Highlights
– Report finds CBP has granted reduced cargo scrutiny before company security profiles are validated
– CBP continues to increase number of security specialist personnel conducting company validation
– C-TPAT strengthens balance between trade community and cargo security, yet lingering internal inefficiencies threaten national security in the long-term
Launched by Customs and Border Protection (CBP) in 2001, the Customs and Trade Partnership Against Terrorism (C-TPAT) is part of a layered approach to secure the international supply chain against terrorists, smuggling and narcotics. Under C-TPAT, the international trade community including importers, customs brokers, air, sea and land carriers submit a supply chain security profile to CBP. In return, CBP reviews the profile and evaluates if it is in compliance with custom laws and regulations required for the trade sector. If the security profile adequately meets the minimum-security guidelines CBP validates the security profile and grants a reduced likelihood of scrutiny of the firm’s cargo. By the end of 2007, CBP granted C-TPAT certification to 7,948 firms, which accounts for nearly 30 percent of all United States (US) imports.
C-TPAT allows for a steady balance between the flow of traded goods and securing incoming cargo through an international trade partnership against smuggling weapons and dangerous materials. However, an April 2008 report by the Government Accountability Office (GAO), which examined a sample of 25 company reviews by CBP from March 2006 to September 2006, found several challenges and constraints that are effectively limiting the success of the program, and in turn, are leaving the US vulnerable to a potential security breach via terrorist smuggling.
Stopping Short of Validation
The recent GAO report found several problems involving the validation of company security profiles. In some cases, GAO discovered reduced cargo scrutiny might have been awarded before the company implemented additional security improvements requested by the US government. Below are additional faults GAO uncovered that limit the effectiveness of the C-TPAT:
• Security specialists are encouraged to track the progress of a company’s corrective actions, yet CBP does not require its employees to systematically follow up to ensure the requested security practices remain consistent with CBP minimum security criteria. Instead, CBP requires security specialists to check back occasionally to see if a C-TPAT member’s has improved and ensure members conduct an annual self-assessment for their security profiles. However, the specialists are not required to verify and document whether companies implement C-TPAT validation recommendations.
• CBP employees do not typically test the member company’s supply-chain security practices and CBP does not utilize a third party audit, which could provide a more objective approach to a company’s self-assessment evaluation.
• CBP developed a personal PC-based instrument, the Validation Security Assessment Tool (VSAT), to help security specialists ensure validation information is collected correctly and documented. However, the GAO report has found that the VSAT uses a binary format, such as answering questions as “yes/no”. This ultimately limits the tool’s accuracy as security specialists could answer “no” to a question even if the question is “not applicable” or if it is skipped.
Improvements Shown, Challenges Remain
While these internal problems limit the ability of CBP to know whether member security measures are reliable and accurate, the GAO report concluded that the C-TPAT program has shown some progress over the last few years. For example, CBP has deployed a centralized database to facilitate information storage and has expanded C-TPAT staff by 280 percent from 41 specialists in 2005 to 156 in 2007. CBP expects to hire an additional 50 security specialists by the end of 2008.
Securing the flow of goods along the international supply chain that enters the US through 326 airports, seaports, and designated land borders will remain a daunting task for CBP in the long-term. The C-TPAT program highlights the importance in maintaining an effective anti-terrorism partnership with the private sector and international trade community. However, enhanced cargo security will continue to be limited and leave the US vulnerable to illicit smuggling schemes unless the CBP rectifies the inefficient practices found in the 2008 GAO report.
