January Rx-360 Supply Chain Security Guidance Paper: Cargo Theft in High Risk Areas
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1 Rx-360 Supply Chain Security Guidance Paper: Cargo Theft in High Risk Areas January 2014
2 Intent/Purpose There is a major concern throughout the pharmaceutical industry with the escalation of violent cargo theft incidents in geographical areas categorized as high risk. A significant increase in thefts has been experienced by Rx-360 member companies in Italy, Mexico, Brazil, and other countries. The bureaucratic theft reporting process, the low probability that crimes will be properly categorized and investigated, and the negative publicity associated with the crimes cause these types of incidents to go unreported. This has a tendency to compound the problem. Transported Asset Protection Association Europe, Middle East and Africa (TAPA EMEA) reports that the modus operandi used by most thieves has been theft from unsecured truck stops, fraudulent pickups, collusion, thefts from moving trucks, and truck hijackings. The use of cargo tracking device (GPS) jammers, which render tracking devices inoperative, has also been on the increase. Significantly, global trends of increasing cargo theft correlate with increasing patient safety risk as stolen goods that have been inappropriately handled reenter the supply chain. The purpose of this document is to summarize issues that Rx-360 companies are experiencing in certain high-risk areas (specifically, Mexico and Italy) and to outline risk mitigation strategies that are currently being considered or implemented by member companies. A risk mitigation options matrix, provided in this document, describes potential risk mitigation elements, their benefits and costs, and how they are currently being used in high-risk areas. Problem Statement Italy: The threat of cargo theft in Italy is severe, with thieves employing a variety of methods to steal cargo. Robberies (the taking of goods by force or intimidation from a person that is present) and burglaries (the forcible entry into a structure with the intent to commit a crime within) are not reported regularly and cargo truck hijackings are routine occurrences. Hijackers in Italy are frequently armed and employ violence to commandeer high-value shipments, at times setting up roadblocks to stop in-transit cargo trucks. Fictitious pickups have also been reported, during which thieves use forged documents of fake shipping companies and false license plates to pose as legitimate truck drivers in order to steal cargo. Goods are subsequently diverted through various channels rather than delivered to the intended destination. Hired truck drivers have falsely reported cargo thefts while purloining shipments themselves. Thefts have also been carried out by thieves driving marked vehicles and dressed as police officers. 2
3 Cargo thieves in Italy typically use brute force to enter warehouses during burglaries. Use of pickaxes and crowbars to force open locks and windows has been reported. In some cases, cargo thieves are able to move carefully so as to avoid being spotted on security cameras, suggesting either insider collusion in some thefts or careful surveillance of facilities prior to burglaries. Cargo theft has also been reported from trucks during trucking industry protests. Demonstrators block drivers progress and force them to stop, creating opportunities to steal the cargo. Criminals frequently target the major transportation hub of Milan and follow specifically-selected loads before stealing the cargo. The extensive use of soft-sided trailers and unsecured parking areas facilitates unauthorized access to cargo shipments while in transit, as well as to preloaded trailers at company warehouses, distribution centers, freight forwarders, and third-party logistics providers. Below Table 1 outlines the data collected by IIS illustrating the tip of the iceberg, as only a fraction of the real cargo thefts are reported. Table 1 * TAPA January 2013 Pharmaceutical thefts were the second highest category over the last 5 years (Table 2). This is quite unusual since, on average, Life Science thefts account for just 1% of all IIS reported freight thefts in EMEA. The high number of such thefts recorded in Italy is in fact due to exceptionally good reporting by various pharmaceutical companies to IIS over the last few months, and should therefore be put into context. 3
4 Table 2 *TAPA January 2013 Table 3 illustrates cargo theft incidents by country. Table 3 *TAPA January
