Bersin: C-TPAT strategy involves doing more with less
U.S. Customs intends to significantly expand the number of companies in its voluntary supply chain security program, and monitor and process the new enrollees, on a smaller budget than in years past, Commissioner Alan Bersin said in an interview Tuesday.
At last week's annual Trade Symposium, the nation's top border management official set a goal of increasing membership in the Customs-Trade Partnership Against Terrorism from 10,000 to 40,000 companies within five to seven years.
But the White House's 2012 budget request submitted to Congress earlier this year says Customs and Border Protection only needs $45 million to manage the program — about $18 million less than appropriated in fiscal years 2010 and 2011. Officials say the program has matured and that initial expenses for facility acquisition, information technology and additional personnel do not need to be covered on a recurring basis.
| Bersin |
Bersin, who is moving on several fronts to enhance the agency's effectiveness and role as a commercial facilitator, suggested that giving the private sector more responsibility for checking the trustworthiness of C-TPAT applicants would allow CBP to scale up the program with existing resources.
'We should not project straight line that it takes this many people to attract this many partners and to administer the program,' Bersin said during a lengthy interview in his office.
'I think we've reached a different point in the evolution of the program where ' we would rely on many of our existing partners to bring in others in their supply chains and do it in ways that would not require the manpower intensive work that the initial certification would achieve,' he added, referring to follow-up revalidations that CBP conducts every three years in most cases.
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There are about 200 personnel in the C-TPAT program, with funding for 207 positions, according to budget documents.
Bersin's position dovetails with recent comments expressing interest in having customs brokers encourage customers that import goods, especially small businesses, to join C-TPAT and then vet their security plans on behalf of CBP.
'It's not to say that we would not have serious standards and rely very heavily on validations. But how those validations were done and who did them are issues that we would expect to be taking up with the private sector,' Bersin said.
During a Trade Symposium town hall Bersin referred to deputizing private firms as a force multiplier and said CBP can share more information with certified shippers about potential threats and vulnerabilities in the supply chain.
'One of the changes we have to make ' is actually bring the private sector into the process, be willing to share information,' he said, noting that if the U.S. military can have private contractors working in war zones, CBP should be able to collaborate with companies on supply chain security.
'CBP is in a position to do it since we deal with top secret, classified intelligence all the time. Most of the information we deal with is neither top secret or classified, even though some of it is classified as such,' Bersin said.
Customs needs to 'be willing to have you collocated and embedded in the manner in which the Marines, the Air Force, the Navy invited the public to be embedded in a much more dangerous and risky enterprise.
'We can work through that and I think get to the point where we can implement what we know now, which is we can't secure the supply chain without calling on those of you who know the supply chain a lot better than we know it away from the American homeland,' he said.
Under C-TPAT, CBP extends expedited import clearance to companies that have approved procedures for maintaining control of shipments at origin and in transit to prevent criminals or terrorists from compromising an ocean container or truck.
The agency says C-TPAT importers are four to six times less likely to incur a security or compliance examination because they are scored lower in its automated targeting system. Other stated benefits are front-of-the-line privileges, when possible, for cargo that is targeted for inspection, stratifying containers in a multiline entry so that those not being held for the compliance exam are quickly released to the custody of the shipper and eligibility for other partnership programs.
CBP inspects about 3 percent of ocean containers and a quarter of the 11.l3 million trucks entering the country.
Agency officials spoke at the Trade Symposium about how they intend to multiply the C-TPAT population and advance their strategy of segmenting traffic by risk, which is designed to reduce the pool of suspicious or unknown shipments for inspectors to focus on.
C-TPAT Director Bradd Skinner said his office would encourage existing C-TPAT members to talk to more of their business partners about the advantages of joining the program. Surveys conducted by CBP show indirect benefits to participation in the trusted shipper program include reduced cargo theft and pilferage, improved predictability moving goods across the border and reduced insurance rates.
One of the agency's goals listed in its budget proposal is to reach out to any Top 100 importers not already in C-TPAT and help overcome any factors preventing them from applying.
Expanding C-TPAT will also require intensified efforts to harmonize the program with similar authorized economic operator (AEO) programs in other countries so that overseas companies certified by other national authorities as having secure supply chain practices can be granted equivalent treatment as C-TPAT importers, said Kevin McAleenan, deputy assistant commissioner for field operations. To achieve so-called mutual recognition, however, CBP has to assess the other program's rules for reviewing corporate security and how they are implemented.
McAleenan said C-TPAT would also become more meaningful to shippers if it can be synchronized with trusted shipper programs being considered or expanded by other U.S. government agencies.
Bersin has made inter-agency collaboration a major point of emphasis since taking office more than a year ago.
C-TPAT will also benefit from the Center of Excellence and Expertise demonstration project, McAleenan said. CEE is a small team created to develop expertise surrounding CBP regulation of the pharmaceutical industry and find ways to remove unnecessary impediments to cargo flows. CEE works closely with drug makers to understand their business operations and compliance processes, and provides guidance to ports of entry on ways to expedite processing for the industry's highly controlled products.
Similarly, the effort to change over from processing every border transaction to managing regular importers on an account basis could contribute to C-TPAT's allure, McAleenan said.
'We've always factored C-TPAT into our transactional analysis. But what the commissioner has challenged us to do is really look and make it an intentional discipline to try and work harder at segmenting the trade moving those people that we trust and know more about out of that transactional targeting focus.
'We know a lot more than the shipper, the address, the consignee, the contents of that shipment.
'We interact with you on the trade side. We might have had a regulatory audit interaction, a textile verification. You might be a member of the Importer Self-Assessment (program). We've got a supply chain validation through C-TPAT and we can connect all of that information to have our trusted partners not face the same impact.
'And as we look at that entire model, we can see the full end-to-end supply chain and identify additional opportunities to reach out and create new membership and make that membership very beneficial,' he said.
The approach now articulated by CBP signals a shift to expand C-TPAT beyond security to also be a quality-assurance program for trade compliance, more in line with World Customs Organization standards for AEOs to also demonstrate compliance with customs requirements and financial viability. More holistic AEO programs in the European Union, for example, provide trade and security benefits to highly compliant and security-conscious traders. ' Eric Kulisch
