COAC, CBP, and TSA Discuss Overlaps in C-TPAT, CCSP Approval Process, Etc.

The following are highlights of their comments:

Overlaps in C-TPAT, CCSP Approval Process

One of the two priority areas that COAC's Air Cargo Security Subcommittee has identified for developing recommendations is the approval process for the Customs-Trade Partnership Against Terrorism (C-TPAT) and the Certified Cargo Screening Program (CCSP). The Subcommittee states that it will continue its analysis of the overlap between the two programs and will look for potential areas for coordination.

Possible abbreviated approval process. The Subcommittee will look at whether it would be possible for someone approved in one of these programs to apply to the other program using an abbreviated process. According to the Subcommittee, companies participating in C-TPAT and CCSP should have a common set of standards and validations should be coordinated.

CBP officials asked the Subcommittee to clarify whether it would be looking at an abbreviated approval process for one program to the other or mutual recognition between the two programs. Subcommittee sources explained that they would be looking at an abbreviated process, not complete mutual recognition from one program to the other.

C-TPAT validation already considered. Officials also noted that being a validated C-TPAT member is already taken into consideration by TSA during the CCSP approval process. The official also noted that the Subcommittee would have to consider the differences between C-TPAT and CCSP, including the fact that C-TPAT applies on a corporate level, while CCSP applies on a facility basis.

Development of C-TPAT for Exporters

Subcommittee members also note that the development of a program such as C-TPAT for exporters is an example of a process that should involve coordination between CBP and TSA.

(COAC members have previously raised the issue of extending C-TPAT to exporters. In the past, CBP has expressed reservations about expanding C-TPAT to exporters due to implementation and resource issues. CBP had also previously stated that once it begins to build a solid foundation in the area of mutual recognition, it could then consider an expansion of C-TPAT to exporters.)

Air Cargo Security Matrix is Essentially Complete

According to the COAC Air Cargo Security Subcommittee, its data matrix of the various cargo security-related programs that affect trade participants in the air cargo supply chain is essentially complete, with only some minor clean up left to be done. According to the Subcommittee, the completed matrix will soon be posted to CBP's Web site.

(The Subcommittee has been working on a matrix to identify areas of possible redundancy and/or areas that could be leveraged to improve and streamline domestic and international air cargo security. A draft matrix was originally posted to CBP's Web site in August 2009 and the most recent update to the matrix was posted in late October 2009.)

Redundancies in Various Background Checks and Vetting to be Examined

The second priority area that the Subcommittee will work on developing recommendations is eliminating redundancies in background checks and vetting for various parties, such as air cargo workers, forwarders, truckers, etc. The Subcommittee will begin to identify any possible regulatory and process modifications to eliminate redundancies.

(See today's ITT, 09111720, for BP summary of TSA's request for comments on its CCSP information collection.)

(See ITT's Online Archives or 08/18/09 news, 09081815, for BP summary of Subcommittee's plans announced at August 2009 COAC meeting.

See ITT's Online Archives or 10/16/09 and 10/22/09 news, 09101620 and 09102235 1, for BP summaries on the posting of updated matrices.)