CBP Issues FAQ on C-TPAT Validation Process

(C-TPAT is a voluntary government-business initiative to build cooperative relationships that strengthen and improve overall international supply chain and U.S. border security. Through C-TPAT, CBP asks businesses to ensure the integrity of their security practices and communicate and verify the security guidelines of their business partners within the supply chain. To date, CBP has issued minimum-security criteria for: importers, customs brokers, third party logistics providers (3PLs), U.S. and foreign-based marine port authority and terminal operators, Mexican long haul highway carriers, air carriers, rail carriers, foreign manufacturers, U.S./Canada and U.S./Mexico highway carriers, and sea carriers.)

The following are highlights of the information provided in the FAQ:

Explanation of C-TPAT Validation Process

A C-TPAT validation is a process through which the CBP C-TPAT program meets with company representatives and visits selected domestic and foreign sites to verify supply chain security measures contained in the C-TPAT participant's security profile are accurate and are being followed.

Goal of a C-TPAT Validation is to Ensure Company's Security Profile is Reliable

The principal goal of a validation for CBP is to ensure that the company's C-TPAT security profile is reliable, accurate, and effective. However, validations also provide a forum through which CBP and a C-TPAT participant can build a stronger partnership by discussing supply chain security issues, sharing "best practices," and cooperatively developing solutions to address potential vulnerabilities.

CBP adds that a validation is not an audit. Whereas CBP routinely performs audits in a variety of operational and regulatory areas (e.g. trade compliance, NAFTA), C-TPAT validations do not measure a company's adherence to existing government rules and regulations. Instead, the validation is focused on the verification of supply chain security processes and procedures that a company voluntarily agrees to verify or perform under the auspices of the C-TPAT program.

Security Profiles of C-TPAT Participants Validated within 1 Year of Certification

CBP validates the security profiles of all C-TPAT participants in accordance with SAFE Port Act requirements. The Security and Accountability for Every (SAFE) Port Act of 2006 requires validation within one year of the company being certified.

If Validation Findings are Satisfactory, Results Will Increase Benefit Levels

At the conclusion of a validation, company management will be briefed on the findings of the validation. Additionally, a written Validation Report will be prepared and presented to the company shortly thereafter.

If the validation findings are satisfactory, the results will increase the level of benefits provided to participants. If the validation findings reveal significant weaknesses in the company's application of C-TPAT guidelines or criteria, some or all of the participant's C-TPAT benefits may be suspended or removed until corrective action is implemented and verified.

(According to the C-TPAT program benefits guide, tiered benefit levels for C-PTAT partners ensure that examination benefits are commensurate with the partner's status in the program and are recognized by the SAFE Port Act. Minimal program benefits are afforded until after an on-site validation is performed to confirm that the C-TPAT member has in fact adopted tighter security measures. The highest level of program benefits are awarded to those partners that exceed the minimum-security criteria.)

(See ITT's Online Archives or 03/26/09 news, 09032610, for BP summary of a CBP official recently providing an update on C-TPAT.)

FAQs available at http://www.cbp.gov/xp/cgov/trade/cargo_security/ctpat/ctpat_validation/validation_faqs.xml