CBP Discusses C-TPAT Third Party Validation Pilot and Other C-TPAT Issues
On October 4, 2007, the Senate Commerce, Science, and Transportation Committee held a hearing, entitled "Security of Our Nation's Seaports."
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The purpose of the hearing was to review the Department of Homeland Security's implementation and administration of several port and cargo security programs authorized in the Security and Accountability for Every (SAFE) Port Act, the Maritime Transportation Security Act of 2002, and the Coast Guard and Maritime Transportation Act of 2004.
U.S. Customs and Border Protection's Assistant Commissioner of the Office of Field Operations testified at the hearing and discussed the Customs-Trade Partnership Against Terrorism Third Party Validation Pilot and other C-TPAT issues. (See future issues for additional CBP topics discussed at the hearing.)
Trade Interest in C-TPAT Third Party Validation Pilot for China Has Been Minimal
CBP stated that interest in the C-TPAT third party validation pilot for China has thus far been minimal, noting that of the more than 300 C-TPAT importers that were invited to participate, to date less than a dozen have chosen to do so.
The primary concerns expressed by C-TPAT members for not participating were the sharing of proprietary business and security data with a third party and the costs associated with the validation, which must be incurred by the C-TPAT importer.
Chinese Government is Currently Reviewing Third Party Validation Pilot
CBP states that the Chinese government has officially indicated that CBP's development and implementation of the C-TPAT third party validator pilot is under review, noting initially that the private sector in China may be reluctant to have C-TPAT validations conducted in-country.
In order to demonstrate trade support for the process, CBP states that it identified a certified C-TPAT partner that has significant business in China to demonstrate its willingness to participate in the validation process. In addition, the CBP Commissioner and senior managers have traveled to China to discuss this matter in an effort to clarify the validation process as well as to offer a joint validation pilot involving five currently certified C-TPAT companies willing to participate. CBP notes that, to date, it has not received an official response to this proposed project.
CBP is Reviewing Current C-TPAT Minimum Security Criteria
CBP states that clearly defined minimum security criteria have been developed and implemented for the major C-TPAT enrollment sectors and will be completed for all current enrollment sectors by fall 2007.
(Currently, air carriers and air freight consolidators, ocean transportation intermediaries, and non-vessel operating common carriers (NVOCCs) only have minimum security guidelines in place.)
The SAFE Port Act requires CBP to work with the Departmental Advisory Committee on Commercial Operations of CBP and Related Homeland Security Functions (COAC) to review and modify, as appropriate, these criteria on an annual basis, and CBP states that it has done so. CBP states that this will be completed each year as part of the development of the C-TPAT annual plan, another SAFE Port Act requirement. CBP states that it is finalizing revisions to the C-TPAT Strategic Plan, which was first published in December 2004.
(See ITT's Online Archives or 10/10/06 news, 06101005, for BP summary of the C-TPAT provisions in the SAFE Port Act.)
CBP to Create New C-TPAT Offices in Buffalo, NY and Houston, TX
CBP states that an additional staffing of 50 supply chain security specialists will be brought on board with the creation of two new offices - one in Buffalo, NY to focus principally on Canadian membership, and one in Houston, TX to focus on Mexican enrollment. With the addition of this staff, expected by early 2008, CBP expects to be in compliance with the SAFE Port Act mandated timelines for validations.
(See ITT's Online Archives or 04/27/07 news, 07042705, for BP summary of CBP's notice announcing the C-TPAT third party validation pilot.
See ITT's Online Archives or 08/01/07 news, 07080105, for BP summary of CBP's updated information on its C-TPAT third party validation pilot, which listed an 11th validator.)
CBP written hearing statement (dated 10/04/07) available at http://commerce.senate.gov/public/_files/CBPSenateCommerceWrittenStatement100407000.pdf.