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U.S. Consumer Product Safety 
Commission 
1 
CPSC Staff Workshop on Electronic Filing of 
Certificates as Included in Proposed Rule on 
Certificates of Compliance 
September 18, 2014 
This presentation was prepared by CPSC staff, has not been reviewed or approved by, 
and may not reflect the views of, the Commission.
For those of you in the room, please mute electronics and phones. 
For those of you watching on the web, you can email questions for the speakers to: 
efiling@cpsc.gov. 
The transcript for today’s workshop will be added to the docket at: 
www.regulations.gov Docket number: CPSC–2013–0017 
The PowerPoint presentations will also be available at: 
http://www.slideshare.net/USCPSC
John Blachère 
This presentation has not been reviewed or approved 
by the Commission and may not reflect its views 
9/19/2014 3
Presentation Acronyms 
 HTSUS – Harmonized Tariff Schedule specific to the 
United States 
 ITDS – International Trade Data System 
 CBP – U.S. Customs and Border Protection 
9/19/2014 4
Certificates – Current 
 CPSA section 17(a)(2) - requires the 
Commission to refuse admission for 
regulated products not accompanied by a 
certificate 
 CPSA section 14(a)(2) – requires testing and 
certification before importation 
 CPSA section 14(g)(3) – requires certificates 
to accompany the product or shipment of 
products, as well as be provided to CPSC 
and CBP upon request. 
9/19/2014 5
Existing 1110 Rule 
 Paper or electronic certificates (URL typically on the 
product, container, or invoice) 
 Electronic certificates must be created before 
importation 
 Available to CPSC and CBP as soon as the product 
or shipment itself is available for inspection. 
 In practice, Certificates: 
 Obtained and reviewed at the time of entry through 
broker or importer which may take time to present 
and may delay release 
 No ability to assess industry compliance with 
requirement 
9/19/2014 6
Certificates - Proposed 
 Proposed rule (proposed 16 CFR §1110.13) – 
certificates for imported products must be filed 
electronically with CBP at the time of filing the CBP 
entry or at the time of filing the entry and entry 
summary, if both are filed together. 
 Aligns with Executive Order 13659: “Streamlining the 
Export/Import Process for America's Businesses” 
 Entering required data elements for certificates at the 
time of entry would allow the agency to 
 Electronically review and facilitate release 
 Prioritize examinations with certificate data at entry 
9/19/2014 7
Risk Assessment Methodology (RAM) 
 CPSA Section 17(h)(1) Requires CPSC to: 
 Establish and maintain a permanent product surveillance 
program, in cooperation with other federal agencies, to 
carry out the Commission’s responsibilities and to 
prevent the entry of unsafe consumer products into the 
commerce of the United States. 
 CPSIA Section 222(a) Requires CPSC to: 
 Develop a Risk Assessment Methodology (RAM) that 
identifies shipments of consumer products that are 
 (1) intended for import into the United States; and 
 (2) likely to include consumer products in violation of 
Section 17(a) of the CPSA (15 USC 2066(a)) or other 
import provisions enforced by the Commission. 
9/19/2014 8
Risk Assessment Methodology 
(RAM) 
 CPSIA Section 222(b) requires CPSC RAM 
development to: 
 Use CBP’s ITDS insofar as practicable, 
 Incorporate the RAM into CPSC’s IT 
modernization plan, and 
 Examine how to share information with CBP for 
the purpose of identifying risky shipments. 
9/19/2014 9
Total Risk Management at Import 
 Monitoring 
 Shipment activity by product, entity, and port/region 
 Violation history/risk by product, entity, and port/region 
 Address risk in product areas and entities at import. 
 Examples: 
 Limited complexity: ATVs 
 High complexity: Toys 
9/19/2014 10
Risk Assessment Program 
Components 
 Intergovernmental Memoranda of Understanding 
and agreements 
 Collocated personnel with CBP 
 Integration with CBP data systems - pilot system 
 Other improvement projects 
 Product coding 
 Internal case and process monitoring 
9/19/2014 11
Risk Assessment Program 
Components 
 Intergovernmental Memoranda of Understanding 
and agreements 
 Collocated personnel with CBP 
 Integration with CBP data systems - pilot system 
 Other improvement projects 
 Product coding 
 Internal case and process monitoring 
1 
9/19/2014 12
Risk Assessment Program 
Components 
 Intergovernmental Memoranda of Understanding 
and agreements 
 Collocated personnel with CBP 
 Integration with CBP data systems - pilot system 
 Other improvement projects 
 Product coding 
 Internal case and process monitoring 
2 
9/19/2014 13
Collocated Staff 
Works cooperatively at ports to target and screen 
shipments 
 Chemical analysis – XRF and FT-IR 
 Mechanical analysis – Use/abuse and physical 
assessment 
 Document verification – Certification and tracking 
labels 
9/19/2014 14
Risk Assessment Program 
Components 
 Intergovernmental Memoranda of Understanding 
and agreements 
 Collocated personnel with CBP 
 Integration with CBP data systems - pilot system 
 Other improvement projects 
 Product coding 
 Internal case and process monitoring 
3 
9/19/2014 15
Pilot System (ITDS/RAM) 
Integrates available risk information to model and 
support Commission enforcement strategy 
involving product hazards at importation 
Potential sources of risk data include: 
 Shipment (CBP) 
 Case history (CPSC & CBP) 
 Examination history (CPSC) 
 Injury and death (CPSC) 
 Commercial information (Third Party) 
9/19/2014 
14
Pilot System Functions 
 Statistical modeling to assist in the prioritization 
of projects and operations 
 Risk-based standard reporting for product 
managers to know importation patterns 
 Graphical User Interface to manage screening 
and exams at ports of entry 
 Systematic assessment methodology to review 
and prioritize all shipments of potential 
interest to CPSC 
9/19/2014 
15
CPSC-CBP Data Synchronization 
9/19/2014 18
CPSC-CBP Data Synchronization 
9/19/2014 19
CPSC-CBP Data Synchronization 
9/19/2014 20
CPSC-CBP Data Synchronization 
9/19/2014 21
CPSC-CBP Data Synchronization 
9/19/2014 22
Risk Assessment Program 
Components 
 Intergovernmental Memoranda of Understanding 
and agreements 
 Collocated personnel with CBP 
 Integration with CBP data systems - pilot system 
 Other improvement projects 
 Product coding 
 Internal case and process monitoring 
4 
9/19/2014 23
HTSUS Reclassification 
Work with the U.S. International Trade Commission on 
the reclassification of some product areas to support 
regulation enforcement and defect identification 
 Completed once for the January 1, 2011 mapping 
 Toys 
 ATVs 
 Children’s Durable Products 
 Drywall 
 Second set under review 
9/19/2014 24
Modernizing Certificate Collection 
Will: 
 Reduce the shipments reviewed that are compliant 
or out of scope 
 Reduce the time spent per shipment to verify 
compliance with our laws 
 Improve the rate of discovery of hazardous/violative 
products per staff month 
 Provide a single, reliable store of certificate data 
9/19/2014 25
John Blachère 
This presentation has not been reviewed or approved 
by the Commission and may not reflect its views 
9/19/2014 26
Single Window and 
Automated Commercial Environment 
(ACE) 
Brenda Smith 
ACE Business Office 
CPSC Workshop on Electronic Filing of Certificates at Entry 
September 18, 2014
28
Single Window Authorization and Support 
 Executive Order signed February 19, 2014 – Streamlining the 
Export / Import Process for America’s Businesses 
 Directs 47 U.S. Federal agencies with a role in trade to be ready to 
participate in the electronic “Single Window” by December 2016 
 Expands scope of the Border Interagency Executive Council (BIEC) 
to all agencies with a border interest 
 ITDS Board of Directors provides executive leadership and 
direction, and works with PGAs on automation 
 ACE Executive Steering Committee (DHS and CBP executives) 
provides oversight and guidance to the ACE Program to ensure 
successful development and operation 
29
IT Foundation for the Single Window 
ACE will automate trade processing and data collection for 47 federal agencies 
Enhances agency enforcement missions through 
trade targeting and risk segmentation 
Increased USDA food seizures 30-fold 
Automated processes saving CBP $46M/year 
Reduces U.S. supply chain transaction costs 
Streamlines interagency processing through 
collaboration and less paperwork 
Strengthens the global supply chain to protect U.S. 
