COAC Discusses Ways to Eliminate Paper, Redundancies with ATF, EPA, Etc.
At the December 7, 2011 COAC meeting, the COAC Subcommittee on One U.S. Government at the Border (1USG@TB) provided an update on its efforts to identify redundancies with CBP and Participating Government Agency requests for documents/data. The Subcommittee has been focusing its efforts on the PGA member agencies of the Border Interagency Executive Committee1 and has begun a series of phone calls with each of the BIEC’s PGAs in order to discuss issues such as whether there is a need for reliance on paper forms, the viability of leveraging data currently provided to CBP for PGA purposes, how the recognition of an importer’s trusted shipper status by CBP could change the amount/type of data required by a PGA, etc.
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Form 6, Document Imaging Discussed with ATF
On November 3, 2011, the subcommittee held a call with representatives from Alcohol, Tobacco, and Firearms (ATF). The Subcommittee discussed specific examples of opportunities for identifying and eliminating redundancies, ranging from tactical discussions on the potential for streamlining collection of ATF’s required Form 6 (which ATF regulations require to be in paper form), to higher level discussions around the potential for all parties to leverage one imaging platform and one data collection system. After the call, ATF personnel requested that the dialogue with the subcommittee continue in order to explore specific ways to improve the import process. The subcommittee states that future discussions with ATF will address ATF’s development of its own e-Forms system and regulatory requirements that certain information be gathered in paper form.
(See ITT’s Online Archives 09091115 for summary of ATF’s future interface for firearms/defense article imports)
Pesticide Data, Paper Forms Discussed with EPA
The Subcommittee’s second call was held with representatives from the Environmental Protection Agency on November 22, 2011 which focused on pesticides. The Subcommittee discussed the amount of data EPA requires that is already collected via CBP’s processes, the presence of forms that preclude fully automated entry processing, etc.
Further subcommittee discussions with EPA representatives will focus on providing avenues for EPA to gain additional insight into the business processes used by importers and brokers when importing pesticides and higher level discussions on the simplified entry processes being developed by CBP and the trade.
Subcommittee Plans Additional Calls for Other PGAs
The Subcommittee states that it is currently developing timing and action plan for engaging the remaining PGAs that are members of the BIEC and will provide an update on those engagement efforts at the next COAC meeting.
CBP to Provide Overview of PGA Message Set and DIS
CBP will be providing the subcommittee with a high-level overview of the PGA Message Set and the Document Imaging System (DIS) so the subcommittee can gain a better understanding of current PGA modernization efforts.
1The BIEC serves as an Executive Advisory Board to interagency import safety related issues and includes 10 chartered members -- Animal and Plant Health Inspection Service (APHIS); Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF); Consumer Product Safety Commission (CPSC); Customs and Border Protection (CBP); Environmental Protection Agency (EPA); Food and Drug Administration (FDA); Food Safety Inspection Service (FSIS); Immigration and Customs Enforcement (ICE); National Highway Traffic Safety Administration (NHTSA); and National Marine Fisheries Service (NMFS).
(See ITT’s Online Archives 11042933 for summary of CBP’s DIS and its plans to push documents to PGAs using DIS in August 2011.
See ITT's Online Archives 11122064 for summary of TSN report on DIS, etc.
See ITT’s Online Archives 11110416 for summary of eligibility requirements for initial ACE DIS.
See ITT’s Online Archives 11111713 for announcement of CBP’s posting of CATAIR changes for the PGA message set.)
CBP report available here
Subcommittee progress report available here