CBP and Others Testify Before House Homeland Security Subcommittee During Six Month Review of SAFE Port Act

This is Part I of a series of summaries on the consolidated statements of CBP, Coast Guard, and TSA officials and provides highlights regarding the Container Security Initiative (CSI), Customs-Trade Partnership Against Terrorism (C-TPAT), etc. See future issue of ITT for Part II, which will highlight issues regarding the Transportation Worker Identification Credential (TWIC) program.

Highlights of CBP, Coast Guard, and TSA Consolidated Statements

CBP is developing a resource optimization model for Office of Int'l Trade. To meet the Congressional requirements of the SAFE Port Act, CBP is developing a resource optimization model (ROM) for the Office of International Trade (OT)¹ which will be designed to determine the right number and right mix of resources to facilitate legitimate trade.

Additionally, in preparation of submitting a report on the reorganization into the OT, CBP has been meeting regularly with the related Departmental Advisory Committee on Commercial Operations of Customs and Border Protection and Related Homeland Security Functions (COAC) subcommittee.

CBP Expects C-TPAT program to fulfill its operational goals for 2007, 2008. With current staffing levels, CBP expects the C-TPAT to fulfill its operational goals for calendar years 2007 and 2008.

2009 validations/revalidations expected to exceed 4,000. CBP projects that revalidations will reach over 2,300 in 2009. The addition of Mexican Highway Carrier validations (done annually due to higher risk models) will add approximately 400. Further, required initial validations within 1 year of certification are being projected at 1,500. As a result, the final validation/revalidation totals needed would well exceed 4,000 for 2009.

By end of 2007, CSI will be operational in 58 foreign seaports. Today, CSI is operational in 50 ports covering 82% of the maritime containerized cargo shipped to the U.S. CBP projects that by the end of 2007, CSI will be operational in 58 foreign seaports, covering over 85% of cargo destined for the U.S. The statement notes that CSI Declarations of Principles for each of the additional eight ports have been signed.

CBP continually updates ATS, working on enhancing the ATS Maritime rule set. CBP continually updates the Automated Targeting System and regularly reevaluates to improve the data sets in ATS.

CBP has been working to enhance the ATS Maritime rule set capabilities for ocean cargo targeting. Updated rule sets were placed into production on March 21, 2007, to conduct initial assessments. Since that time, there have been further refinements and enhancements to the maritime rule set.

CBP is currently modeling several versions of a new Country of Interest list to include iterations of different scores and scenarios to include entity concepts such as first time, unknown, and high volume. CBP's Office of Field Operations is currently using the updated rule set (OCEN5) for maritime threshold targeting.

DHS expects to submit international supply chain plan by July 10th deadline. The SAFE Port Act requires the Department of Homeland Security to develop and implement a strategic plan to enhance the security of the international supply chain, including protocols for post-incident resumption of trade.

A working group consisting of DHS component subject matter experts convened shortly after enactment and completed drafting the strategy in early February 2007. DHS is currently consulting with appropriate groups and is on track to finalize the document and meet the July 10, 2007 submission deadline.

Necessary technology does not exist for container security minimum standards. DHS does not believe that, at the present time, the necessary technology exists for having minimum standards for container security as they would likely cause significant disruption of the flow of legitimate commerce. DHS is actively working with industry to test different technologies and methodologies that would provide economically and operationally viable enhancements to container security.

(It should be noted that C-TPAT minimum security criteria include a requirement that all C-TPAT importers affix a high security seal to loaded containers bound for the U.S. These seals must meet or exceed the current ISO/PAS 17712 specifications for high security seals.)

DHS recently submitted its RPM deployment strategy to Congress. The SAFE Port Act requires that a deployment strategy plan be developed for the placement of radiation portal monitors (RPMs) throughout U.S. ports of entry. DHS recently submitted this plan to Congress.

Specifically, the SAFE Port Act mandates that all containers entering through the top 22 seaports be scanned for radiation. Currently, DHS has deployed radiation detection equipment to each of these 22 ports. Due to unique operational considerations at some of these ports, not every terminal within a port is currently equipped with such equipment. However, the statement notes that by the end of 2007, CBP will scan 98% of all containerized cargo at these 22 seaports. With the additional deployment of radiation screening equipment, CBP currently scans 91% of the cargo and 81% of the passenger vehicles arriving from Canada; 96% of the cargo and 91% of the passenger vehicles arriving from Mexico, as well as 89% of arriving sea-borne cargo containers.

Coast Guard expects to complete initial foreign port assessments by March 2008. The Coast Guard has increased the pace of foreign port assessments and is on track to complete an initial assessment of all trading partners by March 2008. The Coast Guard intends to conduct assessments on a two year cycle thereafter.

Maritime facilities to be inspected at least twice a year (once unannounced). Due to an increase in funding, the Coast Guard will be able to ensure that each maritime facility is inspected no less than two times per year, with at least one being an unannounced inspection.

(See ITT's Online Archives or 11/06/06 news, 06110625, for the final part of BP's summary on the SAFE Port Act, with links to previous parts.)

¹Also referred to by CBP as the Office of Trade.

Consolidated statements (dated 04/26/07) available at http://homeland.house.gov/SiteDocuments/20070427081129-55763.pdf