interests and enhance prosperity 
Supports U.S. manufacturing growth by facilitating 
exports 
National Export Initiative 
Single Window 
Security and Safety 
One U.S. Government at the 
Border 
U.S. Economic 
Competitiveness 
Global Supply Chain Strategy 
Automated Commercial Environment 
33% faster truck processing 
Up to 76% duties/fees paid interest free via ACE 
Nine agencies receiving automated data via ACE 
Pre-arrival data linked and available in ACE 
Participating ocean carriers saving $900K/year in 
reduced courier costs 
30
Implementing the Single Window 
Three enablers provide the means for Partner Government 
Agencies (PGAs) to participate in ITDS/ACE 
 Partner Government Agency (PGA) Message Set - Establishes 
a single, harmonized set of information to be collected 
electronically from international traders by CBP on behalf of PGAs 
 Interoperability Web Services - Provides a system-to-system 
pipeline for data transfer between CBP and PGAs 
 Document Image System (DIS) - Allows trade members to 
supply images of needed documents electronically during the 
cargo import and export processes 
The ACE portal provides PGAs with a graphical user interface (GUI) to 
view the data in ACE, search on that data and run reports. The ACE portal 
is a consistent interface across PGAs that differs only by their particular 
information and processing needs. 
31
PGA Integration Status 
4 9 9 
32 
2 
2 
10 
11 
6 
9 
30 
25 
20 
15 
10 
5 
0 
PGA Message Set Document Image System 
(DIS) 
Interoperability Web 
Service (IWS) 
Developed In Progress Remaining 
PGAs 
• CPSC is among the nine agencies using IWS capabilities
PGA Message Set Processing Benefits 
 Today, PGA data is submitted manually via paper forms, requiring human 
intervention and manual correlation with transactions 
 PGA Message Set extends existing CATAIR message set to allow 
submission of PGA data electronically to CBP along with entry and entry 
summary filings 
 The Single Window will streamline transmission, processing and distribution 
of PGA data, yielding significant cost savings and efficiency: 
 Trade and multiple government agencies will no longer exchange information via 
multitude channels during the cargo release process 
 Data will be available to agencies more quickly, allowing for better identification 
of dangerous or prohibited shipments 
 Automated PGA interactions reduce paper and enable near-real time decision 
making by Government authorities 
 Single Window makes it easier for industry to comply with government 
regulations and reduces costs for Government and industry 
33
PGA Onboarding Process 
47 PGAs to be on-boarded in three phases, beginning with PGAs with 
Cargo Release responsibilities 
 Phase I – Initial capabilities deployed to 10 agencies by April 30, 2014 
 Phase II – Advanced capabilities deployed to 13 agencies by July 4, 2015 
 Phase III – Advanced capabilities deployed to remaining agencies by 
July 1, 2016 
34
CPSC Connectivity Status 
 IWS enabled October 2011 
 CPSC receiving production entry and entry summary data 
directly from CBP 
 CPSC upgraded to advanced Event Exchange capability in IWS 
on September 10, 2014 
 CBP and CPSC are engaged in on-going discussions to plan 
for exchange of forms via DIS to supplement the admissibility 
review process 
 Planning to be DIS capable with July 4, 2015 ACE deployment 
35
Mandatory Dates for Transition to ACE 
Date Mandatory Requirement Time Remaining 
May 1, 2015 Mandatory use of ACE for electronic 
import and export manifest filings 
8 months 
November 1, 2015 Mandatory use of ACE for electronic 
Cargo Release and related Entry 
Summary filings 
14 months 
October 1, 2016 Mandatory use of ACE for all 
remaining portions of the CBP cargo 
process 
25 months 
36
Questions? 
Visit http://cbp.gov/ace 
Or e-mail us at: ASKACE@cbp.dhs.gov 
37
PGA Data Processing: Architecture 
38
Food Safety and Inspection Service 
Food Safety and Inspection Service 
Pilot for PGA Message Set 
Bob Berczik 
International Relations and Strategic Planning Staff 
Office of Public Policy and Program Development 
Food Safety and Inspection Service, USDA 
40
Food Safety and Inspection Service: 
Mission in Action 
We are the public health 
agency in the USDA 
responsible for ensuring 
that meat, poultry, and 
processed egg products 
are safe, wholesome, and 
accurately labeled. 
• Federal Meat Inspection Act (FMIA), 1906 
• Agricultural Marketing Act (AMA), 1946 
• Poultry Products Inspection Act (PPIA), 1957 
•Humane Methods of Slaughter Act (HMSA), 1958 
• Egg Products Inspection Act (EPIA), 1970 
Our Authority 
Through a series of Acts, Congress 
empowers FSIS to inspect all meat, 
poultry, and processed egg products 
in interstate commerce. 
