1. An introduction to the program, state of
play and explanation of its operations
Presented by
Ron May
Director, Buffalo, NY C-TPAT Field Office
March 2012
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Field Operations

2. C-TPAT Achievements
October 9, 2012
• Certified Members by Business Type Importers - 4352
10,397 - Certified Partners to current date
60
885
• 164 - Total C-TPAT staffing level Carriers - 2985
4352
1263
• 21,454 - Total Validations Completed Brokers - 852
– 11,516 - Initial Validations Completed
– 9,938- Re-Validations Completed Foreign Manufacturers - 1263
852
• Number of completed validations by year: Consolidators/3PLs - 885
-2011 / 715-Initial Validations / 2,229-Revalidations
2,940-Total Validations in 2011 Marine Port Authorities and Terminal
2985 Operators - 60
-2012 / 460 -Initial Validations / 1,145-Revalidations
1,605-Total Validations in 2012
• 1,453 - Total Suspensions
• 1,100 - Total Removals
• Internationalization Efforts: Validations By Year
– 6 - Mutual Recognition Arrangements: New Zealand, Canada, Jordan , Japan, Korea, European Union 4000
– 2 - Mutual Recognition Projects: Taiwan, Singapore
3000
– 12 - Technical Assistance Projects: Malaysia, Mexico, Philippines, Guatemala, China, Colombia,
Israel, Peru, Vietnam. Dominican Republic, Costa Rica, India 2000
– 2 - Capacity Building Training Programs: Ghana, Kenya
1000
– 4 - Rounds of joint validations with the General Administration of China Customs
0
• Security Criteria Implemented: 2006 2007 2008 2009 2010 2011 2012
– 10 - Business Entity Types: Importers, Air Carriers, Highway Carriers, Mexico Long Haul Highway
Carriers, Rail Carriers, Sea Carriers, Foreign Manufacturers, Customs Brokers, Port
Authorities/Terminal Operators, Third Party Logistics Providers (3PLs).
• Tiered Benefits Structure – commensurate with security enhancements. Best Practices Catalog.
– 329 - Tier 3 Importers
March 2012
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3. FY10 – Entry Values
Tier III Importers
• 329 Partners
• 27% of Entry Value
• 15% of Entries
March 2012
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4. Supply Chain Security Specialist
“The C-TPAT Supply Chain Security Specialist (SCSS) primarily conducts
C-TPAT Validations of C-TPAT member companies and serves as the principal
advisor and primary point of contact for certified members in the
C-TPAT program.”
• 146 SCSSs Currently On-Board; includes 18 Headquarters employees
• Seven field offices: New York, Washington D.C., Miami, Los Angeles,
Newark, Buffalo, Houston
• Extensive travel
March 2012
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5. Program Travel
• Covered 6 of 7 continents
• Nearly 100 countries visited (multiple visits within higher risk countries)
– Angola - Colombia - Malaysia
– Bangladesh - Brazil - Russia
– Israel - Mexico - Guatemala
– Sri Lanka - Jordan - El Salvador
– Pakistan - Egypt - Haiti
– India - Ivory Coast
– Botswana - Nicaragua
**Each SCSS averages approx. 75-100 days a year on travel
March 2012
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6. C-TPAT Program Business Types
C-TPAT program currently has 10 Business Entity Types:
 Importers
 Sea Carriers
 U.S./Canadian Highway Carriers
 U.S./Mexico Highway Carriers
 Rail Carriers
 Air Carriers
 Mexican and Canadian Foreign Manufacturers
 Licensed U.S. Customs Brokers
 Mexico Long Haul Highway Carrier
 U.S. Marine Port Authority/Terminal Operators
 Third Party Logistics Providers (3PL)
March 2012
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7. Minimum-Security Criteria
• Risk Assessment
• Business Partner Requirements
• Conveyance, Container & Trailer Security
• Physical Access Controls
• Personnel Security
• Procedural Security
• Physical Security
• Security Training and Threat Awareness
• Information and Technology Security
These criteria are posted both in Spanish and English and
the criteria for foreign manufacturers is posted in 12
different languages to include Thai, Chinese and Arabic.
March 2012
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8. What is a Supply Chain?
Supplier
Raw Material
Conveyance
Consumer Consignee
FOR HIGHWAY CARRIERS:
The supply chain for highway carriers for C-TPAT purposes is defined from
the yard where the tractors and trailers are stored, through pickup at the
manufacturer/supplier/vendor, through to the consignee.
March 2012
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9. Validation and Revalidation Visits
• Initial validation visits take place within 12 months of certification (unless documented
circumstances prevent this)
• Revalidation visits take place within 4 years of original validation completed date.
• C-TPAT partner is strongly recommended to attend overseas or foreign portion of validation or
revalidation visit.