5 Mexico: The threat of cargo theft in Mexico is categorized as severe. Organized criminal groups, including extremely well-funded and well-equipped drug cartels, will go to great lengths to successfully steal in-transit goods. Cargo thieves in Mexico are often very knowledgeable of how to overcome protective measures such as container locks and seals, GPS units, and even security escorts. Thieves often use violence or the threat of violence during the course of cargo thefts. According to one survey, nearly 73% of all robberies in Mexico are violent. Since the beginning of 2012, hijackers have kidnapped between 15 and 20 truck drivers. Most of these kidnappings have taken place in Tamaulipas, a border state known for extreme levels of cartel violence. Organized criminals have been known to attack targeted shipments at vulnerable points of transit, such as isolated stretches of highway or areas known to be out of GPS range. Distribution centers and production facilities have also been targeted by organized criminal groups. In several cases involving cartel members, the thieves enter a facility, hold the employees at gunpoint while loading the company s own transport equipment, and depart with the stolen product. Cartels have been known to cordon off entire sections of highways by setting up roadblocks. Once vehicles and cargo trucks enter these cordoned areas, cartel members target the goods of their choice. In several reported incidents, cartels have used trucks and trailers stolen during earlier attacks to block roadways. Cargo thefts from freight trains are also prevalent in Mexico. These acts are often carried out by both opportunists and highly organized criminal gangs. Some of the methods employed include: The bribing of train conductors to stop in secluded areas to avoid detection. This is ideal (from the criminal s standpoint) for breaking seals on the rail cars and taking the goods in transit Holding the conductor and on-board security personnel at gunpoint while taking the cargo Executing multiple thefts along the same rail line in certain cities by opportunistic thieves 5
6 FreightWatch recorded an increase in hijacking events in Mexico throughout During the first quarter of the year, 76% of all recorded cargo theft incidents involved a hijacking. Moreover, pharmaceutical thefts increased by 50% from 2011 to Mexican cargo thieves have recently become more sophisticated and more specialized; they target high-demand products that will command high prices when sold on the black market. Organized cargo theft criminals establish relationships with drug cartels and the corrupt police officers who will facilitate thefts in exchange for payoffs. Some extort custom agents, warehouse employees, and security guards at truck yards by using the threat of violence. The use of GPS jamming devices has also increased. Overall, the average loss value per theft incident increased by 122% during the reporting period, from $178,558 USD in 2011 to $396,061 USD in 2012 (see Table 4 below). Alcohol, Cashin-transit and Tobacco all saw high average loss values. Pharmaceutical thefts increased significantly as well. Table 4 *FreightWatch International Mexico Annual Report January 29,
7 FreightWatch International illustrates the number of product types (left y axis) versus the average value (right y axis) of cargo thefts in Table 5. Table 5 January 2014 FreightWatch International Mexico Annual Report January 29, 2012 Incidents Experienced by Rx-360 Member Companies Rx-360 member companies have suffered many incidents of armed robberies in Italy since 2010, with a significant spike in activity from September 2012 to April The majority of robberies have been last mile, where deliveries are being made from a regional warehouse to hospitals and pharmacies in a limited geographical area. In most cases, these robberies involve a mixed load (i.e., from more than one company) of pharmaceutical products, with each company s loss being relatively low, and the thefts not being consistently reported by individual companies. Logistics service providers (LSP) main national warehouses have been targeted, but to a lesser extent. Load values at LSP warehouses are much higher than those in last mile incidents, but the level of protection afforded to them is also higher. The current distribution network in Italy relies on a limited number of licensed local distribution companies in each region, a system that has remained essentially unchanged since it was set up by the pharmaceutical industry in the late 1990s. The regional distribution companies operate their own regional warehouses and subcontract to the national LSP. The level of subcontracting 7