41
Public Health Information System (PHIS) 
o Designed to collect, consolidate, and analyze data derived from both domestic 
inspection and foreign country inspection systems 
o Centralized computer database that generates random import inspection tasks and 
stores inspection results, based on: 
• Exporting country, process category, species, performance 
o Interconnected with US Customs and Border Protection’s (CBP) Automated 
Commercial Environment (ACE) 
o Pre-populates shipment data received from industry, enhancing controls and reducing 
fraud 
• PHIS connection to ACE 
• Partner Government Agency (PGA) Message Set 
 PGA Message Set Pilot underway with two brokers making entries at three POEs with 
nationwide implementation to follow 
o GOAL: to streamline the Customs entry process and transition away from paper – 
based application process for FSIS import inspection 
42
PHIS 
o Enables interface with U.S. Customs and Border 
Protection’s Automated Commercial Environment (ACE) 
system 
• Business-to-government exchange of shipment data 
• Provides FSIS Advance Notice when Customs entry filed 
• Replaces paper application for inspection (Form 9540-1) 
 Uses existing data collected by CBP 
 Incorporates FSIS specific data into the CBP standard data set 
(UN/CEFACT and WCO compliant) 
43
o Importers are required to apply for 
FSIS import inspection for all 
entries of meat, poultry, and egg 
products 
o An Entry or Entry Summary 
Certified for cargo release in ACE, 
combined with the PGA Message 
Set, will eliminate the need for 
paper applications 
• An electronic FSIS Form 
9540-1 will expedite the 
clearance process on 
regulated shipments 
FSIS Import Application (FSIS Form 9540-1) 
44
o Electronic import application 
in PHIS retrieves data from 
ACE 
• PGA Message Set data completes 
the data fields missing from the 
FSIS import application 
o For example 
• Broker information provides local 
broker first name*, last name*, 
phone number,* email address* 
or fax number 
o *Data fields are required in 
PHIS import application 
• PHIS utilizes information to 
exchange electronic messages 
between FSIS and Trade 
Current Partial Data Feed 
45
Data Complete with Message Set 
PG19 CB 
PG21 LOCAL BROKER CONTACT INFORMATION – FIRST NAME AND LAST NAME, 
LOCAL PHONE NUMBER, AND E MAIL ADDRESS – MARTHA STEWART 313-666- 
7777 JAS2@hotmail.com 
PG21 LOCAL BROKER FAX NUMBER IS 313-666-7771 
46
FSIS Data Grouping 
The PGA Message Set accommodates the following “many-to-one” 
data relationships: 
o Many inspection certificates to one entry 
• The PG 50 and 51 start and end the groupings 
• Multiple PG 14 (inspection certificates) may relate to the PG 
13 (the foreign government that issued the certificate) 
o Many lots within one inspection certificate 
• The PG 50 and 51 start and end the groupings 
• Multiple data lines providing specific lot information are 
related to the PG 14 (inspection certificate) 
47
Foreign Inspection Certificates 
o FSIS requires all imported meat, poultry and egg products to be properly 
certified by the competent authority in the exporting foreign country 
o The electronic import application in PHIS uses a combination of 
information supplied in part from Trade and from the foreign inspection 
certificate 
• Currently PHIS receives official certification data electronically from Australia, 
New Zealand, and the Netherlands* 
• For shipments certified electronically, when importers/brokers identify the 
inspection certificate number through the PGA Message Set, FSIS PHIS will 
populate the import application based on the eCert data 
o Filers making entries from countries that do not certify shipments 
electronically must provide additional PGA Message Set data identifying 
product attributes 
*Note: FSIS will develop the capability to exchange official certification data 
electronically with other foreign governments 
48
FSIS Message Set Pilot 
o The FSIS PGA Message Set Pilot began on April 27, 2014 
o FSIS pilot has two Customs brokers actively participating: 
• A.N. Deringer, Broker Filer, Code 551 
• Barthco International Inc. dba OHL International, Broker Filer Code 
OHL 
• Customs brokers participating in the pilot have the option to file 
entries with or without the complete message set data elements 
o Pilot entries are at three ports of entry: 
• Champlain, NY, Port Code 0712 
• Philadelphia, PA, Port Code 1101 
• Houston, TX Port, Code 5301 
49
FSIS Message Set Pilot 
o From April 27, 2014 through September 4, 2014, the two participating 
brokers in the FSIS pilot have submitted a combined 109 entries through 
ACE utilizing the PGA message set representing 4.5 million pounds of 
product under FSIS jurisdiction 
o Entries filed are for product from Canada, Australia and New Zealand 
o Product from Australia and New Zealand are interfacing with government-to-government 
inspection certificate data exchange (eCert) 
50 
Message Set Entries by Import Country of 
Origin 
Canada (A.N.Derringer) 
Australia (OHL combined with 
eCert) 
New Zealand (OHL combined 
with eCert)
FSIS Message Set Pilot 
o 87% of the pilot entries had no identified issues 
o 13% of the pilot entries to date had identified issues 
o Types of issues encountered: 
o Data mapping both internal to FSIS and external to filer software use 
o HTS conflict (1 entry) 
Note: No identified issues delayed shipment movement or reinspection of 
product by FSIS. No data transfer issues from ACE to FSIS have been 
identified. 
51
FSIS Message Set Pilot (software validations) 
o Automation of eCert pre-population of the application based on the 
PG14 record from the filer 
• 42 entries submitted validated the success of eCert filings from 
Australia and New Zealand systems. 
o Multiple inspection certificates (PG14) identified on a single entry 
• 6 entries submitted with multiple certificate numbers and PHIS created 
separate applications based on the PG14 records as expected 
o Increase shipment monitoring capabilities to prevent Failure to 
Present (FTP) 
• PG 30 record facilitates FSIS monitoring 
o Elimination of FSIS import inspectors to manually enter application 
data increases efficiency of reinspection process 
52
References 
o Data Samples and Guidelines for Using the PGA Message Set for Electronic 
Completion of the U.S. Department of Agriculture (USDA), Food Safety 
Inspection Service (FSIS) Application for Import Inspection (FSIS Form 9540-1) 
http://www.fsis.usda.gov/wps/wcm/connect/98c45f3c-8a5b-47d7-9907- 
2fdc7352547f/Data_Samples_Guidelines_PGA_Message_Set.pdf?MOD= 
AJPERES&CACHEID=44196b9d-4fc1-45e0-a1de-eb3701385366 
o Public Health Information System (PHIS) – Import Component 
http://www.fsis.usda.gov/wps/portal/fsis/topics/international-affairs/importing-products/ 
phis-import-component/CT_Index1 
53
FSIS Contacts 
Bob Berczik 
202-690-4163 
Robert.Berczik@fsis.usda.gov 
Mary Stanley 
202-720-0287 
Mary.Stanley@fsis.usda.gov 
54
EPA ACE Pilots: 
Looking for Volunteers 
Consumer Product Safety Commission 
Workshop on Electronic Filing 
Bethesda, MD 
September 18, 2014
Topics 
• EPA-regulated commodities 
• What we are doing 
• What Trade can expect 
• Pilot programs 
• Trade Participation, Getting Started 
• Sample Message Set 
• Summary 
• Questions? 
