Random exams cancel some C-TPAT benefits, CBP admits

   Too many random security inspections of ocean containers fall on trusted shippers who are supposed to receive fewer exams for making investments to ensure their international shipments aren’t compromised by criminals or terrorists en route to the United States, a U.S. Customs official conceded last month.
   Companies certified for following high security standards throughout their supply chain as part of the voluntary Customs-Trade Partnership Against Terrorism program receive lower scores in Customs and Border Protection’s risk rating system, making their shipments about five-times less likely to be selected for a non-intrusive container scan, according to the agency.
   Importers have complained for years that the benefits they receive from C-TPAT do not justify the resources they spend to meet CBP’s eligibility criteria. In some cases shipments traveling inland under a customs bond to expedite delivery are subject to an automated and physical exam upon arrival at a West Coast port and then are re-examined at the inland destination port where Customs collects any duties and clears the goods.
   There are 10,250 certified companies in C-TPAT, but government and industry officials say the number should be higher. Last year, then-Commissioner Alan Bersin challenged the agency to expand the program to 40,000 members within five to seven years.
   CBP’s Office of Field Operations (OFO) is in the process of reviewing how it assigns containers for large-scale imaging after realizing that ports of entry operated under separate requirements to meet utilization requirements for vehicle and cargo inspection systems, Dan Baldwin, executive director for cargo and conveyance security, said at a customs brokers conference in Hollywood, Fla.
   “There are often times we’re performing work simply because we had the equipment as opposed to really embracing risk management,” he said. The agency’s layered levels of enforcement strengthen security but the various programs tend to operate in silos “without fully understanding the downstream effect” of redundant measures on the public, he added.
   An intensive exam, in which cargo is physically removed from a truck or container, can cost a shipper $2,500 to $3,000 to cover labor, storage and other fees.
   Random sampling is a technique used by many security programs as a precaution against those who might try to game the system, but the way it is applied at CBP unintentionally undermines C-TPAT, Baldwin admitted.
   C-TPAT status is factored into initial targeting decisions, but it needs to also be integrated into the statistical algorithms used to select random containers for inspection, Baldwin elaborated in an e-mail. 
   “Given the significant costs each examination requires, each decision to examine needs to take into account the costs and benefits of that decision,” he said.

Related Content U.S. Customs considers combining C-TPAT, ISA

   At the conference, Baldwin said OFO is still learning to be more sensitive to the real-world outcomes of its security measures and take a holistic approach to enforcement and trade facilitation. The goal is to deliver on the incentives promised to industry partners, he added. – Eric Kulisch