WB Skinner, Inc. proudly participates in the Customs Trade Partnership Against Terrorism (CTPAT) program, since its inception in 2016 and has been validated by CTPAT for 2020. This means that after careful review of our supply chain, our Supply Chain Security Specialist (“SCSS”) has determined that we meet CTPAT’s minimum-security requirements. Part of this review consists of our SCSS reviewing the status of the custom entries for the Importer of Record (“IOR”).
One of the CTPAT requirements is that we must notify our SCSS if any of our clients have had their cargo seized, regardless of CTPAT membership.
Even though U.S. Customs can independently identify this, they want the Customs Broker to educate the IOR on (a) the critical importance of having security procedures to minimize the possibility of an incident, and (b) how to investigate an incident (with their business partners in their supply chain).
Some of these protocols include having procedures in place at the point of stuffing and inspection, properly sealing (ISO seals), maintaining the integrity of the shipping containers and trailers, as well as prevention of Forced Labor and having international standards in place for Wood Packaging materials “WPM,” etc.
We have seen that failure to have these procedures can be detected during a targeted or random inspection and thus result in seizures, delays, confiscations, heavy penalties and CBP targeting future shipments, as well as penalties to the shipper.
After reviewing the links below, if you would like further information about this or any phase of the CTPAT program, (including the 2020 CTPAT annual review), please contact my CTPAT consultant, Mr. Ronald Jaspan, President of Norman Jaspan Associates, Inc. (“NJA”) at Ronaldj@njai.us or 917-699-9542. Please reference your correspondence to NJA, with the code of “SKINNER2021” for special pricing.
Bill Skinner, President
- ISO Seals & VVTT Seal Verification Process: http://www.cbp.gov/sites/default/files/documents/Bulletin%20-%20April%202014%20-%20ISO%2017712%20High%20Security%20Seals.pdf
- Container/IIT/ Container Seal Inspection: Inspection: During the 7/8-point inspection, the inspector must also inspect the door, handles, rods, hasps, rivets, brackets, container locking mechanism to detect tampering & inconsistencies prior to attaching seal as well as conduct an agricultural check. Visually inspect the outside and inside for visible contaminants such as plants, seeds, insects, egg masses, snails, animals, animal droppings and soil. Wash or vacuum the area to remove all contamination. If the container/IIT (International Instrument of Transportation) cannot be cleaned, please request a new container or vessel. See #14,15,16 &17 for different types of Pest Inspections depending on where the IIT is originating from:
- CTPATs-TBML-(Trade Based Money Laundering)-Warning Indicators: https://www.normanjaspanassociates.com/wp-content/uploads/2020/06/CTPATs-TBML-Warning-Indicators-July-25-2018.pdf
- Internal Conspiracies: https://www.normanjaspanassociates.com/wp-content/uploads/2020/06/Internal-Conspiracies-ENG.pdf
- Suspicious Mail & Packages: https://about.usps.com/publications/pub166/pub166_v04_revision_112019_tech_015.htm
- Forced Labor “FL”- (Even though this section is NOT a requirement, please note that CBP detain, seizing goods, withholding release orders and imposing significant fines can result from importing product which has been produced with forced labor such as prison labor, etc.).Is a documented social compliance program in place that, at a minimum, addresses how the company ensures goods imported into the United States were not mined, produced or manufactured, wholly or in part, with prohibited forms of labor, e.g., forced, imprisoned, indentured, or indentured child labor?
- Wood Packaging Material “WPM”-Pallets/Dunnage: All Imports (with certain exceptions), which includes wooden dunnage and pallets, will be denied entry if their wood packaging material does not conform to the IPPC guidelines and marking requirements.