56
57 
EPA-Regulated Commodities 
Under environmental statutes 
administered by EPA, six 
programs have import safety 
responsibility. 
Ozone Depleting Substances (CAA) 
Vehicles and Engines (CAA) 
Fuels (CAA) 
Toxic Substances (TSCA) 
Pesticides (FIFRA) 
Hazardous Waste (RCRA) 
• Statutory requirements are built 
on risks to human health and the 
environment. 
• Admissibility of EPA-regulated 
commodities are based on 
compliance to statutory 
requirements (reporting).
ODSTS 
Verify 
PRISM 
58 
What We Are Doing: 
eFiling, Automated Processing 
Internet 
ODS 
Engines 
Pesticides 
Hazardous 
Waste 
WIETS 
Importers, Brokers, 
& Carriers 
Central Data 
Exchange (CDX) 
CBP & EPA 
Import Data 
Customs 
and 
Border 
Protection 
ACE Data 
Warehouse ACE/ITDS Single 
Window 
ABI Interface 
EDI 
ACE’s ESB 
EPA’s 
Network Node 
XML 
EPA 
Staff 
Streamline, improve reporting/processing of legal imports/exports 
• Paper to electronic filing (Entry, Entry Summary Certified for 
Release, Simplified Entry/Cargo Release) –Partner Government 
Agency (PGA) Message Set, Automated Broker Interface (ABI) 
• Validations to automate reviews for many EPA-regulated 
commodities 
• Electronic status messaging – ABI messages (including errors 
and clearance) 
• Updates, corrections – before arrival at, exit from ports 
Goal: Early indication reporting requirements are met 
BEFORE cargo is loaded on a plane, truck, train, or 
ocean vessel.
59 
What Trade Can Expect: 
• Shortened review/processing time from current paper 
filings (in some cases from days/weeks to minutes/seconds) 
• Standardized filing process for EPA-regulated commodities 
at all Ports nationwide 
• Eliminate duplicate reporting to EPA, CBP 
• Eliminate courier fees 
• Error responses for invalid filings to provide specific 
information (data element level) 
• Ability to update and correct PGA Message Set filings 
(future)
60 
Pilot Programs 
• Current pilots in production (April 30, 2014) 
– Ozone Depleting Substances 
– Vehicle and Engine Declarations 
 Starting in ports of Long Beach and Newark 
• Pilots planned for fall/winter 2014 
– Notice of Arrival for pesticide imports 
 Starting in ports of Chicago, Port Huron, Newark 
– Hazardous Waste Exports (Spent Lead Acid Batteries) 
 Starting in ports of Hildago, Laredo 
• Get started now 
– PGA Message set samples, get going with software developers
Trade Participation 
• What you will do 
– Create message sets 
– Submit Test filings to the Certification Environment in ACE 
– Receive, respond to Customs And Border protection (CBP) 
notifications if needed 
– File in Production 
• What you need to file (boiled down): 
– Ozone Depleting Substances (ODS): approved importer of record, 
quantity 
– Vehicle/Engine Declaration: Data from forms 3520-1 and 21; 
certification number 
– Pesticides Notice of Arrival: Data from form 3540-1; registration, 
producer establishment number 
– Hazardous Waste Exports: Consent number 61
Getting Started 
62 
• Are you an ACE Filer? Talk to your CBP Client Rep. 
• Are you filing these commodities at these ports? 
• Confirm participation. 
– Current Pilots - Contact me and your Client Rep to get started. 
– Planned Pesticide Pilot - Respond to CBP-issued Federal Register 
Notice (expected Fall 2014), contact me. 
– Planned Hazardous Waste Export Pilot - contact me. 
• Work with EPA and your software developers. Begin 
identifying PGA Message Set adjustments to your 
software (EPA will work with you on examples).
Sample PGA Message Set 
1 2 3 4 5 6 7 8 9 
10 
1 2 3 4 5 6 7 8 9 
20 
1 2 3 4 5 6 7 8 9 
30 
1 2 3 4 5 6 7 8 9 
40 
1 2 3 4 5 6 7 8 9 
50 
1 2 3 4 5 6 7 8 9 
60 
1 2 3 4 5 6 7 8 9 
70 
1 2 3 4 5 6 7 8 9 
80 
O I O F F M O S Q U I T O R E P E L L E N T 
P G 0 1 0 0 1 E P A P S 1 Y 
P G 0 2 P 
P G 0 7 O F F M O S Q U I T O R E P E L L E N T 
P G 1 4 2 E P 8 6 9 3 4 0 - 8 
P G 1 9 E P N 0 1 2 3 4 5 C H N 0 0 2 
P G 1 9 C B S U P E R C U S T O M S B R O K E R A G E C O M P A N Y 5 0 0 E A S T 1 7 T H S T R E E T 
P G 2 0 1 0 0 N E W Y O R K N Y U S 1 0 0 1 2 
P G 2 1 C B J O H N S M I T H 2 0 2 2 3 4 5 6 7 8 J O H N . S M I T H @S U P E R B R O K E R A G E . C O M 
P G 1 9 I M B U G S P R A Y I M P O R T C O M P A N Y 3 4 5 N E WB E R R Y S T R E E T 
P G 2 0 2 0 3 B O S T O N M A U S 0 2 1 0 5 
P G 2 1 I M J A N E S M I T H 6 1 7 2 3 4 5 6 7 8 J A N E . S M I T H @B U G S P R A Y I M P O R T . C O M 
P G 5 5 N P C I 
P G 1 9 O V M A R I T I M E I N D U S T R I A L S H I P P E R S 6 0 0 P O R T R D 
P G 2 0 N E WA R K N J U S 2 0 0 3 4 
P G 2 1 O V J A Y S M I T H 4 1 0 1 1 2 3 4 5 6 J A Y . S M I T H @M A R I T I M E S H I P P E R S . C O M 
P G 1 9 D E Q S U P E R I O R S H I P P I N G C O M P A N Y 4 3 2 P O R T B O U L E V A R D 
