Eventual Integration of Other Agencies in ISF Seems Likely, Though Difficult, Says DiNucci

The eventual addition of other government agency (OGAs) data within the Importer Security Filing program is a realistic possibility, but much would be required before that happens, said Rich DiNucci, acting assistant commissioner for the CBP Office of Field Operations. DiNucci, who spoke Nov. 6 at a Coalition of New England Companies for Trade (CONECT) event, said while OGA involvement seems to be the direction the program is headed, there's still some big impediments in the way. DiNucci said he expects the government to someday look at how "you combine these data sets so you can use them cross-agency," but that's "going to be a long, long discussion."

Despite early concern about providing CBP the early data, the program has matured in recent years, he said. "I think over time, now, as the trade has gotten to the point that they know the data is accurate and the compliance rates are pretty good," so they are now wondering why not use ISF for other purposes, he said "The conversation has progressed the last five to six years" and it's a conversation that should be had, he said.

At the same time, some agencies may have certain statutory requirements that would make eliminating similar programs difficult, said DiNucci. For instance, the Food and Drug Administration's prior notices are required under the Bioterrorism Act of 2002, he said. As a result, trying to substitute transmission of ISF information for prior notices would likely be complicated, said DiNucci.

The Trusted Trader pilot that combines the Customs-Trade Partnership Against Terrorism with the Importer Self-Assessment program will "drive the promise of C-TPAT" by opening up a new world of benefits, said DiNucci. CBP recently selected the nine volunteers to participate in the pilot (see 14101019). DiNucci noted that another agency, in addition to the FDA and Consumer Product Safety Commission, recently inquired about joining the program. While he didn't specify the agency, he noted it was his "good partner during sequestration," perhaps sarcastically referring to the Environmental Protection Agency, which had some trade processing problems during the congressional budget fight last year (see 13110715). It seems that the other executive agencies are coming to understand where the programs are headed, he said.