CBP Plans to Ramp Up C-TPAT Validations
At the February 6 COAC meeting, Under Secretary Hutchinson said that CBP is planning to increase the number of validations of participants in the Customs-Trade Partnership Against Terrorism (C-TPAT). CBP uses validations to ensure that the supply chain security measures contained in the C-TPAT participant's security profile have been implemented and are being followed. CBP will seek to both reduce the amount of time it takes to conduct validations and increase the number of validations performed, in large part by dedicating more resources to the task. CBP is continuing to hire and train supply chain security specialists for this purpose - 20 are already on the job, and another 40-60 should follow in 2004. CBP has initiated over 700 validations so far, completed 140, and wants to bring that number to 300 or more this year. That would represent more than 60% of the C-TPAT participants who are eligible to undergo validations.The increase in validations is part of a CBP effort to improve its ability to measure participants' compliance with C-TPAT-related security measures. Along the same lines, the trade community has asked CBP to provide it with information on the effectiveness of C-TPAT and other security programs. CBP officials said that they are currently using measurements such as narcotics seizures and compliance rates to evaluate the success of these programs in comparison to before their implementation, but added that CBP is also willing to consider examining other data and sharing the results with the trade. However, they added that information on targeting rates and results will probably remain internal to CBP, and that only anecdotal evidence will be made public. CBP has made clear that it intends to continue to refine C-TPAT in 2004, and the COAC said that it would report back by its next meeting in early April on its recommendations for enhancing the program. One change that CBP is looking to make is requiring C-TPAT participants to meet certain standards with respect to container locks and seals, and Hutchinson said that a new Container Working Group will work with industry to develop those standards. Hutchinson indicated that Elaine Dezenski, the newly appointed Director of Cargo and Trade Policy in the DHS Directorate of Border and Transportation Security, will play a leading role in this group. In general, Dezenski will direct the Cargo and Trade Policy Unit, which focuses on policy initiatives related to international cargo, trade, and supply chain security. This unit will work closely with CBP and the Transportation Security Administration (TSA) on cargo screening and trade facilitation policy matters such as C-TPAT, the Container Security Initiative (CSI), and advance manifest requirements and targeting. Hutchinson stressed that CBP does not plan to make C-TPAT mandatory, stating that he believes partnerships are better than regulatory requirements. However, he suggested that if participants do not comply with their agreed security measures, or if there is a cargo-related terrorist incident despite the existence of the program, pressure to take "more stringent" measures could increase.