P G 2 0 L A P U - L A P U C I T Y P H 3 2 3 4 0 2 4 8 6 
P G 2 1 D E Q J O H N R E Y E S 6 3 3 2 4 1 1 5 8 0 0 J O H N . R E Y E S @S U P E R I O R S H I P P I N G . P H 
P G 1 9 L G F A M O U S S T O R A G E A N D WA R E H O U S E 1 2 3 4 5 J E R S E Y A V E 
P G 2 0 N E WA R K N J U S 0 7 3 1 0 
P G 2 1 L G M A R K 6 6 3 2 4 5 7 7 8 3 3 M A R K . J I M@T I M E . C O M 
P G 2 2 9 4 4 C I E P 3 Y 0 2 1 1 2 0 1 4 
P G 2 6 2 0 0 0 0 0 0 0 0 1 0 0 0 O Z 
P G 2 6 1 0 0 0 0 0 0 1 0 0 0 0 0 B O 
P G 2 9 K G 0 0 0 0 0 0 0 2 8 4 5 3 
P G 0 2 C C A S 9 4 2 7 1 - 0 3 - 1 
P G 0 4 Y D E E T 0 1 5 3 7 5 7 
P G 0 2 C C A S 5 2 3 0 4 - 3 6 - 6 
P G 0 4 Y I R 3 5 3 5 0 3 5 0 0 0 0 
P G 0 2 C C A S 1 1 9 5 1 5 - 3 8 - 7 
P G 0 4 Y P I C A R I D I N 0 0 5 5 0 0 0 
P G 0 2 C P C 0 0 6 4 9 1 
P G 0 4 Y B T M O C R Y 1 F 0 0 2 1 0 0 0 
8/28/2012 U.S. Environmental Protection Agency 63
Summary 
• EPA and CBP are testing in pilots 
– Moving to eFiling, automated processing 
• Need Trade volunteers to test 
– eReporting, early filing, messaging 
– Look for Federal Register Notice for pesticides pilot 
– Contact your Client Rep and me if you are interested 
64
65 
For More Information 
Roy Chaudet 
Office of Information Collection 
Office of Environmental Information 
U.S. Environmental Protection Agency 
202-566-1703 
chaudet.roy@epa.gov
66 
Questions?
www.anderinger.com 
© 2013 A.N. Deringer, Inc. 
CPSC - ITDS 
Heritage of Trust Since 1919 
• Introduction/perspective 
• Timing & resources necessary to participate in FSIS pilot 
• ACE conversion 
• Software development 
• Testing 
• Additional data fields 
• How many additional data fields required 
• Additional time required to process shipment
One U.S. Government 
at the Border 
September 2014 
68
13th Term COAC 1 US 
Government @ TB November 2013 Public Meeting 
Recommendations 
Unified Filing of Entry Information 
Entry and PGA data sent well in advance 
of cargo arrival 
CBP and PGA review data in advance of 
cargo arrival, screening for data 
accuracy, importer & product 
compliance etc. 
Clear PGA responses to filer at the line 
level 
Sound Risk Assessment methodologies 
employed (prefer to use data not 
69
13th Term COAC 1 US 
Government @ TB Trusted Trader Program 
 Expedited clearance for known importers 
 Leverage CBP and Trade’s investment in C-TPAT, 
ISA or FS 
Single Window Efficiencies 
 Collect only the data required and utilize 
data collected for other purposes for the 
PGA data whenever possible 
Consider alternative method of identifying 
importers/exporters/foreign facilities – DUNS 
number? 
 Risk Assessment Methodology system must be 
robust, recognizing compliant importers, 
70
13th Term COAC 1 US 
Government @ TB Single Window Challenges 
Ability to timely obtain the right data from 
the actual importer well in advance of 
cargo arrival 
Key entry errors – they will occur! The more 
data required, (especially free form, not 
table driven) the greater the chance for 
errors 
Management of data across all PGA 
message sets will be a challenge to the entry 
filer and the importer. Data creep is a major 
concern for the trade community 
When data anomalies occur, immediate 
feedback to the filer must be given in form of 
71
Business Needs & Realities 
The Global Supply Chain is constantly evolving 
– legitimate trade should be managed as 
efficiently as possible 
Non-resident Importers of Record are 
becoming more common. 
Business to Consumer (B2C) shipments are 
increasing 
Trade moves 24/7 – need the PGAs to make 
admissibility decisions well in advance of 
arrival to keep goods flowing. 
 Set High vs Medium vs Low Risk Priorities and 
perform post entry audits. 
 Staged implementation (similar to APHIS 
72
Keys to Success 
Vigorous Trade Participation in ACE 
The more you test, the more you learn about 
the system, the process and the data 
requirements, and the more efficient the 
trade will become in managing the data. 
 Participation in PGA Pilots by Importers and 
Brokers who will be affected by the PGA 
message set for that Agency is critical to the 
success of the PGA Pilot. 
 Data Quality Issues can be addressed 
 Mutual Understanding of the Data 
Requirements and Commercial Availability of 
the Data can be achieved 
 The Pilot is an important exercise to ensure 
73
Thank You 
One U.S. “Efficient” Government at the Border 
Is our GOAL! 
74

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CPSC Risk Assesment Model (RAM), CBP Automated Commercial Environment (ACE), & Pilot Programs

  • 1. U.S. Consumer Product Safety Commission 1 CPSC Staff Workshop on Electronic Filing of Certificates as Included in Proposed Rule on Certificates of Compliance September 18, 2014 This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.
