For participants of the Customs Trade Partnership Against Terrorism (CTPAT) security program, a validation meeting with U.S. Customs & Border Protection (CBP) can feel daunting. But with a proactive approach and ample preparation, it doesn’t have to be.
What is a validation meeting?
Validation meetings are an opportunity for CBP’s Supply Chain Security Specialists (SCSS) to confirm their assigned member companies are following the established security procedures and adhering to the Minimum Security Criteria for CTPAT. The SCSS will select both a domestic and foreign location to conduct this review process, and both meetings generally take place within a couple of months of one another.
As always, CTPAT is a flexible program that can be adapted based on a company’s size, supply chain, and other relevant factors. Because of this, CTPAT members should approach the validation meeting as a collaborative process. It is an opportunity to ask questions directly to the assigned SCSS, identify improvements, and discuss ways to implement best practices, where possible.
Be prepared for your notification from CBP
As stated on CBP’s website, CBP will provide written notification of the validation at least 30 days in advance of the scheduled date. However, an upcoming validation should not be a surprise. CTPAT participants can expect a validation every three to four years on average, and the CTPAT web portal lists the next expected validation year for each participant. If your company participates in CTPAT, the best way to prepare is to keep your program up to date throughout the entire year.
Simple steps to make the most of the validation process
Since CTPAT is a voluntary program, validations are meant to be a cooperative meeting, not an “audit.” But lack of preparation for a validation meeting can cause additional and unnecessary work overall. To help avoid unreadiness, these tips can help your company get organized and ready:
Meet with your cross-departmental CTPAT committee without delay
Once you receive notification of your validation date, meet with your CTPAT committee as soon as possible. This is not a “one-man-show” whereby your company’s CTPAT point of contact does all the talking; rather, relevant stakeholders and process owners should also be prepared to participate in the discussion with CBP.
Follow the standard agenda provided by CBP but ask for adjustments if necessary
If the proposed order of topics does not work best for your company attendees or you simply feel another order makes the most sense to present your CTPAT program, explain that in advance of the meeting. Your SCSS is likely to agree with your request.
Provide the SCSS with an overview of your supply chain
The CTPAT program has never been a “one size fits all” program, and your SCSS is likely conducting multiple validations in the same week. Remind CBP of what might be unique about your specific supply chain.
Focus on evidence of implementation
The point of the validation is to demonstrate how your company has implemented each process and procedure. Be prepared with evidence in the form of completed security audits, checklists, photographs, example forms, etc.
Clearly state your best practices
These procedures can be within your company and more specifically, your security program.
Consider using a presentation
The use of a presentation can help keep the discussion moving forward. No matter the format, an organized approach is the best way to ensure efficiency during the meeting.
Run a practice rehearsal with all participants, if needed
This includes a facility of the tour if the validation meeting will occur in person.
Ask for feedback at the conclusion of the meeting
Though CBP will provide a formal validation report within a couple of months after the meeting, you should leave the meeting with a solid idea regarding your program’s strengths and any perceived weaknesses.
Consider a third-party perspective, if needed
Even a well-established CTPAT program can benefit from a fresh set of eyes. Consider utilizing a consultant or other CTPAT expert to review your security program. This could include a comprehensive review of the entire security profile and supporting documentation, assistance preparing for domestic and/or foreign validation meetings with CBP, or simply a review of the content that you plan to present to CBP during the validation meeting.
If your company requires assistance with CTPAT, connect with one of our team members. The trade policy team at C.H. Robinson offers customizable CTPAT solutions that can make a real impact for your security programs.
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