Cargo Exams
Tradewatch 2011
Steve Pasienski
Background
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Joint Automotive Associations Study
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Goal: Minimize Supply Chain Disruptions
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Study exam process
Identify best practices
Identify opportunities to improve process
Time Line
Study
Initiated
Sept. 2009
Initial
Visits
May & July
2010
Meeting
with
CBP HQ
Aug. 2010
Port
Visits with
CBP HQ
Follow-up
Meeting with
CBP HQ
Nov 2010
Feb 14 2011
Issues to address
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Length of time for VACIS “X-Ray” exams
System limitations, manual processes
Additional costs for unnecessary VACIS exams
Terminals have no visibility C-TPAT status
Inconsistencies among ports
Paper documents Vs Electronic
Turn around time at CES
Initial Visits
Finding:
Vessel discharge can take up to 3
days. CBP compliance target is
scanning exam containers within 48
hour of vessel departure.
Issue:
If target is not met containers can be
held up to 5 days or longer before
VACIS is completed.
Recommendation: Establish best practice of scanning
containers within 48 hours of discharge
from vessel.
Initial Visits
Finding:
Some terminals discharge exam
flagged containers onto wheels, while
non-flagged get stacked.
Issue:
If exam is flagged after discharge,
terminal needs to “dig” container out
of the stack.
Recommendation: Establish best practice of identifying
C-TPAT containers for a compliance
exam 24 hours prior to vessel arrival.
Initial Visits
Finding:
CBP “7H” code was designed for
enforcement holds but it is also used
for compliance holds in AMS.
Issue:
CBP policy requires all containers to
be scanned (VACIS) at the terminal
when a 7H code is in system.
Recommendation: Differentiate between compliance and
enforcement holds in messaging.
Initial
Visits
Finding:
Terminals do not have visibility to
importer’s C-TPAT status
Issue:
Limits Terminal’s ability to be proactive
in staging containers for VACIS and
delivery to CES.
Recommendation: Notify terminals when C-TPAT
containers are up for exam. Establish
best practice timeframe of 24 hours to
complete VACIS after discharge.
Initial
Visits
Finding:
CBP generally notifies terminals that it
has completed VACIS by electronic
message before the end of the shift.
Issue:
Sometimes notification takes place the
following day.
Recommendation: Establish best practice of notification
before end of shift and where possible,
encourage immediate notification by
mobile device.
Initial
Visits
Finding:
Exam site does not know C-TPAT
status for containers unless advised.
Issue:
Exam site cannot prioritize staging of
freight for CBP.
Recommendation: Reinforce the importance of front-ofline status for C-TPAT freight.
November 2010 Visits
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CBP HQ Staff arranged and attended
these port visits.
Learned process from CBP perspective
at each port.
Feb 14th Meeting with CBP HQ
Focus:
1.
Use of 7H Code
2.
C-TPAT Front-of-Line Privileges
3.
Partial Release
4.
CBP/Industry Working Group
Feb 14th Meeting with CBP HQ
Focus: Use of 7H code
Result: CBP HQ will reissue guidance for using
“Public Remarks” field in AMS.
OFO is requiring additional functionality to
deploy holds at the container level.
ACE M1 deployment scheduled for end of 2011
Feb 14th Meeting with CBP HQ
Focus: C-TPAT Front-of-Line privileges
Result: CBP HQ will reissue guidance on
use of “Public remarks” field:
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C-TPAT status first
Then container number to be examined
Feb 14th Meeting with CBP HQ
Focus: Partial Release
Result: CBP committed to investigate
system limitations involved with
implementing partial release.
Also need to investigate other
government agencies issue.
Feb 14th Meeting with CBP HQ
Focus: CBP/Industry Working Group
Result: CBP committed to meet every 6
months to discuss progress.
Next meeting will be sometime
this summer.