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07-23-2010 - C-TPAT: Exam Benefits and Risk Assessment

With more than 7,400 companies currently participating, the Customs Trade Partnership against Terrorism (C-TPAT) program continues to grow and evolve. While the principle goal of C-TPAT is enhanced border security, the program is designed to offer benefits to its members.

U.S. Customs and Border Protection (CBP) indicated C-TPAT members are 4 to 6 times less likely to incur a security or compliance examination. They also advised that “CBP has significantly increased the exam rate over the last several years”. Inbound ocean container exam rates increased by 68% in 2008 when compared to 2002.

In addition to a reduction in overall examinations several benefits are extended to C-TPAT members including the following: 

  • Stratified exam benefit whereby imports consisting of multiple containers, with only one container targeted for exam, may move the remaining containers to their premises. These containers must remain sealed and available for inspection contingent upon the result of the examination of the targeted container.
  • Front-of-the-Line privileges allow C-TPAT member containers targeted for exam to be moved ahead of non C-TPAT shipments awaiting exam, regardless of how long they have been there.
  • Business resumption is a benefit that will allow C-TPAT members first consideration in the resumption of trade in the event of a serious disruption.
  • Mutual recognition is a trend in which C-TPAT members, or their suppliers, participating in CBP approved security programs administered by other counties will receive additional benefits.
  • Several additional benefits currently exist or are proposed for C-TPAT members.

While the benefits of becoming a member are tangible the process of obtaining and retaining membership continues to evolve. A result of CBP’s ongoing assessment of members was the publication of a trade bulletin dated April 23, 2010 regarding international supply chain security risk assessments. A documented risk assessment is a requirement for acceptance into the C-TPAT program and then, at a minimum, must be updated annually thereafter. The risk assessment must address the minimum security criteria requirements as published by CBP.

The trade bulletin stated “During the validation and revalidation process and when conducting an in-depth review of security breaches, it became apparent that the process of conducting an international supply chain security risk assessment was not being performed completely.  Most C-TPAT members are conducting a comprehensive domestic risk assessment of their own facilities and processes in the United States; however, many members were not assessing the potential threats and vulnerabilities that may exist within their international supply chain from the point of packing / stuffing and at each transportation link within the chain, until the cargo reaches the final point of distribution in the United States. “

A Security Risk Assessment is a fundamental component of a company’s security program and the trade bulletin outlines a basic “5 Step Risk Assessment Process Guide” which includes:

  1. Mapping Cargo and Business Partners: Identify business partners and how cargo moves throughout the supply chain. Include modes of transportation (air, sea, rail or truck) and nodes (country of origin, transit points).
  2. Conducting a Threat Assessment: Identify such threats as Terrorism, Contraband / Human Smuggling, Organized Crime, or other Conditions which may increase the probability of a security breach.  
  3. Conducting a Security Vulnerability Assessment: Based on C-TPAT minimum security criteria, determine if Business Partners have gaps, vulnerabilities, or weaknesses which may lead to a security breach.
  4. Preparing an Action Plan to Address Vulnerabilities: Developing a written strategy to address potential gaps, vulnerabilities, and weaknesses.  
  5. Documenting How the Security Risk Assessment is Conducted: Writing the policies / procedures on who will be responsible for conducting the assessment; what will be included in the assessment; why the assessment must be conducted; when (how often) the assessment will be conducted; where the assessments will be conducted; and how the assessment will be conducted.

Since publication of the trade bulletin a Frequently Asked Questions and a C-TPAT Supply Chain Risk Assessment Guide were published on July 1, 2010 and July 21, 2010 respectively. These documents, in conjunction with comprehensive information on the C-TPAT program, may be found at:

http://www.cbp.gov/xp/cgov/trade/cargo_security/ctpat/

Geo. S. Bush & Co., Inc. (GSB) is a C-TPAT member and proficient in understanding the C-TPAT program and requirements. Please think of Geo. S. Bush & Co., Inc. as your C-TPAT partner and do not hesitate to contact us should you wish to discuss the benefits of being a C-TPAT member. Please call (503) 228-6501, and/or email: info@geosbush.com.