CBP Working Through Backlog of Remote CTPAT Validations, Garza Says

CBP will focus on getting through a backlog of Customs-Trade Partnership Against Terrorism revalidations that it had been originally scheduled to perform in 2020 as it lays out its work plan for validations in 2021, said Manual Garza, CTPAT director at CBP’s Office of Field Operations, on a call with members of the National Customs Brokers and Forwarders Association of America on Feb. 3.

With CBP only able to get through 700 validations in 2020, about 3,400 remain that had been scheduled for that year before the agency’s plans were disrupted by the COVID-19 pandemic. CBP will focus on revalidations of low- and medium-risk CTPAT members as it conducts the remote validations, with high-risk members — such as new applicants that have never been validated — likely not getting validations this year, Garza said.

CBP has been working out the kinks in its remote validations, many related to agency and company firewalls preventing access to video calls on Microsoft Teams. CBP will also use WebEx for the validations, Garza said. Each will be a conversation of about three hours to verify documentation on policies and procedures that each CTPAT member will have already sent to CBP. Companies will be notified by a CBP supply chain specialist before their validations.

The remote validation process has been a positive for CBP when it comes to longtime CTPAT members that the agency already trusts. The virtual process has drastically reduced the amount of logistical planning that goes into CTPAT validations, including scheduling, travel, hotels and rental cars. “This makes it a lot easier because we don’t have to go anymore,” Garza said.

Many of the CTPAT minimum security criteria are “very flexible,” and should present no problem to customs brokers who are now working remotely due to the pandemic. Garza said that in his previous role as a supply chain specialist, long before COVID-19 pandemic mitigation measures, he personally validated CTPAT members from their own homes when that was their place of business. Homes have locks on their doors, and home computers have cybersecurity protections, he said. Supply chain specialists will understand the situation, and there “will be workarounds,” Garza said.

Customs brokers will be critical as CBP moves forward with the forced labor component of its CTPAT Trusted Trader program, Garza said. While brokers themselves won’t be subject to any forced labor criteria, they will play a role in educating their clients on the criteria, he said. While the forced labor criteria aren’t requirements today, Garza said they “probably will be a requirement a year from now.”

In response to a question on whether the relatively new CTPAT logo can be used by brokers, Garza said a process is currently in place for certified and validated CTPAT members to apply to use the trademarked logo through the Department of Homeland Security. CBP also has a new logo that “just went into effect this week,” Garza said.

Garza said he himself is on the lookout for use of the logo by unauthorized parties, including consultants that use it on marketing materials. Asked to publicly detail the process for requesting to use the logo, Garza declined, citing the backlog that would be created due to the potential volume of requests and the single staff member tasked with managing the requests. He did say the process can be found by anyone looking for it.