  • 2. For those of you in the room, please mute electronics and phones. For those of you watching on the web, you can email questions for the speakers to: efiling@cpsc.gov. The transcript for today’s workshop will be added to the docket at: www.regulations.gov Docket number: CPSC–2013–0017 The PowerPoint presentations will also be available at: http://www.slideshare.net/USCPSC
  • 3. John Blachère This presentation has not been reviewed or approved by the Commission and may not reflect its views 9/19/2014 3
  • 4. Presentation Acronyms  HTSUS – Harmonized Tariff Schedule specific to the United States  ITDS – International Trade Data System  CBP – U.S. Customs and Border Protection 9/19/2014 4
  • 5. Certificates – Current  CPSA section 17(a)(2) - requires the Commission to refuse admission for regulated products not accompanied by a certificate  CPSA section 14(a)(2) – requires testing and certification before importation  CPSA section 14(g)(3) – requires certificates to accompany the product or shipment of products, as well as be provided to CPSC and CBP upon request. 9/19/2014 5
  • 6. Existing 1110 Rule  Paper or electronic certificates (URL typically on the product, container, or invoice)  Electronic certificates must be created before importation  Available to CPSC and CBP as soon as the product or shipment itself is available for inspection.  In practice, Certificates:  Obtained and reviewed at the time of entry through broker or importer which may take time to present and may delay release  No ability to assess industry compliance with requirement 9/19/2014 6
  • 7. Certificates - Proposed  Proposed rule (proposed 16 CFR §1110.13) – certificates for imported products must be filed electronically with CBP at the time of filing the CBP entry or at the time of filing the entry and entry summary, if both are filed together.  Aligns with Executive Order 13659: “Streamlining the Export/Import Process for America's Businesses”  Entering required data elements for certificates at the time of entry would allow the agency to  Electronically review and facilitate release  Prioritize examinations with certificate data at entry 9/19/2014 7
  • 8. Risk Assessment Methodology (RAM)  CPSA Section 17(h)(1) Requires CPSC to:  Establish and maintain a permanent product surveillance program, in cooperation with other federal agencies, to carry out the Commission’s responsibilities and to prevent the entry of unsafe consumer products into the commerce of the United States.  CPSIA Section 222(a) Requires CPSC to:  Develop a Risk Assessment Methodology (RAM) that identifies shipments of consumer products that are  (1) intended for import into the United States; and  (2) likely to include consumer products in violation of Section 17(a) of the CPSA (15 USC 2066(a)) or other import provisions enforced by the Commission. 9/19/2014 8
  • 9. Risk Assessment Methodology (RAM)  CPSIA Section 222(b) requires CPSC RAM development to:  Use CBP’s ITDS insofar as practicable,  Incorporate the RAM into CPSC’s IT modernization plan, and  Examine how to share information with CBP for the purpose of identifying risky shipments. 9/19/2014 9
  • 10. Total Risk Management at Import  Monitoring  Shipment activity by product, entity, and port/region  Violation history/risk by product, entity, and port/region  Address risk in product areas and entities at import.  Examples:  Limited complexity: ATVs  High complexity: Toys 9/19/2014 10
  • 11. Risk Assessment Program Components  Intergovernmental Memoranda of Understanding and agreements  Collocated personnel with CBP  Integration with CBP data systems - pilot system  Other improvement projects  Product coding  Internal case and process monitoring 9/19/2014 11
  • 12. Risk Assessment Program Components  Intergovernmental Memoranda of Understanding and agreements  Collocated personnel with CBP  Integration with CBP data systems - pilot system  Other improvement projects  Product coding  Internal case and process monitoring 1 9/19/2014 12
  • 13. Risk Assessment Program Components  Intergovernmental Memoranda of Understanding and agreements  Collocated personnel with CBP  Integration with CBP data systems - pilot system  Other improvement projects  Product coding  Internal case and process monitoring 2 9/19/2014 13
  • 14. Collocated Staff Works cooperatively at ports to target and screen shipments  Chemical analysis – XRF and FT-IR  Mechanical analysis – Use/abuse and physical assessment  Document verification – Certification and tracking labels 9/19/2014 14
  • 15. Risk Assessment Program Components  Intergovernmental Memoranda of Understanding and agreements  Collocated personnel with CBP  Integration with CBP data systems - pilot system  Other improvement projects  Product coding  Internal case and process monitoring 3 9/19/2014 15
  • 16. Pilot System (ITDS/RAM) Integrates available risk information to model and support Commission enforcement strategy involving product hazards at importation Potential sources of risk data include:  Shipment (CBP)  Case history (CPSC & CBP)  Examination history (CPSC)  Injury and death (CPSC)  Commercial information (Third Party) 9/19/2014 14
  • 17. Pilot System Functions  Statistical modeling to assist in the prioritization of projects and operations  Risk-based standard reporting for product managers to know importation patterns  Graphical User Interface to manage screening and exams at ports of entry  Systematic assessment methodology to review and prioritize all shipments of potential interest to CPSC 9/19/2014 15
  • 23. Risk Assessment Program Components  Intergovernmental Memoranda of Understanding and agreements  Collocated personnel with CBP  Integration with CBP data systems - pilot system  Other improvement projects  Product coding  Internal case and process monitoring 4 9/19/2014 23
  • 24. HTSUS Reclassification Work with the U.S. International Trade Commission on the reclassification of some product areas to support regulation enforcement and defect identification  Completed once for the January 1, 2011 mapping  Toys  ATVs  Children’s Durable Products  Drywall  Second set under review 9/19/2014 24
  • 25. Modernizing Certificate Collection Will:  Reduce the shipments reviewed that are compliant or out of scope  Reduce the time spent per shipment to verify compliance with our laws  Improve the rate of discovery of hazardous/violative products per staff month  Provide a single, reliable store of certificate data 9/19/2014 25
  • 26. John Blachère This presentation has not been reviewed or approved by the Commission and may not reflect its views 9/19/2014 26
  • 27. Single Window and Automated Commercial Environment (ACE) Brenda Smith ACE Business Office CPSC Workshop on Electronic Filing of Certificates at Entry September 18, 2014
  • 28. 28
  • 29. Single Window Authorization and Support  Executive Order signed February 19, 2014 – Streamlining the Export / Import Process for America’s Businesses  Directs 47 U.S. Federal agencies with a role in trade to be ready to participate in the electronic “Single Window” by December 2016  Expands scope of the Border Interagency Executive Council (BIEC) to all agencies with a border interest  ITDS Board of Directors provides executive leadership and direction, and works with PGAs on automation  ACE Executive Steering Committee (DHS and CBP executives) provides oversight and guidance to the ACE Program to ensure successful development and operation 29
