUSINESS
IN CASE OF AUTOMATED COMMERCIAL SYSTEM FAILURE

AGENCY: CUSTOMS SERVICE, TREASURY.

ACTION: GENERAL NOTICE.

SUMMARY: THIS NOTICE ANNOUNCES CUSTOMS PLAN TO CONDUCT A TEST TO
EVALUATE ITS CAPABILITY TO CONTINUE PROCESSING THE IMPORTATION OF
MERCHANDISE IF ITS COMPUTER SYSTEM, THE AUTOMATED COMMERCIAL SYSTEM
(ACS), FAILS. THE TEST WILL SIMULATE THE ABSENCE OF AN ELECTRONIC
ENVIRONMENT. ELECTRONIC FILERS IN THE TRADE COMMUNITY WILL BE
REQUESTED TO FILE REQUIRED CUSTOMS INFORMATION ON PAPER FORMS.
PARTICIPATION IN THIS TEST WILL PROVIDE THE TRADE COMMUNITY WITH THE
OPPORTUNITY TO EXAMINE THEIR OWN PROCEDURES TO DETERMINE WHETHER THE
ARE PREPARED TO OPERATE IN THE EVENT THAT THE ACS IS NOT AVAILABLE.
BECAUSE A FULL-SCALE TEST INVOLVING ACS DOWNTIME WOULD BE TOO
DISRUPTIVE AND COSTLY TO THE TRADE COMMUNITY, CUSTOMS PLANS TO MERELY
SIMULATE ACS DOWNTIME. WHILE SIMULATING DOWNTIME, CUSTOMS COMPUTERS
WILL STILL BE FULLY OPERATIONAL. THE SIMULATION WILL RUN,
SIMULTANEOUSLY AT TWO CUSTOMS PORTS OF ENTRY, FOR A PERIOD OF 24
HOURS. THE TRADE COMMUNITY AND THE PORTS WHERE THIS SIMULATION WILL
OCCUR ARE AWARE OF THE PLANNED SIMULATIONS.

THE SIMULATIONS WILL BE CONDUCTED DURING THE MONTH OF JUNE 1999 A
WILL RUN SIMULTANEOUSLY AT THE TWO PORTS SELECTED FOR A CONTINUOUS
PERIOD OF 24 HOURS.

FOR FURTHER INFORMATION CONTACT: CUSTOMS MANAGEMENT CENTERS, PORTS OF
ENTRY, ACS CLIENT REPRESENTATIVES, OR RAY JANISZEWSKI, HEADQUARTERS
OFFICE OF FIELD OPERATIONS, TRADE PROGRAMS, (202) 927-0365.

SUPPLEMENTARY INFORMATION:

BACKGROUND

ON FEBRUARY 4, 1998, THE PRESIDENT ISSUED EXECUTIVE ORDER 13073
(E.O.) (63 FR 6467; 3 CFR 1998 COMPILATION ; 34 WEEKLY
COMP.PRES.DOC. 198) WHICH CONCERNED THE YEAR 2000 CONVERSION. THIS
COMPUTER PROGRAMMING PROBLEM IS FREQUENTLY REFERRED TO AS THE Y2K (FOR
YEAR 2000) PROBLEM.) THAT ORDER DIRECTED, IN PART, THAT EXECUTIVE
BRANCH AGENCIES ASSURE THAT NO CRITICAL FEDERAL PROGRAM EXPERIENCES
DISRUPTION BECAUSE OF THE Y2K PROBLEM, AND COOPERATE WITH THE PRIVATE
SECTOR OPERATORS OF CRITICAL NATIONAL AND LOCAL SYSTEMS IN ADDRESSING
THE Y2K PROBLEM.

IN A MEMORANDUM DATED MARCH 26, 1999, THE DIRECTOR, OFFICE OF
MANAGEMENT AND BUDGET (OMB) TASKS ALL EXECUTIVE AGENCIES TO TAKE AN
EVEN STRONGER LEADERSHIP ROLE AND WORK WITH OUR PARTNERS TO ASSURE
THEY HAVE ADDRESSED ANY YEAR 2000 PROBLEMS THAT COULD AFFECT FEDERAL
PROGRAMS, JOINTLY TEST THAT THE FEDERAL PROGRAM WILL WORK, AND
TOGETHER PUBLICLY DEMONSTRATE THAT IT WILL.

PURSUANT TO E.O. 13073, THE GENERAL ACCOUNTING OFFICE (GAO) WAS
DESIGNATED AS THE LEAD FEDERAL GOVERNMENT AGENCY TO COORDINATE THE
FEDERAL POLICY CONCERNING YEAR 2000 CONVERSION.

GUIDANCE PROVIDED BY THE GAO IN THE PUBLICATION "YEAR 2000 COMPUTING
CRISIS: BUSINESS CONTINUITY AND CONTINGENCY PLANNING" (GAO/AIMD-10.1.19,
DATED AUGUST 19, 1998) ADVISES GOVERNMENT TESTING/TRIALS OF BUSINESS
CONTINUITY TO EVALUATE WHETHER INDIVIDUAL CONTINGENCY PLANS ARE CAPABLE
OF PROVIDING THE DESIRED LEVEL OF SUPPORT TO THE AGENCY'S CORE BUSINESS
PROCESSES AND WHETHER THE PLANS CAN BE IMPLEMENTED WITHIN A SPECIFIC
PERIOD OF TIME. IT ALSO PROVIDES THAT WHERE A FULL-SCALE TEST MAY BE TOO
COSTLY, THE AGENCY MAY CONSIDER END-TO-END TESTING OF KEY CONTINGENCY
PLAN COMPONENTS.

