PIP-C-TPAT Harmonization Challenges

(CBSA-IE Canada)

CBSA’s Director, Program Division Writes to I.E.Canada…

Following is an extract from CBSA Program Director Claude St.Denis’ recent letter to I.E.Canada president Mary Anderson regarding the current problems implementing a seamless interface between the C-TPAT and PIP security programs:

We understand that industry’s original expectations were that mutual recognition would mean that a company would be able to apply to one and receive membership in both. We believe that this concept between Canada and the U.S. makes sense. Mutual recognition was, however, accomplished with the U.S. in accordance with the World Customs Organization’s SAFE Framework of Standards and the Authorized Economic Operator concept, and how the U.S.’s C-TPAT program wanted to proceed. Under this concept, programs that have reached mutual recognition remain separate and companies must continue to apply for membership into each separate program. Essentially, mutual recognition assures that both countries have similar minimum security requirements, similar site validations practices, and offer similar benefits.

That being said, we have a very strong working relationship with the U.S. Customs and Border Protection (CBP) and its Customs and Trade Partnership against Terrorist (C-TPAT) program. Consultations are ongoing to streamline and standardize the two programs. For example, PIP and C-TPAT are working together to develop a unified site validation report. This will provide a strong foundation upon which to harmonize C-TPAT and PIP.

As mentioned... a critical component of harmonization is the development and implementation of a web portal. To this end, the PIP program recently developed a high level business requirements document leveraging C-TPAT’s web portal requirements. All options were considered, including using C-TPAT’s web portal, and it was determined through this analysis that PIP would be required to develop its own web portal. The PIP program is currently seeking funding for the web portal. Once funding is allocated, industry will be consulted on the design of the portal. At this time, and given that we are seeking funding, we are unable to provide specifics in terms of strategies and timeframes surrounding harmonization.

We have taken note of your recommendation that we immediately harmonize the PIP/C-TPAT application forms. Our automated solution and application processing is dependant on our current application form format. Modifying it would require significant changes to our recently developed system for the PIP program’s modernization. Given the investment required to make these changes, and that harmonization with C-TPAT is potentially on the horizon, and the risks associated with system changes, the CBSA has deemed it preferable at this time to wait until we can build a web portal to develop a unified application. Furthermore, the current PIP/C-TPAT applications, although different in structure, have significant similarities.

Read the complete letter here (PDF).