  • 30. IT Foundation for the Single Window ACE will automate trade processing and data collection for 47 federal agencies Enhances agency enforcement missions through trade targeting and risk segmentation Increased USDA food seizures 30-fold Automated processes saving CBP $46M/year Reduces U.S. supply chain transaction costs Streamlines interagency processing through collaboration and less paperwork Strengthens the global supply chain to protect U.S. interests and enhance prosperity Supports U.S. manufacturing growth by facilitating exports National Export Initiative Single Window Security and Safety One U.S. Government at the Border U.S. Economic Competitiveness Global Supply Chain Strategy Automated Commercial Environment 33% faster truck processing Up to 76% duties/fees paid interest free via ACE Nine agencies receiving automated data via ACE Pre-arrival data linked and available in ACE Participating ocean carriers saving $900K/year in reduced courier costs 30
  • 31. Implementing the Single Window Three enablers provide the means for Partner Government Agencies (PGAs) to participate in ITDS/ACE  Partner Government Agency (PGA) Message Set - Establishes a single, harmonized set of information to be collected electronically from international traders by CBP on behalf of PGAs  Interoperability Web Services - Provides a system-to-system pipeline for data transfer between CBP and PGAs  Document Image System (DIS) - Allows trade members to supply images of needed documents electronically during the cargo import and export processes The ACE portal provides PGAs with a graphical user interface (GUI) to view the data in ACE, search on that data and run reports. The ACE portal is a consistent interface across PGAs that differs only by their particular information and processing needs. 31
  • 32. PGA Integration Status 4 9 9 32 2 2 10 11 6 9 30 25 20 15 10 5 0 PGA Message Set Document Image System (DIS) Interoperability Web Service (IWS) Developed In Progress Remaining PGAs • CPSC is among the nine agencies using IWS capabilities
  • 33. PGA Message Set Processing Benefits  Today, PGA data is submitted manually via paper forms, requiring human intervention and manual correlation with transactions  PGA Message Set extends existing CATAIR message set to allow submission of PGA data electronically to CBP along with entry and entry summary filings  The Single Window will streamline transmission, processing and distribution of PGA data, yielding significant cost savings and efficiency:  Trade and multiple government agencies will no longer exchange information via multitude channels during the cargo release process  Data will be available to agencies more quickly, allowing for better identification of dangerous or prohibited shipments  Automated PGA interactions reduce paper and enable near-real time decision making by Government authorities  Single Window makes it easier for industry to comply with government regulations and reduces costs for Government and industry 33
  • 34. PGA Onboarding Process 47 PGAs to be on-boarded in three phases, beginning with PGAs with Cargo Release responsibilities  Phase I – Initial capabilities deployed to 10 agencies by April 30, 2014  Phase II – Advanced capabilities deployed to 13 agencies by July 4, 2015  Phase III – Advanced capabilities deployed to remaining agencies by July 1, 2016 34
  • 35. CPSC Connectivity Status  IWS enabled October 2011  CPSC receiving production entry and entry summary data directly from CBP  CPSC upgraded to advanced Event Exchange capability in IWS on September 10, 2014  CBP and CPSC are engaged in on-going discussions to plan for exchange of forms via DIS to supplement the admissibility review process  Planning to be DIS capable with July 4, 2015 ACE deployment 35
  • 36. Mandatory Dates for Transition to ACE Date Mandatory Requirement Time Remaining May 1, 2015 Mandatory use of ACE for electronic import and export manifest filings 8 months November 1, 2015 Mandatory use of ACE for electronic Cargo Release and related Entry Summary filings 14 months October 1, 2016 Mandatory use of ACE for all remaining portions of the CBP cargo process 25 months 36
  • 37. Questions? Visit http://cbp.gov/ace Or e-mail us at: ASKACE@cbp.dhs.gov 37
  • 38. PGA Data Processing: Architecture 38
  • 39.
  • 40. Food Safety and Inspection Service Food Safety and Inspection Service Pilot for PGA Message Set Bob Berczik International Relations and Strategic Planning Staff Office of Public Policy and Program Development Food Safety and Inspection Service, USDA 40
  • 41. Food Safety and Inspection Service: Mission in Action We are the public health agency in the USDA responsible for ensuring that meat, poultry, and processed egg products are safe, wholesome, and accurately labeled. • Federal Meat Inspection Act (FMIA), 1906 • Agricultural Marketing Act (AMA), 1946 • Poultry Products Inspection Act (PPIA), 1957 •Humane Methods of Slaughter Act (HMSA), 1958 • Egg Products Inspection Act (EPIA), 1970 Our Authority Through a series of Acts, Congress empowers FSIS to inspect all meat, poultry, and processed egg products in interstate commerce. 41
  • 42. Public Health Information System (PHIS) o Designed to collect, consolidate, and analyze data derived from both domestic inspection and foreign country inspection systems o Centralized computer database that generates random import inspection tasks and stores inspection results, based on: • Exporting country, process category, species, performance o Interconnected with US Customs and Border Protection’s (CBP) Automated Commercial Environment (ACE) o Pre-populates shipment data received from industry, enhancing controls and reducing fraud • PHIS connection to ACE • Partner Government Agency (PGA) Message Set  PGA Message Set Pilot underway with two brokers making entries at three POEs with nationwide implementation to follow o GOAL: to streamline the Customs entry process and transition away from paper – based application process for FSIS import inspection 42
  • 43. PHIS o Enables interface with U.S. Customs and Border Protection’s Automated Commercial Environment (ACE) system • Business-to-government exchange of shipment data • Provides FSIS Advance Notice when Customs entry filed • Replaces paper application for inspection (Form 9540-1)  Uses existing data collected by CBP  Incorporates FSIS specific data into the CBP standard data set (UN/CEFACT and WCO compliant) 43
  • 44. o Importers are required to apply for FSIS import inspection for all entries of meat, poultry, and egg products o An Entry or Entry Summary Certified for cargo release in ACE, combined with the PGA Message Set, will eliminate the need for paper applications • An electronic FSIS Form 9540-1 will expedite the clearance process on regulated shipments FSIS Import Application (FSIS Form 9540-1) 44
  • 45. o Electronic import application in PHIS retrieves data from ACE • PGA Message Set data completes the data fields missing from the FSIS import application o For example • Broker information provides local broker first name*, last name*, phone number,* email address* or fax number o *Data fields are required in PHIS import application • PHIS utilizes information to exchange electronic messages between FSIS and Trade Current Partial Data Feed 45
  • 46. Data Complete with Message Set PG19 CB PG21 LOCAL BROKER CONTACT INFORMATION – FIRST NAME AND LAST NAME, LOCAL PHONE NUMBER, AND E MAIL ADDRESS – MARTHA STEWART 313-666- 7777 JAS2@hotmail.com PG21 LOCAL BROKER FAX NUMBER IS 313-666-7771 46
  • 47. FSIS Data Grouping The PGA Message Set accommodates the following “many-to-one” data relationships: o Many inspection certificates to one entry • The PG 50 and 51 start and end the groupings • Multiple PG 14 (inspection certificates) may relate to the PG 13 (the foreign government that issued the certificate) o Many lots within one inspection certificate • The PG 50 and 51 start and end the groupings • Multiple data lines providing specific lot information are related to the PG 14 (inspection certificate) 47
