IANA/NITL 2005 - C-TPAT evolving into three-tiered program

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CBP establishing hierarchy of requirements and benefitsBy Peter A. Buxbaum, AJOTUS Customs and Border Protection believes that the Customs-Trade Partnership Against Terrorism should be a dynamic, rather than a static, program. C-TPAT is a voluntary government-private partnership for importers, shippers, intermediaries, carriers, and other international trade actors. Established in the wake of the terror attacks of September 11, 2001, C-TPAT will be demanding higher levels of supply chain security in exchange for increased benefits for companies that invest and adopt C-TPAT security criteria, according to a CBP official who spoke at a recent trade symposium in Washington.
The result will be a three-tiered system of C-TPAT benefits, based on the level of security, validation results, and use of C-TPAT best practices, according to Todd Owen, acting executive director for cargo and conveyance security at CBP’s Office of Field Operations.
C-TPAT security criteria issued by CBP earlier this year, which the agency is now phasing in, requires C-TPAT importers to use their leverage over foreign vendors to meet minimal security criteria at the point where containers are stuffed. Importers must also see that their vendors incorporate C-TPAT security standards into commercial documents such as requests for proposals and purchase orders and are required to monitor compliance by those vendors.
This measure has extended CBP’s cargo security program beyond the US government’s usual scope. “The US Government does not have the regulatory reach into the supply chain beyond our borders,” Owen explained. “C-TPAT companies use their leverage with their foreign vendors to increase security at all points in the supply chain.”
The first C-TPAT tier will consist of certified companies, according to Owen. “These are companies that have submitted security plans, have committed to meet C-TPAT minimal security criteria, and had those plans evaluated and approved by CBP supply chain security specialists and have had no history of significant compliance or law enforcement problems,” he explained.
Tier One benefits include reduced ATS scoring, which means fewer security and compliance inspections. “Only C-TPAT members, C-TPAT certified importers and carriers, have access to FAST lanes on the land borders,” Owen added. “Only C-TPAT members are eligible for the Importer Self-Assessment Program, for training classes, and for assistance with security issues.”
The Second Tier would consist of validated C-TPAT companies. “They would get even further ATS reduction in their scoring, and even fewer inspections,” Owen said. CBP has already validated the supply chains of ten percent of all certified C-TPAT members, with another 20% in progress. Among the added benefits for validated C-TPAT partners will be prioritization of their shipments to the front of inspection lines when one of their shipments is up for either a random inspection by CBP or for inspection by another agency due to its separate requirements.
Tier Three will consist of validated C-TPAT members who have also adopted C-TPAT best practices. “The third tier is the highest level for C-TPAT,” said Owen. “These companies are the ones that get the Green Lane. That means that C-TPAT partners that meet the gold standard of best practices will get no inspections for security.” They will be subjected to infrequent random inspections, however.
Owen emphasized that Tier Three members will have to shoulder a continuing obligation to improve their supply chain security. For example, he said, if and when smart containers come into use, they may very well be required for Tier Three membership. In addition, CBP will be pushing Tier Three members to adopt the highest corporate governance standards in an effort to inculcate supply chain security throughout all ranks of a company. “We believe that it is critical to push down security concepts to all components of a company from the top,” Owen said.
Owen also noted that CBP will soon be publishing a catalog o

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Peter Buxbaum has been writing about international trade and transportation, as well as security, defense, technology, and foreign policy, for over 20 years. Besides contributing to the AJOT, Buxbaum's work has appeared in such leading publications as [em]Fortune, Forbes, Chief Executive, Computerworld, and Jane's Defence Weekly[/em]. He was educated at Columbia University.