IN ACCORDANCE WITH E.O. 13073 AND GAO GUIDANCE, CUSTOMS WILL BE
TESTING TO MAKE SURE THAT IF ITS ACS COMPUTER SYSTEM FAILS DUE TO AND
Y2K PROBLEM, CUSTOMS AND THE TRADE COMMUNITY WILL BE ABLE TO CONTINUE
OPERATING. THIS TEST WILL SIMULATE THE FAILURE OF THE COMPUTER
ENVIRONMENT TO DETERMINE WHETHER CUSTOMS IS CAPABLE OF CONTINUING TO
PROCESS THE MOVEMENT OF MERCHANDISE BASED SOLELY ON PAPER FORMS
SUPPLYING THE REQUIRED INFORMATION. PARTICIPATION IN THIS TEST ALSO
WILL PROVIDE THE TRADE COMMUNITY WITH THE OPPORTUNITY TO EXAMINE THE
PROCEDURES TO DETERMINE WHETHER THEY ARE PREPARED TO OPERATE IN THE
EVENT THAT THE ACS IS NOT AVAILABLE.

THIS TEST HAS VALUE IN OTHER THAN A Y2K SCENARIO. IT IS IMPORTANT
FOR CUSTOMS AND THE TRADE COMMUNITY TO KNOW THAT EACH OTHER CAN
CONTINUE TO OPERATE IF EVER THERE IS A FAILURE OF CUSTOMS AUTOMATED
PROCESSING SYSTEMS FOR ANY REASON.

TEST DESIGN

CUSTOMS WILL SIMULATE A FAILURE OF THE ACS DURING THE MONTH OF JUNE
OF THIS YEAR AT TWO PREDETERMINED CUSTOMS PORTS OF ENTRY. THE PORTS
OF ENTRY INVOLVED HAVE ALREADY BEEN INFORMED OF THE COMPUTER FAILURE
SIMULATION. ALSO, THE TRADE COMMUNITIES AT THESE PORTS HAVE BEEN
CONSULTED, PARTICIPATED IN THE PLANNING AND PROCEDURES TO IMPLEMENT
THE SCENARIO, AND HAVE AGREED TO PARTICIPATE IN THE SIMULATION
SCENARIO FOR A 24-HOUR TIME-PERIOD.

THE SIMULATION WILL TEST THE EFFECTIVENESS OF CUSTOMS BUSINESS
CONTINGENCY OF OPERATIONS PLANS FOR CERTAIN KEY BUSINESS PROCESSES,
INCLUDING ARRIVAL, ENTRY, EXAMINATION AND RELEASE OF MERCHANDISE,
ENTRY SUMMARY, AND COLLECTIONS.

THE FAILURE OF ACS WILL BE MERELY SIMULATED; ACS WILL REMAIN FULL
OPERATIONAL. CUSTOMS WILL NOT SUSPEND PAPERLESS ENTRY AND ENTRY
SUMMARY DESIGNATIONS. CUSTOMS WILL ASK, HOWEVER, THAT ELECTRONIC
FILERS PRESENT PAPER DOCUMENTS FOR THEIR TRANSACTIONS. PAPER
DOCUMENTS USED DURING THE SIMULATION FOR THESE TRANSACTIONS WILL BE
FOR TESTING PURPOSES ONLY AND WILL NOT BE CONSIDERED DOCUMENT
SUBMISSIONS FOR PURPOSES OF MEETING ANY LEGAL OR REGULATORY
REQUIREMENTS.

CUSTOMS NOTES THAT CUSTOMS AND THE LOCAL TRADE PARTICIPANTS FOR
THIS TEST DO NOT WISH TO IDENTIFY THE PARTICIPATING PORTS OF ENTRY A
THIS TIME, SO AS NOT TO DISRUPT THE NORMAL FLOW OF TRADE AND, THUS,
SKEW THE RESULTS OF THE SIMULATION. IT IS ALSO NOTED THAT THE TEST
RESULTS WILL BE ANALYZED BY ALL PARTIES INVOLVED AND BUSINESS
CONTINGENCY PLANS OF PORTS WILL BE ADJUSTED AS NECESSARY. ADDITIONAL
TESTING AT ONE OR MORE PORTS OF ENTRY MAY BE NECESSARY AT A LATER
TIME.

THIS TEST SHOULD FURTHER RAISE THE CONFIDENCE LEVEL OF THE TRADE
COMMUNITY IN CUSTOMS ABILITY TO CONTINUE TO PROVIDE SERVICE IN THE
EVENT OF A SIGNIFICANT SYSTEMS FAILURE.

DATED: MAY 21,1999

/S/ CHARLES W. WINWOOD
ASSISTANT COMMISSIONER
OFFICE OF FIELD OPERATIONS