CBP readies new C-TPAT criteria for carriers
U.S. Customs and Border Protection plans to release its list of tighter security criteria for air, rail and sea carriers who participate in the Customs-Trade Partnership Against Terrorism this month, said Todd Owen, the agency official in charge of the program. The draft documents are undergoing final review, he said during last week’s meeting of the Department of Homeland Security’s Advisory Committee on Commercial Operations (COAC) in Los Angeles. Each of the carrier sectors will be allowed an opportunity to provide comment on the proposed criteria.
Michael Mullen, director of trade relations, said in June he expected the agency to release the first draft of carrier criteria in July. No reason was given for the delay, but CBP decisions must run through an extensive DHS review process and Owen was also pulled down to New Orleans to help with Hurricane Katrina recovery in September. Owen was the port director in New Orleans prior to taking over the C-TPAT program.
Although carriers do not receive many concrete benefits from CBP, they tend to participate to meet the demands of their customers who want assurances there are no security gaps that could result in inspection delays when they hand over shipments to transportation providers.
In March, the border agency announced minimum standards for importers who have signed up for the voluntary supply chain security program.
Owen said the third and final phase for existing C-TPAT importers to meet stricter minimum criteria for shoring up supply chain practices went smoothly as most companies had little difficulty establishing written and verifiable processes for selecting foreign suppliers and making sure they also follow approved supply chain best practices. The third phase of criteria went into effect on Sept. 26.
After the new carrier criteria are completed, CBP will turn its attention to drafting tighter rules for brokers, consolidators, freight forwarders and third party logistics providers.
During his briefing, Owen said his office has completed a catalog of best practices that will help guide companies on ways to meet or exceed minimum-security criteria. The catalog, which is the byproduct of lessons picked up during nearly 1,000 on-site validations of corporate security practices conducted by the agency so far, will be made public at the Customs Trade Symposium. The annual event is scheduled for the first week of November in Washington.
The C-TPAT office is processing C-TPAT applications and auditing companies faster because it is increasing automation and personnel, he said.
CBP is on track to complete 1,000 validations by the end of the year after completing only 400 during the first two years of the program, Owen said. A supply chain inspection team was scheduled to make the first visit to plants in Pakistan this week.
All companies must now submit their security profiles by electronic means and supply chain specialists this month began receiving tablet PCs with an automated assessment tool designed to make validations more consistent.
Owen said the program now has 86 supply chain specialists who visit companies and review their supply chain procedures to make sure they are adequate and match measures promised in their security profile. The number of validators given by Owen conflicts with recent statements by Commissioner Robert Bonner that 150 specialists are now in place, a discrepancy that could be explained by the fact that the agency’s goal is to have 150 supply chain specialists on staff.
The extra personnel means that CBP can also go back and recheck companies, Owen said.
About 25 percent of validated importers, or 110 companies, have achieved Tier 3 status allowing the greatest reduction in inspection levels. Companies can request they be considered for Tier 3 status once they have cleared up any deficiencies in security at the point of stuffing or during transit, but CBP won’t grant Tier 3 to companies until it conducts a validation, he said. Owen and his deputy, not the supply chain specialists, make decisions about which companies qualify for Tier 3, he emphasized.
Mullen said Tier 1 of C-TPAT eventually will include an extremely small number of firms because it will be limited to new applicants.
During the summer CBP invited 200 Asian exporters to join C-TPAT, Owen said. Mexican manufacturers were the only foreign-based who previously were allowed to enter the program. CBP is selectively expanding the program to keep reviews of companies at a manageable level.