CBP Officials Discuss CSI, C-TPAT and Office of Trade Issues at August 16, 2007 COAC Meeting

This is Part IV of a multi-part series of summaries on the August 16, 2007 COAC meeting and focuses on information provided by CBP officials and COAC members on various Office of Trade, Customs-Trade Partnership Against Terrorism (C-TPAT), and Container Security Initiative (CSI) issues. See future issues for additional summaries on the August meeting.

CBP Office of Trade Completes Optimal Staffing Model, Works to Ease EPA Vehicle Enforcement

CBP officials discussed a variety of issues relating to its new Office of Trade, including:

Model finds staffing should be increased to reach "optimal" level. CBP officials stated that the Office of Trade has put together a resource allocation model (RAM) on the issue of the optimal resource levels (i.e., optimal staffing levels) for CBP's trade mission, as required by the Security and Accountability for Every (SAFE) Port Act. The RAM was sent to Congress in early July 2007.

(The RAM was to describe the optimal staffing levels required to carry out the commercial operations within CBP, including commercial inspection, release of cargo, and specified revenue functions.)

In preparation of the RAM, CBP officials stated that they looked at issues such as how CBP can meet the growing demands of trade, how it can leverage technology, partnership programs, and process improvements to help the trade mission, etc.

As a result of the RAM, CBP found that there would need to be staffing increases on the trade side for "optimal" function of the trade mission.

(See ITT's Online Archives or 07/13/07 news, 07071399 3, for BP summary of a Senate Finance Committee letter to the CBP Commissioner questioning why CBP had not submitted the RAM by the June 30, 2007 deadline.)

Easing of EPA enforcement policy for vehicle, engine labeling. According to CBP officials, they have been working with the Environmental Protection Agency to change the EPA's enforcement policy for labeling of vehicles and off-road engines. CBP officials noted that there had been a zero tolerance seizure policy and CBP has been working with EPA to ease certain policies in certain instances.

COAC Members Ask for Expansion of C-TPAT Sectors and Benefits

During the August 16, 2007 meeting, COAC members addressed CBP officials on a variety of C-TPAT-related issues, which are highlighted below:

3PLs. COAC announced that it has assembled a subcommittee to address the issue of expanding C-TPAT to include third party logistics providers (3PLs).

(At the May 2007 meeting, CBP announced that it was considering expanding C-TPAT to 3PLs and Mexican long-haul highway carriers. See ITT's Online Archives or 05/17/07 news, 07051705, for BP summary of this announcement. See ITT's Online Archives or 08/09/07 news, 07080905, for details of CBP's August 22, 2007 expansion of C-TPAT to Mexican long haul highway carriers.)

Trade benefits for C-TPAT members. COAC members raised the issue of trade-related benefits for C-TPAT members. COAC members noted that they are interested in making progress on obtaining trade-related benefits for C-TPAT members. Some members expressed the opinion that many of the benefits previously requested (in COAC's 2005 "Green Lane" benefits proposal) have not been addressed sufficiently.

One member noted that two of the previously requested benefits (the expanded ability to file paperless entries and authorization to remotely file all types of entries) were passed to CBP's Office of Trade because it was thought that those benefits would not have to be limited to C-TPAT members, but that such benefits have not yet been granted.

CBP responded to COAC concerns by noting that it would be easier to grant trade-related benefits to C-TPAT members if the C-TPAT validation process (which currently focuses on security issues) included some kind of trade validation and that this is one of the barriers to granting trade benefits to security programs such as C-TPAT. CBP officials expressed a willingness to talk about C-TPAT trade benefits again.

(See ITT's Online Archives or 01/20/06 news, 06012010, for BP summary of COAC's "Green Lane" benefits proposal to CBP.)

C-TPAT for exporters. One COAC member also asked CBP to think about expanding C-TPAT to exporters (to dovetail with the World Customs Organization's (WCO's) Framework of Standards to Secure and Facilitate Global Trade (SAFE Framework).

CBP responded to COAC by noting that it does not have sole authority over exports, but shares responsibility with the Department of Commerce for exports. CBP said that it would keep it under consideration during the evolution of the C-TPAT program.

Report on return on investment survey. CBP officials noted that the University of Virginia (UVA) has completed its report regarding its survey of C-TPAT members to gather return on investment data. A formal copy of the study is expected to be printed by the end of August 2007 and will be posted on CBP's and UVA's Web sites.

Internal CSI Effectiveness Report Due to Congress in September

COAC has been working with CBP to complete a CSI effectiveness report. According to CBP officials, the report will also soon be going to the Department of Homeland Security (DHS) for review. CBP officials note that the report is internal and due to Congress by the end of September 2007.

(See ITT's Online Archives or 08/21/07, 08/22/07, and 08/23/07 news, 07082110, 07082220, and 07082310, for Parts I-III in the series of summaries on the August 16, 2007 COAC meeting.)