LETTERS TO THE EDITOR

LETTERS TO THE EDITOR

Customs has final say on C-TPAT validation

As the new Customs and Border Protection commissioner comes up to speed with the workings of one of the most complex jobs in the U.S. government, I would like to comment on one position he took in The Journal of Commerce article of June 26, that "C-TPAT validation should be the responsibility of the government."

I led the International Standardization Project to develop an industry standard for supply-chain security and can state that the working group - which consists of representatives from the World Customs Organization, national experts from more than 10 nations, supply-chain operators and major maritime industry organizations - strongly agrees.

Within the standard we developed (ISO PAS 28001), we inserted text that not only states that only a customs authority can grant Authorized Economic Operator status, but requires that organizations adopting ISO PAS 28001 make contact with their customs authority and follow its suggestions.

Basically, the industry standard requires entities in the supply chain to clearly describe their scope of operation, assess their security within this scope, address gaps found and document the results. Supply-chain operators who are trying to construct secure supply chains will find it easier to work with entities that already have performed these tasks than with companies that have to start from scratch.

There are also provisions for compliance with the standard for companies to be audited by a third party. It is not required, but companies may make a business decision to seek such an audit. In time, some customs authorities may give certain weight to security work accomplished in meeting the industry standard when an entity applies for Authorized Economic Operator status (C-TPAT is one such program), but there is no question of the authority of Customs as the final say on this issue.

The ISO work does not challenge the role of Customs. Rather, it helps organizations thinking of applying for AEO status to systematically review their security and document the results.

In summary, the ISO standard is a tool that can be leveraged by Customs.

Steven J. O'Malley, PAS 28001 project leader, International Organization for Standardization, and director of maritime security, Science Applications International Corp.