This sort of intrigue and adventure is common for a team of three Customs and Border Protection supply chain specialists during a validation inspection of several shippers in the Lahore, Pakistan area. The validation was part of the Customs-Trade Partnership Against Terrorism program launched in November 2001. The partnerships are between CBP and the trade community to implement security standards and safe practices that better protect the entire supply chain against exploitation by terrorists, from foreign loading docks to our ports of entry. In exchange, companies that meet CBP security standards get expedited treatment when crossing our borders.

For 10 days, the team worked under tight security inspecting six facilities in Lahore. The inspection, based on a validation checklist, covers all components of the program. The team looks at the physical security of the shipper’s facility— the gating, lighting and facility access controls. In these areas, the Pakistani companies look good. Personnel security practices are also scrutinized. Specialists determine the scope of background investigations performed on key personnel in critical areas like finance and security. For this validation blitz, the answers are good ones. All security personnel are former military and have had comprehensive suitability investigations completed.

Questioning security practices
Infiltrating an information technology system is one tool a would-be terrorist or smuggler could use, so computer and communication security practices are assessed. Answers are sought to questions like: Do employees establish sufficiently complex passwords and keep them secure? Are audit trails maintained that record system activity by application processes and by user activity? Is there intrusion detection capability? As might be expected, lesser-developed countries frequently need improvements in this area of technology.

Step by step, each phase of the process is systematically examined and procedures are analyzed to make sure that adequate controls are in place. Shippers should examine containers before loading or “stuffing” to make sure they are empty and free of false compartments. Check. Once loaded there should be procedures to keep the container and its contents safe in transit. Check.

However, not every site has adequate practices. Todd Owen, acting executive director for cargo and security conveyance for CBP gives an example. “One company allows drivers to take their truck and trailer home for the night or weekend and then take it to the dock. Obviously, this is not a good practice, as control and oversight over the load is lost for a block of time.”

Membership in the anti-terrorism partnership has grown from seven at the program inception to more than 10,000 members. But, the customs-trade partnership is expanding in other areas, specifically in validating the security of the supply chain of members. During the first 2-1/2 years of operations, teams conducted 400 validations compared to the more than 1,000 conducted in the last year.

Traveling the world to validate CBP's trade anti-terror program is no vacation. Sometimes security is so tight, all you get to see out your window is a police escort.

Trust but verify
In order to join the partnership a company has to meet all of the defined security criteria for their industry whether it is an importer, manufacturer, carrier or freight forwarder. Using a “trust but verify” philosophy, CBP has established a cadre of supply chain specialists that has more than doubled during the last year to a current level of 88 with an increase to 156 before the end of fiscal year 2006. This staff increase will for more validation inspections of members’ security procedures.

Two-or three-person teams conduct validation inspections on-site to ensure that member operations pass muster. Supply chain specialists have backgrounds that represent the specific operational environments that they will inspect: seaport, airport or land border. The teams use industry specific validation checklists as a basis for the inspections that typically last one to two weeks.

Supply chain security is much like chain of custody for evidence. As a shipment changes hands or is transported from one place to another, controls to ensure the integrity of the shipment must be in place. Inspections result in a validation report that provides a brief history of the company and details findings including deficiencies and “best practices.” Owen explains that the validations do more than just confirm compliance, “As more and more validations take place, not only is confidence in the efficacy of C-TPAT growing, but we are developing models of best practices and what works best and efficiently in securing the supply chain.”

Targeting risk
Locations for the inspections are selected based on risk assessments, with supply networks with the highest risk of terrorist infiltration being validated first. This explains how a team ended up in Pakistan and in other areas that carry formal State Department warnings to travelers or advisories to maintain a high level of security awareness.

Validation teams may go to Miami, but they also assume risk in foreign locales in order to ensure the safety of our borders. This year validation inspections were conducted for the first time in Sri-Lanka, Oman, Turkey, Russia and Indonesia—Cambodia is on this year’s schedule.

Validations will continue and increase as the partnership program moves into Phase II. The new guidelines formalize what were recommendations of security measures into requirements. Importers are asked to do everything they can to ensure that their foreign business partners develop and document supply-chain security measures that are consistent with the partnerships anti-terror requirements. What importers will receive in return for adherence to these new rigorous standards is still not concrete. But there are definite benefits.

According to Owen, “Non-C-TPAT importers have their shipments stopped by CBP for enforcement examinations six times more often than C-TPAT importers, and four times more often for trade-compliance issues. That's measurable. That has a large financial impact on these companies. It allows them to be more productive with the timeliness issues."

During foreign validations, simple things can become surprisingly complex. Take a toothache. During the Pakistan inspection one of the team members had a dental problem. This meant finding a dentist recommended by the State Department, but it entailed much more. Before the dentist could see the team member, he had to clear his office of patients and armed guards did a reconnaissance of the premises. The dentist, an expatriate from New York, performed his work while armed guards stood by. LK