CBP moves ahead on C-TPAT for air carriers, 3PLs
U.S. Customs and Border Protection last week released its minimum security criteria for air carriers participating in the Customs-Trade Partnership Against Terrorism and the program’s director said he hopes to have similar security criteria in place covering third-party logistics providers by early 2008.
Officials had previously said they intended to open up enrollment for the first time to logistics providers by the end of last summer.
The agency is carefully studying the dynamics of the outsourced logistics sector and developing a common definition for such a service provider. The exercise is proving difficult because the industry uses so many subcontractors. CBP wants to make sure that any security plans instituted by the 3PL are also pushed down the pipeline to the companies doing the actual work.
The C-TPAT office plans to complete a draft proposal for 3PL minimum security requirements by early December, get executive approval by the end of the month and present the standards to the Commercial Operations Advisory Committee for final review, said program director Bradd Skinner during the quarterly meeting of the federal advisory panel on Friday.
C-TPAT is a voluntary industry partnership program under which importers with approved internal security controls for their supply chain are eligible to receive fewer container security exams at ports of entry. Carriers and other service providers do not receive similar trade facilitation benefits, but tend to join the program to attract business from shippers that need all their suppliers to follow the same standards in order to receive expedited clearance at the border.
Earl Agron, vice president of security for ocean carrier APL, questioned the need for opening C-TPAT to 3PLs because of resource issues. The key supply chain vulnerabilities, he said, are the point of stuffing and the truck move to the foreign port. There are so many warehouses and logistics companies that CBP will be spread too thin unless it has unlimited resources to verify compliance of companies within this sector, he said.
Skinner told COAC that the air cargo security criteria were reviewed by the Transportation Security Administration, which is developing its own trusted shipper program for domestic air cargo shipped on passenger planes. The plan would allow certified shippers to inspect their own cargo that is booked on passenger airlines. TSA tentatively plans to begin the first phase of implementing the program on Jan. 4.
As part of the coordination effort, the two agencies conducted a joint validation so that TSA could observe how CBP conducts an audit of a company involved in the air cargo sector and better understand each other’s programs, Skinner said.
CBP supply chain specialists plan to coordinate with TSA representatives before conducting on-site visits of shippers to eliminate potential conflicts, but the agencies do not appear prepared to share the outcomes of their respective evaluations.
“If a company meets the stringent TSA requirements for personnel identification (and other security procedures), it should have no problem meeting the C-TPAT requirements,” Skinner said.
The C-TPAT program has grown to 7,774 certified members and validated more than 90 percent of the companies so they can receive the full trade benefits, according to the agency’s latest statistics. CBP has conducted 2,334 validations this year and expects to complete 670 more by the end of the year to achieve its objective of doing 3,000 validations in 2007, Skinner said.
CBP’s goal is to conduct 3,600 overseas supply chain security audits in 2008 and even more in 2009, he added.
The agency has suspended or removed 416 companies from the program, about half of them Mexican long-haul highway carriers. The suspension figures are more than double the amount since the program’s inception in 2002 through 2006.
Skinner said CBP has granted Tier 3 status to 230 companies, meaning they are now eligible for the lowest risk scores and other facilitation benefits.
CBP is in the process of setting up management teams to run the new Houston and Buffalo C-TPAT offices by the end of the year and hopes to hire and deploy field auditors shortly thereafter, Skinner said. The new offices will focus on Canada and Mexico supply chains.
There are still fewer than a dozen companies that have taken advantage of the third-party validation program that CBP is offering in China, where its own inspectors so far have not been permitted to travel, Skinner said. CBP set up the one-year trial program at the insistence of Congress and implemented it to help companies whose only suppliers are in China receive validations. CBP certified 11 private companies to conduct validations on its behalf, but shippers have been reluctant to pay for the service so far.
CBP and China Customs have recently reached preliminary agreement to allow U.S. officers to visit Chinese companies, but details remain to be worked out.
Meanwhile, CBP should seriously explore opening C-TPAT to exporters so that U.S. companies can meet the requirements of trade security programs in the European Union and other countries, said COAC member Bruce Leeds, senior export/import advisor for Boeing Co. Without an export component to C-TPAT, countries may find it difficult to share the results of their audits and grant mutual benefits to those companies to ease the burden of applying to multiple security programs.
Leeds said jurisdictional issues with doing domestic supply chain audits could be avoided if the program is properly planned, and COAC would help lobby for extra funds to handle export validations.
Additional information is available at the CBP Web site at www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/air_carrier_criteria/ ' Eric Kulisch