The Customs Service has developed a validation process to ensure that C-TPAT participants have implemented the security measures outlined in their Security Profile and in any supplemental information provided to Customs. The validation process will be conducted jointly by U.S. Customs personnel and a representative of the industry participant. The validation will focus on the material in the participant’s C-TPAT security profile and any related materials provided by the participant and will be conducted under the guiding partnership principles of C-TPAT.

Objective

    The purpose of the validation is to ensure that the supply chain security measures contained in the C-TPAT participant’s security profile have been implemented and are being followed. In the context of the company’s operations and the C-TPAT security recommendations, the validation team will evaluate the status and effectiveness of key security measures in the participant’s profile and make recommendations where appropriate.  

Validation principles

    The guiding principle of the C-TPAT program is partnership.  The C-TPAT program is voluntary and designed to share information that will protect the supply chain from being compromised by terrorists and terrorist organizations.

    The validation process will enable Customs and the C-TPAT participant to jointly review the participant’s C-TPAT security profile to ensure that security actions in the profile are being effectively executed. Throughout the process there will also be the opportunity to discuss security issues and to share best practices with the ultimate goal of securing the international supply chain.

    C-TPAT validations are not audits. In addition, they will be focused, concise, and will last not longer than 10 work days.

    Based on the participant’s C-TPAT security profile and the recommendations of the validation team, headquarters will also oversee the specific security elements to be validated.

Conducting a validation

    To ensure their accuracy, the security profiles of C-TPAT participants will be validated. The order in which a C-TPAT participant’s profile will be selected for validation will be based on risk management principles. Validations may be initiated based on import volume, security related anomalies, strategic threat posed by geographic regions, or other risk related information. Alternatively, a validation may be performed as a matter of routine program oversight. Customs Headquarters will schedule a company’s first validation within approximately three years of the company becoming a C-TPAT certified participant. Customs field offices will not initiate validations and unannounced validations will not be conducted. C-TPAT participants will be given 30 days advance written notice along with a request for any supporting documentation that is needed.

    A Partnership Validation Team (PVT), consisting of Customs Office of Field Operations personnel and a representative of the C-TPAT participant, will conduct the on-site C-TPAT validation. 

    Customs representatives on a PVT will be officers knowledgeable in supply chain security matters. Customs PVT members will receive supply chain security training to assist them in working with industry representatives to promote effective corporate supply chain security programs. Customs Headquarters will determine the Customs representatives for each PVT. All Customs PVT representatives will be personnel from the Office of Field Operations.

    The Customs Partnership Validation Team Leader (assigned by Customs Headquarters) will be responsible for the team’s reviewing the company’s security profile, other security information provided by the company, and data and information retrievable from other sources to determine the focus of the validation. This will help ensure that the validation is effective and limited in duration.

Validation venue

    A validation is an on-site review of the participant’s C-TPAT supply chain security profile. The actual site of the validation may vary depending on the aspect(s) of the participant’s profile that the C-TPAT Validation Team will review.

    Under normal circumstances the validation will begin with a briefing of company officials at the domestic corporate office or facility of the C-TPAT participant.  If additional data or information is required to validate a portion of a C-TPAT participant’s supply chain domestically or overseas, the PVT leader will request approval of travel through the Director, C-TPAT, at Customs Headquarters.

Validation procedures

    Upon receiving direction from headquarters, Customs PVT leader will provide the company with a written notification of the scheduled validation. The notice will be issued at least 30 days prior to the start of the validation and will include a request for supporting documentation or materials, if any. The PVT leader will also contact the C-TPAT participant to establish a single point of contact at the corporate level.

    Each validation will be customized for the participant involved and focused on the company’s C-TPAT security profile.  Prior to the on-site validation, the Customs representatives on the PVT will review the participant’s C-TPAT security profile, any supplemental information received from the company, and any Customs Headquarters instructions, to determine the extent and focus of the validation. 

    In preparation for the on-site validation, the validation team may also consider pertinent C-TPAT security recommendations. These security recommendations are a reference tool for considering the sufficiency of specific aspects of a participant’s C-TPAT security profile. It is understood that the recommendations are not mandatory and are not all-inclusive with respect to effective security practices.

    As noted earlier, to begin the validation, the PVT will meet with company officials to discuss the process.  Upon completion of the validation, the PVT will again convene with company officers to discuss validation findings.  Although not a part of the PVT, the company’s Customs account manager will normally attend the company briefings that initiate and complete the validation process.

Validation report

    Validation findings will be documented, included in the team’s final report, and forwarded to the director of C-TPAT for final editing and sharing with the C-TPAT participant.  Ideally the report will affirm or increase the level of benefits provided to the participant.  However, depending on the findings, some or all of the participant’s C-TPAT benefits may be deferred until corrective action is taken to address identified vulnerabilities.  With respect to actions resulting from a validation, Customs authority will rest with the executive director, Border Security and Facilitation.