Tuesday, July 10, 2007

Read it Twice, and still can't believe it

Today's Congressional Quarterly Homeland Security newsletter story that DHS is now letting private companies evaluate whether other private companies have strict enough security programs in place with regard to maritime commerce would be funny if it were a joke. But, it isn't a joke.

The "C-TPAT" or "Customs Trade Partnership" Against Terrorism program was already laughable. In exchange for filing paperwork with DHS claiming to have a rigorous security regime in place, shipping companies can reduce dramatically (by some accounts, to zero) their chances of having their cargoes inspected, thereby speeding their flow through the supply chain. Any audits to confirm that firms' security representations are, in fact, true, were done only after the fact, turning Ronald Reagan's sensible "trust, but verify" dictum on its head. The last time I checked, a couple of years ago, only 11% of the companies in the program had been subjected to audits to confirm their representations. And, also by the way, any verification that was done by DHS was not only after the fact, but also limited to whatever features of the program shippers deigned to allow DHS to scrutinize. Loopholes big enough for the Titanic to slip through, you might say.

But, at least, until now, it was DHS that was doing the validation. The notion that, going forward, private companies will be doing the asssements of other private companies, for a fee, is beyond belief. What incentive do private companies have to examine other companies vigorously? Haven't we seen this movie before? Private companies ran airport security before 9/11. The whole point of creating TSA and federalizing screeners was the belated recognition that, left to their own devices, private industry will put profit ahead of security every time.

Will we ever learn?


Anonymous Anonymous said...

You need to brush up on recent C-TPAT history. U.S. Customs has inspected over 60% of C-TPAT members to date and started with companies facing the most risk (container imports). They have removed over a 1000 companies for various non-compliance issues.

My company is currently being audited by U.S. Customs for C-TPAT compliance. The audit is taking over a month with inspectors visiting one of our foreign suppliers and our domestic operations.

They are verifying that we follow the 29 minimum security criteria for importers (there are other criteria for different member classifications). Our Supply Chain Security Profile is kept up to date on Custom's web portal, is reviewed by me and my Custom's rep annually. I, and my company, take supply chain security very seriously.

DHS's use of third party auditors for C-TPAT is a one year pilot program--for locations in China only. As you can imagine, I doubt the Chinese government will allow DHS inspectors into their country to evaluate security. A third party--international inspection company--is probably their only option.

PS. Its impossible to get a 0% inspection rate through C-TPAT.


7:33 AM  

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