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Last December 14, several experts in the CTPAT program, including the former director and supply chain security specialists, conducted a webinar to discuss virtual validations and the new Minimum Security Criteria, two of the main recent challenges for member companies.

In response to the suspension of physical validations to companies as a result of the Covid-19 pandemic, CTPAT specialists have completed about 1,880 virtual validations between July 2020 and October 2021, with an estimated number of 2,000 virtual validations by the end of 2021. The average time for virtual validations is 4 hours or less for 65% of the companies evaluated, reaching up to 8 hours for the rest. One of the main factors affecting validation time is the preparation and complexity of the supply chain in each company, so this seminar reviewed measures to carry out a successful validation in the shortest possible time.

Although the sanitary contingency continues to affect the performance of physical visits to member companies’ facilities, virtual validations continue to be a fundamental process for companies to demonstrate that their procedures and activities comply with the CTPAT Minimum Safety Criteria. The complete and correct completion of the safety questionnaire, as well as the visual evidence, become the basis for the specialist to corroborate the company’s compliance with the criteria.

Companies that are selected for a virtual validation in 2022 will be notified via a generic email, informing them that the specialist assigned to their account will contact them at a later date to schedule the validation session(s). Once this notification is received, the company will have a period of time to prepare for virtual validation. This preparation is key to ensure that the key members of the organization involved in the supply chain participate and support with their corresponding evidence. Additionally, it is recommended to have a senior management representative at one of the sessions (through a message or short video) to emphasize the comprehensive commitment as a CTPAT member in maintaining security within the supply chain.

A successful virtual validation relies primarily on proper repair and practice, so it is recommended that companies consider the following measures:

– Collect as much evidence of implementation as possible prior to validation (photographs, graphics, videos, forms, etc.) and order it according to the established agenda.

– Designate a leader to be the link between the specialist and the other members of the company.

– Store information through an automated record keeping system or encrypted USB portable storage devices (such as Iron Key).

– Define the virtual conference platform to be used for the session, where each participant will connect through his or her own computer.

– Verify that documentation is available in digital format and easily accessible.

– Have a backup plan in case of a signal problem, slow connection or loss of power during the session.

– Perform a trial validation with the equipment to test functions such as screen sharing, document sending and login.

Companies conducting a virtual validation must be prepared to have a video that serves as a virtual tour of the facilities, including high-risk areas such as the perimeter, entrance and exit booths, loading/unloading area, parking lots, security camera monitoring, etc. This video may also include the use of access tools (key cards, biometrics, badges) to enter restricted areas.

Additionally, the program has recently made important changes to the Minimum Security Criteria, the most notable is the inclusion of three new criteria: Agricultural Security, Cyber Security and Security Vision and Accountability. In addition to this, about 150 changes were made to the security questionnaire in all standards, increasing the mandatory requirements (Must) and decreasing the suggested guidelines (Should).

During the virtual validations, companies must present evidence of compliance with these three new criteria, so it is suggested to corroborate that the necessary updates have been made to the applicable procedures and formats.

According to conversations with CTPAT program officials, first-time validations will remain physical, while follow-up validations will continue to be virtual for the foreseeable future. However, physical visits to companies for first-time validations have not resumed at this time, nor is there an estimated date for them to take place.

Therefore, it is absolutely important that companies pending their follow-up validation have the correct preparation to perform it virtually with their CTPAT specialist.

We invite you to contact TLC Asociados for advice on the CTPAT virtual validation procedure, and to verify that your company complies with the new Minimum Security Criteria.

“In TLC Asociados, we develop a multidisciplinary team of experts in audits and risk analysis for consulting and ensuring compliance with foreign trade operations”.

For further information or comments regarding this article, please contact:

AEO and C-TPAT Certification Division

TLC Asociados S.C.

tlc@tlcasociados.com.mx

A total or partial reproduction is completely prohibited. All rights are reserved to TLC Asociados, S.C. The content of this article is not a consultation; therefore, TLC Asociados S.C., its team and its author do not assume any responsibility for the interpretations or implementations the reader may have.