• CBP covers cost of its employees for travel and accommodations. C-TPAT participant only
covers cost associated with its own employees.
• Many factors are considered in selecting site visit, but primary focus is still on greatest risk to
overall supply chain and CBP’s need for compliance with the SAFE Port Act.
• Additional considerations:
– Recent incidents or problems at another location
– Newly acquired supply chain components
– Lack of additional sites to visit
– Law enforcement information (internal CBP decision)
– Volume or production rates from site
– Weather, holidays, labor issues, political issues, disease concerns and other unique circumstances.
March 2012
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10. Increase Focus on Evidence of Implementation
Sample Matrix:
Documented Procedures EVIDENCE OF IMPLEMENTATION How far back did you go?
Document/ checklist/ form Reviewed and obtained copy of procedures/ documentation/ files Current week______________________
None Reviewed procedures/ documentation/ files - no copy obtained 1-6 months________________________
Risk Assessment WRITTEN PROCEDURES Observed process / site tour 6-12 months ________________________
Documenation uploaded in portal Photo evidence / document scanned Over 12 months____________________
Other ____________________ Explanation of compliance by management / department employee
Document/ checklist/ form Reviewed and obtained copy of procedures/ documentation/ files Current week______________________
None Reviewed procedures/ documentation/ files - no copy obtained 1-6 months________________________
Business Partners WRITTEN PROCEDURES Observed process / site tour 6-12 months ________________________
Documenation uploaded in portal Photo evidence / document scanned Over 12 months____________________
Other ____________________ Explanation of compliance by management / department employee
Document/ checklist/ form Reviewed and obtained copy of procedures/ documentation/ files Current week______________________
None Reviewed procedures/ documentation/ files - no copy obtained 1-6 months________________________
Conveyance
Security WRITTEN PROCEDURES Observed process / site tour 6-12 months ________________________
Inspection Documenation uploaded in portal Photo evidence / document scanned Over 12 months____________________
Other ____________________ Explanation of compliance by management / department employee
Document/ checklist/ form Reviewed and obtained copy of procedures/ documentation/ files Current week______________________
None Reviewed procedures/ documentation/ files - no copy obtained 1-6 months________________________
Physical Access WRITTEN PROCEDURES Observed process / site tour 6-12 months ________________________
Controls
Documenation uploaded in portal Photo evidence / document scanned Over 12 months____________________
Other ____________________ Explanation of compliance by management / department employee
March 2012
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11. Post Incident Analysis (PIA)
When a C-TPAT participant is involved in a supply chain incident, HQ C-TPAT
program staff will examine the incident and provide details to C-TPAT management so
that they can determine the correct response from the program.
All Post Incident Analysis (PIA) will be conducted within 30 days.
The Field Director will assign a SCSS team to conduct the PIA (usually involving the
company assigned SCSS). The PIA report, with program status, and recommendations
must be finalized within this 30 day time frame.
Once the Field Director receives and reviews the PIA report and discusses and approves
the company status recommendation, the full report and recommended actions are then
forwarded to HQ for review by C-TPAT Management. All final decisions on PIA results,
recommendations and C-TPAT program actions must be approved at the HQ C-TPAT
management level.
March 2012
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12. Canadian Company Participation in C-TPAT
Applicants Certified Validated Suspended/
Removed
Importers 2 39 1041 84
Hwy 23 145 1349 187
Carriers
Foreign 1 10 136 8
Mfrs.
Totals 26 194 2526 279
(10%)
March 2012
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13. Mutual Recognition (MR) Process
(4) Phases
1. Side-by-side comparison of program
requirements
2. Pilot programs of joint
validations/observations
3. Signing of agreement
4. Development of information sharing
procedures
March 2012
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14. PIP/PEP
Presentation courtesy of:
Bill Tu
Senior Advisor, CBSA
International & Bilateral Trusted Traders -
PIP Program
March 2012
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15. Beyond the Border:
“A Shared Vision for Perimeter Security and
Economic Competitiveness”
• The “Beyond the Border” Declaration was announced by Canadian
Prime Minister Stephen Harper and U.S. President Barack Obama
in February 2011
• Four key principles underpinning the Declaration:
- Addressing threats early
- Trade facilitation, economic growth and jobs
- Integrated cross-border law enforcement; and
- Critical infrastructure and cyber security
March 2012
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16. Harmonization of PIP & C-TPAT
Harmonization refers to further aligning both programs, where
applicable, in the areas of policy, procedures and
documentation practices while each country retains sovereignty
over its own program.
