CBP Officials Discuss C-TPAT Validations, Best Practices, Suspensions, Etc. With COAC
During the May 16, 2006 meeting of the Departmental Advisory Committee on Commercial Operations of the Bureau of Customs and Border Protection (COAC), U.S. Customs and Border Protection (CBP) officials discussed the Customs-Trade Partnership Against Terrorism (C-TPAT), highlights of which are provided below.
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Third party validations. CBP officials stated that they are seriously looking at the use of third parties for C-TPAT validations. Officials note that the use of third party validators would not be an abdication of the government's responsibility, rather they could be used as a "force multiplier." Officials further note that the discussion of third party validations is in a very early stage within CBP.
(See ITT's Online Archives or 05/10/06 news, 06051010, for BP summary of the House's passage of the SAFE Port Act, which contains a provision requiring a pilot of third party entity C-TPAT validations.)
CBP has completed validations for 32% of certified C-TPAT members. CBP officials stated that to date, 1,900 validations have been completed, which represents 32% of certified C-TPAT membership. CBP officials further stated that another 2,200 C-TPAT validations are currently in process.
According to CBP officials, CBP is on target to reach its goal of completing validations for 45% of certified members by July 1, 2006 and 65% by December 31, 2006.
145 companies have been suspended or removed from C-TPAT program. CBP officials state that 145 companies have been suspended or removed from the C-TPAT program. CBP officials stated that these companies were suspended or removed from the C-TPAT program because (1) of negative validation findings; or (2) they experienced a security "incident" in which their supply chain was breached (e.g., smuggling, drugs, etc.)
Best practices. CBP officials state that they will be providing additional details on C-TPAT best practices when the C-TPAT Security Link Portal becomes operational.
(See ITT's Online Archives or 05/18/06 news, 06051805, for most recent BP summary on the C-TPAT Security Link Portal.)
CBP not ready to allow 3PLs and 4PLs into C-TPAT yet. In response to trade requests that CBP consider allowing 3PLs and 4PLs to participate in C-TPAT, CBP officials stated that they are not quite ready to open up C-TPAT to any new sectors yet.
Draft C-TPAT minimum security criteria for air and rail carriers. CBP officials state that "draft" minimum security criteria for air and rail carriers have been developed and CBP is in the process of receiving feedback on them from the trade community.
Officials note that once a final, conclusive version of the minimum security criteria for air and rail carriers are completed, a decision would be made on how the criteria will be implemented (e.g., whether to phase-in implementation and, if so, over what period).
(See ITT's Online Archives or 05/19/06 and 05/24/06 news, 06051905 and 06052405, for BP summaries on CBP's recently issued C-TPAT "guidelines" for air and rail carriers, which are precursors to C-TPAT minimum security criteria.)