CBP Clarifies Its RFI Technical Requirements for Container Security Devices

CBP has subsequently posted several clarifications in the form of question and answer (Q&A) documents and "modifications" regarding the RFI. (Note that the modifications do not change the RFI and are simple clarifications regarding the date, the point of contact, etc.)

The RFI response date is February 12, 2008 (from February 9, 2008, as previously reported by BP).

Highlights of CBP's Documents Clarifying its RFI on CSDs

Highlights of CBP's documents clarifying its RFI on CSDs include the following (partial list):

Operational scenarios being tested. CBP states that it has not released an operational needs document, but that Section 4 of the CSD Requirements document contains notional scenarios in which a CSD system would be field tested. In addition, in its "Synopsis" document, CBP states that it will conduct evaluations in scenarios that accurately represent its operational environment, which may include:

a supply chain scenario from a Customs-Trade Partnership Against Terrorism (C-TPAT) company in Mexico from the point of stuffing to arrival at a U.S. port of entry along the southern border;

an in-transit scenario involving high-risk commodities in ISO maritime containers as they travel in-bond via Transportation and Exportation (T&E) entry from a west coast seaport to a land border port along the southern border;

an in-transit scenario involving high risk agriculture products in-bond via T&E entry through the U.S. from either Canada to Mexico or Mexico to Canada; and/or

a maritime scenario involving containers that are scanned overseas at a Secure Freight Initiative (SFI) port and laden aboard a vessel bound for the U.S.

Phased approach to testing, hardware required as appropriate. CBP's evaluation process will consist of a phased approach. In order to qualify for testing in successive phases,¹ an offer must complete all testing in the preceding phase. If an offer continues into the next phase, hardware and/or additional material will be required. (CBP states that hardware is not required to be submitted with an offer's initial application package.) CBP adds that it has not established a pre-defined schedule for the phases as the timeframe will depend on the number of CSD systems received.

Partially compliant CSD systems will not be accepted. CBP states that it will not accept partially compliant systems that do no meet all of the system design requirements (such as the interoperability between CSDs and CSD readers) under this RFI. CBP adds that mandatory system requirements are indicated by use of the word "shall" throughout the CSD requirements documents.

RFI will not result in RFP or certification. CBP stresses that its RFI does not constitute a Request for Proposal (RFP) or a promise to issue one in the future, and that it will not be certifying any of the submitted CSD systems. According to CBP, its RFI is for informational and planning purposes only. CBP adds that vendors who do not respond to CBP's RFI will not be precluded from participating in any future RFP issued.

Looking for improvements since 2002 RFI. CBP states that the submissions it received from a June 2002 RFI soliciting CSD technology did not meet CBP's operational needs. As a result, CBP generated technical and administrative CSD requirements that if met by industry, could be used in CBP's operational environment. With the issuance of this RFI, CBP is re-initiating contact with industry in hopes that improvements had been made pertaining to CSD technology.

Goal is to test mature CSD systems, evaluate readiness, etc. CBP states the goal of the RFI is to identify whether currently available CSD systems meet CBP's requirements and to test mature, already existing CSD systems in laboratory, field and under operational conditions in order to evaluate system readiness for operational deployment.

Definition of "move." CBP clarifies that the term "move" in its CSD Requirements document is defined as the trip a conveyance will undertake with a CSD installed and operating with the starting and ending points defined in the four operational scenarios listed above.

Questions should be emailed. According to CBP's "Modification 01" document, all questions should be emailed to CBP.Conveyancesecuritydevice@dhs.gov for an official response. CBP notes that firms will not receive individual responses but the questions and official answers will be posted on www.FBO.gov. CBP requests the trade not to send questions directly to the point of contact, as they will not be answered or forwarded.

¹Test phases include: Phase 1- Technical Review of Vendor Submittal; Phase 2A - Initial Technical Evaluation; Phase 2B - Laboratory Testing; Phase 3 -Limited Operational Testing; and Phase 4 - Large-scale Operational Field Testing.

(See requirements documents posted with the RFI for CSD data elements and their requirements, CSD commands, CSD reader functional requirements, status sensing requirements, etc.)

(See ITT's Online Archives or 01/04/08 news, 08010499 1, for BP summary of CBP's intent to require standard bolt seals for international containers entering the U.S.

See ITT's Online Archives or 12/12/07 news, 07121299 1, for BP summary of a CBP official stating that CBP is looking at limited use applications for CSDs.

See ITT's Online Archives or 07/17/07 news, 07071705, for BP summary of CBP Commissioner Basham stating that the use of CSDs may become a part of the C-TPAT program, etc.)

- RFI closes on February 12, 2008

CBP contact - Sonya Harmon (202) 344-3727

CBP email - CBP.Conveyancesecuritydevice@dhs.gov (for submission of all questions)

CSD documents (including four modifications and two Q&As (dated 12/20/07, 01/08/08, 01/09/08, and 01/10/08) available at http://www.fbo.gov/spg/DHS/USCS/PDDC20229/Reference%2DNumber%2DRFICSD/listing.html

CSD Requirements (Baseline Version, Version 1.2, dated 12/10/07) available at http://fs1.fbo.gov/EPSData/DHS/Synopses/35419/Reference-Number-RFICSD/CSDReqVersion1p2.pdf

CSD: CSD to CSD Reader, Interface Control Document (Baseline Version, Version 1.0, dated 12/10/07) available at http://fs2.fbo.gov/EPSData/DHS/Synopses/35419/Reference-Number-RFICSD/CSDtoCSDReaderICDv1p0.pdf

CSD: CSD Reader-to-Data Consolidation Point, Interface Control Document (Baseline Version, Version 1.0, dated 12/10/07) available at http://fs2.fbo.gov/EPSData/DHS/Synopses/35419/Reference-Number-RFICSD/CSDReader-to-DCPBaselinev1p0.pdf