Of all the major program changes we’ve seen in the last year, new CTPAT Agricultural Security requirements continue to throw supply chain professionals for a loop. So what exactly are the rules, and how do you go about following them? In this article we answer your top eight most frequently asked questions about Agricultural Security for CTPAT to help your organization stay fully compliant with CBP protocol.
1) WHY DOES THE AGRICULTURAL SECURITY CTPAT REQUIREMENT EXIST?
Every year, there are billions of pounds of products entering the U.S., including millions of pounds of agricultural products. In order to prevent the introduction of harmful plants, pests, animal disease, and invasive species, a new agricultural inspection component has been added to the CTPAT container loading process. The agricultural inspection standards are necessary to ensure structures don’t harbor organic contraband or haven’t been contaminated with agricultural pests.
2) WHAT DOES CBP MEAN BY “PEST CONTAMINATION?”
U.S. Customs officially defines pest contamination as “visible forms of animals, insects, or other invertebrates (alive or dead, in any lifecycle stage, including egg casings or rafts), or any organic material of animal origin (including blood, bones, hair, flesh, secretions, excretions); viable or non-viable plants or plant products (including fruit, seeds, leaves, twigs, roots, bark); or other organic material, including fungi; or soil, or water.”
So there you have it! (And, for those of you feeling a little sick to your stomachs after reading that explanation, you’re not alone…it makes us a bit queasy too)
3) WHAT TYPES OF CARGO REQUIRE INSPECTION?
Pest inspections are mandatory for all forms of international travel and transport. This includes ocean containers, refrigerated containers and trailers, over-the-road trailers, flatbed trailers, tank containers, rail and boxcars, hoppers, and unit load devices (ULDs). Overseas supply chain expectations are that this inspection takes place at the point of cargo packing.
4) HOW DO I PERFORM AN AGRICULTURAL INSPECTION?
If you stuff or load containers, your team is required to execute agricultural inspections for every container. Here is a summary of what you need to do to meet the Minimum Security Requirement for Container Load:
- A 7-Point Inspection must be conducted on all empty containers and unit load devices (ULDs) including a check for pests.
- An 8-Point Inspection must be conducted on all empty refrigerated containers and ULDs. In particular, you must check all vents, fans, and refrigeration units for pests.
- A 17-Point Inspection is required for trailers upon stuffing, which includes a pest check.
- An 18-Point inspection is required for refrigerated trailers. This means that, once again, you must do a deep-dive check of all vents, fans, and refrigeration units for hideaway pests.
The 7-Point / 8-Point and 17-Point / 18-Point Inspections have very specific requirements. The most important of which is if you see any evidence of infestation in the container or the agriculture itself during an inspection (i.e. bugs, animals, mold, or really any other potential environmental contaminants), you must halt the loading or movement of the container and alert your supervisor, along with the proper authorities.
After you sound the metaphorical pest alarm, there is a chance you may be able to salvage at least a portion of the cargo by sanitizing the container and transferring any unaffected cargo to another one. In the event that you do run into a serious contamination issue, remember you can always get CBP involved by calling 1-800-BE-ALERT.
5) WHAT ABOUT AGRICULTURAL SECURITY FOR WOOD?
There are also new CTPAT agricultural security requirements for WPM (Wood Packing Material. Under MSC guidelines, only ISPM15 (International Standard for Phytosanitary Measures) approved WPM is permitted in containers traveling across the border. This means that all wooden shipping materials must also meet the requirements, including (but not limited to): crates, pallets, boxes, and any other wood being used to support or brace cargo.
To put this rule simply, if you’re traveling with wood in a container, each and every piece must meet ISPM15 standards. Period.
6) HOW DO I KNOW IF MY WOOD IS ISPM15 CERTIFIED?
To figure out if the wood in your container is compliant with CBP protocol, check for a stamp (either ink or burned / branded) that looks like the image below:
There can be some variation in the ISPM15 seal, but many elements must be exactly as shown. Here’s a quick breakdown to help tell if the stamp is legitimate, using the example above as a reference:
- There must be a rectangular border surrounding all letters, numbers, and markings. However, the exterior border can be either solid or dashed / broken.
- The left-hand box must include the symbol pictured above, along “IPPC” written vertically to the right of the image.
- The “XX” field represents a country code. This must always be made up of two letters.
- The “0000” field represents the unique identifier for the way the wood was treated. This part can vary in length and may include a mix of letters and numerical digits.
- The “XX” and “0000” fields must always be separated by a hyphen.
- The “YY” field represents the type of treatment used on the wood. This will always be either “HT” (Heat Treatment) or “MB” (Methyl Bromide).
IMPORTANT NOTE: Firewood should never be transported unless you have a special license permitting you to do so. If you do have a license, remember that the only type of firewood approved for transport across state lines is specially heated to kill pests and sealed with a governmental stamp.
7) WHY DO CTPAT AGRICULTURAL SECURITY REQUIREMENTS EXIST?
Because this new agricultural policy is such a critical issue, Customs and Border Protection doesn’t solely rely on CTPAT Members to manage all the elements. CBP also helps by conducting random inspections at the port of entry for agricultural cargo. Currently, these searches are conducted in the form of a visual spot-check that includes looking for dirt, bugs, organic material, and soil. However, the future inspection technique will involve canine units and specialized X-Ray machines designed to detect organic material.
Ultimately, the goal of these requirements is to get CTPAT members and CBP working together to help better protect U.S. farmlands, forests, and lakes – all of which have a direct impact on the economy, environment, and health of United States residents. (Thanks for doing your part!)
8) WHERE CAN I GET HELP WITH AGRICULTURAL SECURITY COMPLIANCE?
We hope this information helps you better understand and comply with new CTPAT Agricultural Security regulations. However, if you find yourself in need of a more detailed understanding of this or any other CTPAT requirement, Veroot has you covered. Simply fill out a form on the Veroot C