8 also extends to the transportation company, as local distribution companies do not always have their own vehicles. The reported modus operandi has been very similar for every incident. One or more cars driven by thieves block the road and force a delivery truck to stop. The driver is threatened physically or with guns, and the delivery truck is commandeered. The driver is either left behind, or tied up, blindfolded, and placed in the cargo area of the truck. The thieves drive the truck a short distance, unload it, and leave the truck and driver behind. The involvement of organized crime groups has been very significant in Italy. Many product losses have been through internally arranged and orchestrated thefts after infiltration or influencing of LSPs by such crime groups. Only recently has the magnitude of theft become apparent, as some companies local affiliates have not been reporting losses above country-level headquarters. In addition, and as a result of media coverage and research, it is apparent that there is also large-scale theft of high-value pharmaceutical product in hospitals and even at local pharmacies. Law enforcement response has been mixed, and appears to be uncoordinated among the various agencies authorized to investigate such criminal activity. There has, however, been a recent development through TAPA (partially at the instigation of the pharmaceutical industry) to address the overall issue of the high level of cargo crime in Italy. This has resulted in the formation of a special interest group, with pharmaceutical representation, that will seek to improve law enforcement response through the local Ministry of the Interior. Mitigation Options Matrix for Cargo Theft in High Risk Areas The Options Matrix for Cargo Theft in High Risk Areas was developed to outline mitigation options that Rx-360 member companies have recently started utilizing or are considering implementing in response to the increase in cargo thefts in high-risk areas. Each mitigation option includes a description, the benefit of the mitigation if employed, the risk of use, the cost involved, and how member companies have actually used the mitigation option in Italy or Mexico. 8
9
10 10 January 2014
11 In Mexico, armed escorts, daytime shipping, convoys, driver checklists, and driver security training have been used in combination (but tied to insurance requirements rather than product protection). Regular audits of distributors in Italy, combined with contract incentives, help increase security measures and monetarily incentivize compliance to the contract security requirements. Conclusion With cargo thefts continuing to increase at double digit rates from one year to the next, and violence on the rise in Italy, Mexico, and other countries, companies need to ensure their supply chain security programs are actively managed and monitored. Each individual program should be molded to the needs, region, and companies risk tolerance. It is also important for companies to partner with local regulatory agencies, local law enforcement authorities, and with peer companies to lobby the government to enact, enforce, and strengthen local laws to reduce the number of violent cargo thefts. Risk mitigation measures should be reviewed and modified periodically to account for changes in criminal activity. Successfully reducing the number of violent cargo thefts is heavily dependent upon programs that are strongly endorsed by senior management, cooperation among companies in forums like Rx-360, and coordination with regulatory and law enforcement agencies. This group will continue to explore anti-cargo theft programs, initiatives, and mitigation measures as the risks associated with pharmaceutical cargo theft continue to evolve.
12 ASSOCIATIONS: Associations that provide other resources that you should consider as part of your toolbox include the following: Transported Asset Protection Association (TAPA) TAPA is an association that sets standards for the secure storage and transportation of products. Their mission is to protect high-value theft targeted (HVTT) assets in the transportation supply chain. While the link here is for the TAPA Americas Chapter, it contains links for the other international chapters as well. Pharmaceutical Cargo Security Coalition (PCSC) PCSC is an organization comprising pharmaceutical industry professionals, law enforcement and government entities, cargo insurers, carriers, and risk management advocates who are dedicated to preventing theft of pharmaceutical products in transit. Pharmaceutical Security Institute (PSI) PSI is a not-for-profit membership organization dedicated to protecting the public health, sharing information on the counterfeiting of pharmaceuticals, and initiating enforcement actions through appropriate authorities. Team Members: Tim Valko (Amgen) Bob Satek (AbbVie) Brad Elrod (Pfizer) Edwin Kinkler (Teva) Javier L'Eglise (Bayer) Paul Gibbons (Amgen) Tom Sumner (Amgen) Brian Damon (Amylin) Tony Kidner (Boehiringer Ingelheim GmbH) Amy Imbrogno (Amgen) REFERENCES: 1. FreightWatch International; 2012 Mexico Annual Report; Jan 29, 2012; 2. BSi 3. TAPA EMEA, January 2013 Vigilant Report; 12
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