COAC Working Group for CBP Centers Urges Better Communication

A subgroup of the Commercial Customs Operations Advisory Committee Secure Trade Lanes Subcommittee laid out eight recommendations for how to beef up communications among CBP's Centers of Excellence and Expertise, brokers and other trade entities amid growing pressures at CBP to be vigilant over forced labor, antidumping and other threats.

The Structure Sub-Group, one of three subgroups of the subcommittee's Centers Working Group, according to COAC's agenda for the Sept. 18 meeting, says these recommendations are meant to enhance trade facilitation and allow CBP to effectively address current risks and priorities. The recommendations are meant to facilitate better communication among Customs Trade Partnership Against Terrorism trade members, companies that are in the Customs Trade Partnership Against Terrorism but not C-TPAT Trade Compliance, smaller importers, CBP, and partnering government agencies.

The first recommendation is for CBP to explore and develop methods for creating Center-based communities that would allow for more frequent and robust communications between Center staff, Center members, brokers and other trade entities to help facilitate trade, enhance compliance, and create processing efficiencies, the sub-group said at Wednesday's meeting.

The second recommendation calls for CBP to leverage technology and develop a public messaging system that can be used by the Centers to push out communications directed to center members. For instance, specific CSMS messages or other messages that needed to be delivered for a particular good or commodity such as base metals or aluminum extrusions could be directed to those members of that Center, so that they would really be getting information relevant to the commodities that they're importing, the sub-group said at the meeting.

The third recommendation calls for CBP to explore and develop methods for enhancing connectivity and communication between the many parties involved in center operations, including internal CBP organizations at the ports and the Office of Trade and external stakeholders such as partner government agencies.

For all these recommendations to happen, the subgroup offered its fourth recommendation, which is for Congress and the White House to increase funding specifically for the hiring and continuing education of new and existing center personnel. This includes import entry drawback specialists and the administrative personnel so that they may be able to better handle the significant increases in workflow, volume, complexity and enforcement priorities, the sub-group said.

"The number of specialists has remained relatively static since the creation of the Department of Homeland Security in 2003. That's 20 years," a subgroup representative said at the meeting. "The customs personnel at the centers have so much on their plate, it would help both them and the trade to increase their numbers and ensure they're getting the continuing education that they need."

The fifth recommendation is for CBP to rebalance the workloads and staffing at the different centers for the purposes of adapting to these new current priorities and risks. This would include an evaluation looking at the geographical footprint of the centers.

The sixth recommendation is to institute regular evaluations of Center workloads and staffing "to ensure resources are properly balanced to meet these ever-changing priorities and risks," according to the submitted recommendations report. "A system of regular evaluations will help enhance the quality of the customer experience, maintain needed levels of trade facilitation, and streamline Center efficiencies."

The seventh recommendation is to evaluate whether there are a sufficient number of centers and whether the commodity lines encompassed by specific centers may be too weighty for a single center to oversee, or conversely too narrow to justify the organizational unit.

And the eighth recommendation is for CBP to assess the organizational and funding structures of the centers, like workload and staffing allocations. Organization and funding should be evaluated to ensure that the Centers are properly aligned to maintain the level of customer experience and trade facilitation needed to ensure the economic security of the country while guaranteeing that the Centers can fulfill their mission.