COMMENTARY 
AVOIDING TROUBLE 
IN A C-TPAT VALIDATION 

 
By Ronald Jaspan 

MEMBERS OF THE Customs-Trade 
Partnership Against Terrorism 
beware: Validation or revalidation 
requirements have changed signifi cantly 
since you were initially or last 
certified in the voluntary program. 

Many companies, saying they 
were prepared for that initial or at 
least most recent validation, are 
surprised to be receiving “Actions 
Required/Recommendations” notices 
from Customs. Worse, some have 
been suspended from the program 
because they weren’t able to demonstrate 
to their U.S. Customs Supply 
Chain Security Specialist, known as 
an SCSS, that their company is meeting 
minimum security requirements. 

C-TPAT members might ask, 
“What are all these written procedures? 
How do we monitor the supply 
chain business partner’s Status Verifi cation 
Interface number (or SVI, the 
number Customs issues a company 
when it becomes a C-TPAT member)? 
What is an internal/external audit, 
a threat awareness program, the 
five-step risk assessment or annual 
security profile review? These questions 
and requirements were not 
posed during my last visit.” 

The problem for many C-TPAT 
members is linked squarely to the 
2008-09 recession. Workers were 
laid off in droves or, at best, hiring was 
suspended. Members of a company’s 
original C-TPAT validation team now 
may hold multiple positions or are no 
longer employed at the company. The 
diminution in manpower directly 
impacts a company’s ability to maintain 
the C-TPAT program since initial 
certification or a validation/revalidation 
visit by the SCSS. 

The SCSS requires C-TPAT 
members to create written procedures 
adhering to the adage of “here 
today, gone tomorrow or sooner.” The 
C-TPAT member should assume the 
same written procedures might not be 

implemented by the same employee 
every day or even every hour. 

The C-TPAT member’s objective 
is to score as close to 100 percent 
as possible during the validation 
visit. Any “Recommendations and/ 
or Actions Required” notices the 
C-TPAT member receives as a result 
of the validation/revalidation phase 
will become the starting point by the 
SCSS at the next validation. 

Customs through the SAFE Port 
Act mandates that a C-TPAT participant 
undergo a validation by an 
SCSS within one year of becoming 
C-TPAT-certified. That validation will 
consist of the SCSS visiting the company’s 
domestic office and warehouse 
(importer’s or third-party warehouse) 
and one foreign shipper, where cargo 
is manufactured or distributed, and 
a consolidation facility, if required. 
The foreign trucking company will 
be visited directly or be required to 
be present at the foreign shipper or 
foreign consolidator meeting. 

The validated C-TPAT member 
will undergo a revalidation visit 
within three years of the last validation 
or sooner based on cause or 
incident. The SCSS will contact the 
C-TPAT member and advise of the 
various possible methods of revalidation: 
Visit the domestic facility 
and/or, another company facility, 
conduct a conference call or send 
out a questionnaire to determine 
if the company is meeting the 
minimum security requirements. 
For the foreign segment, the SCSS 
will visit a foreign shipper and 
consolidator, if required, plus the 
respective trucker. 

It’s important that the foreign 
shipper, consolidator and trucker 
be prepared for the C-TPAT validation/
revalidation visit. If the above 
parties aren’t able to demonstrate 
to the C-TPAT member’s SCSS that 
they are meeting the minimum 

security requirements, the C-TPAT 
member may be suspended from the 
program, even if it demonstrated 
compliance on the domestic side. 

In preparing for the validation 
phase, consider the following tips: 

¦ Create a supply chain flow 
chart to determine your company’s 
exposure to risk, starting with the 
shipper (foreign) and ending with 
the importer of record and the 
domestic consignee, regardless of 
who is responsible for contracting 
the business supply chain partner. 
¦ 
Review your security profile to 
ensure it’s compliant with Customs’ 
current requirements. (The requirements 
may have changed and/or 
become more stringent since the security 
profile was initially submitted.) 
¦ 
Review, update and create written 
procedures to implement correct 
requirements within your company. 
¦ Verify the security survey 
questionnaires have been sent and 
completed by the supply chain 
business partner and, in particular, 
by the companies that will be 
reviewed/audited by the SCSS during 
the validation phase. 
¦ 
Thoroughly review the security 
survey questionnaires to ascertain if 
the supply chain business partner 
is meeting the minimum security 
requirements and if the written 
procedures exist and are being implemented. 
If not, communicate with 
your partner and develop written 
procedures. 
Thorough preparation for a validation 
visit by a SCSS is a requirement, 
and not optional, to maintain C-TPAT 
membership and to continue to receive 
the benefits that were the driving force 
behind joining the program. JOC 

Ronald Jaspan is president of Norman 
Jaspan Associates, a New York-based 
management consulting firm. Contact him at 
ronald@normanjaspanassociates.com. 

50 
THE JOURNAL OF COMMERCE www.joc.com MAY 9.2011