When it comes to C-TPAT success, the devil is in the details. Not only do importers need to fully address their implemented operational procedures and security measures, but initial application success also begins with a solid underpinning of inter-departmental coordination. After my first two application submissions, many years ago, I decided that a solo approach was just too time consuming and therefore switched gears to implement a Corporate C-TPAT Committee to directly leverage individual expertise and reduce the time to submit the application and implement. What historically took me eight to nine months to navigate now had whittled down to three to four months from project start to acceptance.
The main time saver was the elimination of my misunderstandings, interpretations, and rewrites of the data to address the required question’s subject matter. In that, I divided up each portal section and assigned them to an eight-person team to address in their own words, not mine. For each section, I divvied up the HR, IT, Cybersecurity, Agriculture, Access Controls, Physical Security, and Security/Governance sections to experts in the company. Information coordination and communication are keys as you, being a trade compliance manager, are not especially an expert in HR, IT, or facility engineering, and your committee members are not so adept into CBPs verbiage and expressed meanings relative to supply chain security.
Having weekly or bi-weekly Teams check-ins with your committee enhances objectives and keeps you on-track in meeting critical deadlines. Focus your attention on both managing project expectations and keeping your members grounded as addressing each misunderstanding of the questions’ requirements can be a full-time job. Additionally, what has garnered a speedy approval of my applications in the past stem from uploading relevant and descriptive examples into the portal. Have committee members read each question in their section thoroughly. They need to highlight the exact deliverable within the question and work with them to find applicable examples, whether it be policy, procedure, diagrams, manuals, or pictures.
Once they assemble the reference materials, then write the answer, noting the details of their examples into a cohesive story that hits on all the requirements of the question. I do not favor or suggest answering the question first, to the best of your ability, and uploading un-referenced supporting documents after the fact. This generally introduces gaps in the answer’s logic and creates uncertainty for the SCSS. Lastly, and it seems logical, upload all examples as you finish writing each answer, not sometime down the line. Keeping all examples together in the portal on a running basis is far more efficient than trying to find them later on your computer at the end when you’re ready to submit.
If you practice over communication with your team and in telling accurate and descriptive stories in your responses, the rate of success is almost assured. In the eight C-TPAT implementations I’ve managed over the past 22-years, exercising the above best practices with my committees have yielded, on average, an approval response rate from CBP between 12 to 48 hours without additional rework initiated by the SCSS. Any questions relative to implementing a successful C-TPAT program, feel free to reach out to me.
