For those of us who are partners in the Customs-Trade Partnership Against Terrorism (C-TPAT) program, the prospect of of having our certification suspended or revoked is not a pleasant one. We worked hard at becoming partners, and continue to diligently assure that our companies are living up to our voluntary commitments to the program.
While the actual level of suspension or removal from C-TPAT participation remains quite small - according to an update published by Customs in June 2013, there were 1,633 suspensions (3%) and 1,194 removals (1%) during 2012 - there have been serious and ongoing concerns voiced by the trade community about what is seen to be very prompt action on the part of Customs when a breach is either voluntarily disclosed by the Partner or discovered by Customs.
The United States Customs and Border Protection has released a document outlining the causes of suspending removing partners from the program, and processes of appeal and reinstatement. The publication can be found at: Customs Trade Partnership Against Terrorism.
Customs issued this publication, in part at least, due to serious and ongoing concerns brought to them by the national trucking associations of both Canada and the U.S.including the Canadian Trucking Alliance, and the American Trucking Association during meetings held with the U.S. embassy in Ottawa and the Department of Homeland Security.
In the document, Customs states that preceding such actions as suspension or removal, extensive outreach is conducted, and that ?subsequent to to removing a Partners benefits, additional outreach efforts are conducted to help the Partner address gaps, vulnerabilities, or weaknesses which led to the suspension, removal or ineligibility determination.? It is not Customs to ?arbitrarily suspend or remove a partner from the program [and] make every effort to work with the partner to achieve required levels of compliance
The document addresses the law mandating that Customs impose rigorous oversight of the program, including the suspension or removal of partners who fail to meet program requirements. In order for C-TPAT to achieve success, and to be an effective security tie, the parties must work in partnership, without the fear of removal from the program for minor infractions that are quickly rectified.
In addition to the informative publication linked on the Customs website above, DHS provided the Canadian Trucking Alliance (CTA) with a helpful checklist of questions that a C-TPAT partner should ask themselves. A link to the CTA website with all of the questions can be found here: CTA Briefing Note
While the questions are directed to Carriers, all participants in the program, whether importers, customs broker or other partners, can use this checklist as one more excellent ?tool in the toolbox? to assure that we retain our Partner status in C-TPAT in good standing.
More information related to C-TPAT can be found in: