CBP Issues Revised "Draft" of New C-TPAT Security Standards for Importers
Although Broker Power had been informed that a document that was largely transcribed in ITT's November 12, 2004 issue was the 'second draft' of U.S. Customs and Border Protection's proposed new C-TPAT Security Standards for Importers, that document may actually have been the 'first draft,' as Broker Power has obtained another draft version entitled: "Draft 2 - C-TPAT Security Standards for Importers."
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(See ITT's Online Archives or 11/12/04 news, 04111210 for BP summary of what BP is now terming the ' first draft.')
Highlights of True 'Second Draft'
Most of the significant changes from the 'first draft' to 'Draft 2' occur on the first page of the drafts. Highlights of these 'first page' changes are as follows:
Risk analysis instead of minimum standards. Appropriate supply chain security measures would be 'based on risk1' rather than 'minimum standards that should be followed on a case-by-case basis depending on the company's size and structure.'
(1 importers would have a documented and verifiable process for determining risk
throughout their supply chains based on their business model (i.e. volume, country of
origin, routing, potential terrorist threat via open source information, etc.)
Brokers, carriers, consolidators, etc. Carriers, terminal operators, brokers and consolidators are no longer listed as business partners for whom the importer must have written and verifiable selection processes.
Instead, for those business partners eligible for C-TPAT certification (carriers, terminal operators, brokers and consolidators, etc.), the importer must have documentation indicating that these business partners are/are not C-TPAT certified.
Only non-C-TPAT business partners would submit responses to security questionnaires. Only current and prospective business partners that are not C-TPAT certified would submit a written response to a security questionnaire regarding their current security procedures. The importer would review these questionnaires and responses, and if weaknesses are noted, the importer should implement the appropriate action plan based on risk, that would assist the business partner improve their security.
(The previous draft had stated that all current and prospective business partners would submit a written report or response to such a questionnaire.)
"Draft 2" Not Yet Available for Distribution
Broker Power is trying to obtain another copy of 'Draft 2' from another source, as the association that made the initial copy available requested that it not be distributed beyond the association membership.
See future issue of ITT for further information on 'Draft 2.'