Harmonization Benefits:
 Single application process for companies seeking to join both programs
 Only one site validation required
 Creates streamlined and efficient border processes
 Enhances security and integrity of the company’s supply chain
March 2012
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17. Harmonization of PIP & C-TPAT
• Implementation:
– Phase 1: Pilot harmonization of two Canada - and two US-based
highway carriers, completed in 2011
– Phase 2: Harmonization 1.0 of Canada and US highway carriers,
scheduled for 2012
– Phase 3: Harmonization 2.0 of all other common lines of business, line
by line (to the fullest extent possible), scheduled for December 2013
March 2012
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18. How the MR process will work
• Both administrations will use risked base scoring to
lower exam levels. Lower risk level will be
communicated to each administration via automated
systems (in development).
• Each administration will monitor application of risk
reductions through normal measurement matrix’s, but
will also use random audit element.
• Process will be very fluid and evolve quickly through live
learning.
March 2012
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19. MR benefits
• Coordination between US and Canada
administrations
• Less duplication (1 visit for both programs)
• Business resumption considerations for program
participants
• Established points of contact within each
administration
• First to receive important informational notices
• Global marketability
March 2012
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20. Challenges to MR process
• Logistics of process (time, travel, money)
• Differences in information collection and
sharing laws, rules, and regulations
• Development of common data platform to
share information (IT)
March 2012
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21. Centers of Excellence and
Expertise
Overview
May 2012
March 2012
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22. Background
Responding to the Call for Trade Transformation
In direct response to calls for more uniform and efficient facilitation, and in collaboration with
the Commercial Operations Advisory Committee (COAC) during FY 2011 CBP created two
pilots
The resulting pilots underwent careful concept testing and validation both within CBP and
with the broader trade community
CEE and AE Pilots
The Center of Excellence and Expertise (CEE) pilot was established in November 2010 to
enhance facilitation, improve enforcement efforts, and increase CBP's knowledge of the
pharmaceutical industry
The Account Executive (AE) pilot was established to work with selected “trusted partners” in
the electronics industry to facilitate trade, while ensuring continued compliance with all import
requirements
Both pilots relied on small cross-occupational core teams, with matrix staff bringing additional
specialized expertise. At the conclusion of the pilots, the AE concept was combined with the
CEE to create new centers to segment risk, facilitate trade for trusted partners and develop
comprehensive enforcement strategies:
Objective: make CBP’s haystack smaller
March 2012
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23. Current Centers
Four Centers Currently Established since October 2011**
Pharmaceuticals, Health & Chemicals Center (NY, NY)
• Covers the full spectrum of commodities within the Pharmaceutical
industry, and will expand to include Chemicals and Health
equipment industries
Electronics Center (Long Beach, CA)
• Covers the full spectrum of commodities within the Information
Technology and Consumer Electronics industries
March 2012
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24. Current Centers continued
Automotive & Aerospace (Detroit, MI)
• Covers the full spectrum of commodities within the
Automotive, Aerospace, and
transportation related industries
Petroleum, Natural Gas & Minerals (Houston, TX)
• Covers the full spectrum of commodities within the
Petroleum and related industries as well as minerals
March 2012
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25. What CEE’s will provide
• Centers serve as a single point of processing for
businesses enrolled in CBP’s trusted shipper programs -
Customs-Trade Partnership Against Terrorism (C-TPAT)
and Importer Self Assessment (ISA)
• Centers will increase industry-based knowledge to
segment risk, develop trade facilitation strategies, and
enhance enforcement
• The Centers will also serve as a resource to the broader
trade community and to CBP’s U.S. government partners
March 2012
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26. Proposed Centers
1. Agriculture & Prepared Products
2. Automotive & Aerospace *
3. Base Metals & Machinery
4. Consumer Products & Mass Merchandising
5. Industrial & Manufacturing Materials
6. Electronics*
7. Petroleum, Natural Gas & Minerals*
8. Pharmaceuticals, Health & Chemicals*
9. Textiles, Wearing Apparel & Footwear
March 2012
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27. Benefits of Centers
Action Benefits
• Eliminate unnecessary • Fewer cargo delays
transactional work for • Reduced costs
compliant importers • Greater predictability
• Shift focus at Ports of Entry to • Better use of CBP employees
high-risk shipments
• Stronger CBP to importer
• Provide single point of contact
relationships
for inquiries
• Increased uniformity and
• Develop cross-functional
transparency for trade
expertise
• CBP expertise and learning
abilities will increase with more
specialization
March 2012
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28. Nexus
• Joint program with CBSA
• Goal is to “establish and expand trusted travel
lanes at airports, waterways, and land
crossings”.
• NEXUS card fulfills travel document requirement
of Western Hemisphere Travel Initiative (WHTI)
• Qualify if citizen or permanent resident of US or
Canada residing in either country
• Gives expedited clearance at air, land and
marine modes of travel (additional requirements
for air travel).
March 2012
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29. NEXUS Information
• Toll free information (US or Canada):
1-866-639-8726
www.nexus.gov
or
www.nexus.gc.ca
March 2012
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30. Email Contact
Ronald.may@dhs.gov
March 2012
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