  • 48. Foreign Inspection Certificates o FSIS requires all imported meat, poultry and egg products to be properly certified by the competent authority in the exporting foreign country o The electronic import application in PHIS uses a combination of information supplied in part from Trade and from the foreign inspection certificate • Currently PHIS receives official certification data electronically from Australia, New Zealand, and the Netherlands* • For shipments certified electronically, when importers/brokers identify the inspection certificate number through the PGA Message Set, FSIS PHIS will populate the import application based on the eCert data o Filers making entries from countries that do not certify shipments electronically must provide additional PGA Message Set data identifying product attributes *Note: FSIS will develop the capability to exchange official certification data electronically with other foreign governments 48
  • 49. FSIS Message Set Pilot o The FSIS PGA Message Set Pilot began on April 27, 2014 o FSIS pilot has two Customs brokers actively participating: • A.N. Deringer, Broker Filer, Code 551 • Barthco International Inc. dba OHL International, Broker Filer Code OHL • Customs brokers participating in the pilot have the option to file entries with or without the complete message set data elements o Pilot entries are at three ports of entry: • Champlain, NY, Port Code 0712 • Philadelphia, PA, Port Code 1101 • Houston, TX Port, Code 5301 49
  • 50. FSIS Message Set Pilot o From April 27, 2014 through September 4, 2014, the two participating brokers in the FSIS pilot have submitted a combined 109 entries through ACE utilizing the PGA message set representing 4.5 million pounds of product under FSIS jurisdiction o Entries filed are for product from Canada, Australia and New Zealand o Product from Australia and New Zealand are interfacing with government-to-government inspection certificate data exchange (eCert) 50 Message Set Entries by Import Country of Origin Canada (A.N.Derringer) Australia (OHL combined with eCert) New Zealand (OHL combined with eCert)
  • 51. FSIS Message Set Pilot o 87% of the pilot entries had no identified issues o 13% of the pilot entries to date had identified issues o Types of issues encountered: o Data mapping both internal to FSIS and external to filer software use o HTS conflict (1 entry) Note: No identified issues delayed shipment movement or reinspection of product by FSIS. No data transfer issues from ACE to FSIS have been identified. 51
  • 52. FSIS Message Set Pilot (software validations) o Automation of eCert pre-population of the application based on the PG14 record from the filer • 42 entries submitted validated the success of eCert filings from Australia and New Zealand systems. o Multiple inspection certificates (PG14) identified on a single entry • 6 entries submitted with multiple certificate numbers and PHIS created separate applications based on the PG14 records as expected o Increase shipment monitoring capabilities to prevent Failure to Present (FTP) • PG 30 record facilitates FSIS monitoring o Elimination of FSIS import inspectors to manually enter application data increases efficiency of reinspection process 52
  • 53. References o Data Samples and Guidelines for Using the PGA Message Set for Electronic Completion of the U.S. Department of Agriculture (USDA), Food Safety Inspection Service (FSIS) Application for Import Inspection (FSIS Form 9540-1) http://www.fsis.usda.gov/wps/wcm/connect/98c45f3c-8a5b-47d7-9907- 2fdc7352547f/Data_Samples_Guidelines_PGA_Message_Set.pdf?MOD= AJPERES&CACHEID=44196b9d-4fc1-45e0-a1de-eb3701385366 o Public Health Information System (PHIS) – Import Component http://www.fsis.usda.gov/wps/portal/fsis/topics/international-affairs/importing-products/ phis-import-component/CT_Index1 53
  • 54. FSIS Contacts Bob Berczik 202-690-4163 Robert.Berczik@fsis.usda.gov Mary Stanley 202-720-0287 Mary.Stanley@fsis.usda.gov 54
  • 55. EPA ACE Pilots: Looking for Volunteers Consumer Product Safety Commission Workshop on Electronic Filing Bethesda, MD September 18, 2014
  • 56. Topics • EPA-regulated commodities • What we are doing • What Trade can expect • Pilot programs • Trade Participation, Getting Started • Sample Message Set • Summary • Questions? 56
  • 57. 57 EPA-Regulated Commodities Under environmental statutes administered by EPA, six programs have import safety responsibility. Ozone Depleting Substances (CAA) Vehicles and Engines (CAA) Fuels (CAA) Toxic Substances (TSCA) Pesticides (FIFRA) Hazardous Waste (RCRA) • Statutory requirements are built on risks to human health and the environment. • Admissibility of EPA-regulated commodities are based on compliance to statutory requirements (reporting).
  • 58. ODSTS Verify PRISM 58 What We Are Doing: eFiling, Automated Processing Internet ODS Engines Pesticides Hazardous Waste WIETS Importers, Brokers, & Carriers Central Data Exchange (CDX) CBP & EPA Import Data Customs and Border Protection ACE Data Warehouse ACE/ITDS Single Window ABI Interface EDI ACE’s ESB EPA’s Network Node XML EPA Staff Streamline, improve reporting/processing of legal imports/exports • Paper to electronic filing (Entry, Entry Summary Certified for Release, Simplified Entry/Cargo Release) –Partner Government Agency (PGA) Message Set, Automated Broker Interface (ABI) • Validations to automate reviews for many EPA-regulated commodities • Electronic status messaging – ABI messages (including errors and clearance) • Updates, corrections – before arrival at, exit from ports Goal: Early indication reporting requirements are met BEFORE cargo is loaded on a plane, truck, train, or ocean vessel.
  • 59. 59 What Trade Can Expect: • Shortened review/processing time from current paper filings (in some cases from days/weeks to minutes/seconds) • Standardized filing process for EPA-regulated commodities at all Ports nationwide • Eliminate duplicate reporting to EPA, CBP • Eliminate courier fees • Error responses for invalid filings to provide specific information (data element level) • Ability to update and correct PGA Message Set filings (future)
  • 60. 60 Pilot Programs • Current pilots in production (April 30, 2014) – Ozone Depleting Substances – Vehicle and Engine Declarations  Starting in ports of Long Beach and Newark • Pilots planned for fall/winter 2014 – Notice of Arrival for pesticide imports  Starting in ports of Chicago, Port Huron, Newark – Hazardous Waste Exports (Spent Lead Acid Batteries)  Starting in ports of Hildago, Laredo • Get started now – PGA Message set samples, get going with software developers
  • 61. Trade Participation • What you will do – Create message sets – Submit Test filings to the Certification Environment in ACE – Receive, respond to Customs And Border protection (CBP) notifications if needed – File in Production • What you need to file (boiled down): – Ozone Depleting Substances (ODS): approved importer of record, quantity – Vehicle/Engine Declaration: Data from forms 3520-1 and 21; certification number – Pesticides Notice of Arrival: Data from form 3540-1; registration, producer establishment number – Hazardous Waste Exports: Consent number 61
  • 62. Getting Started 62 • Are you an ACE Filer? Talk to your CBP Client Rep. • Are you filing these commodities at these ports? • Confirm participation. – Current Pilots - Contact me and your Client Rep to get started. – Planned Pesticide Pilot - Respond to CBP-issued Federal Register Notice (expected Fall 2014), contact me. – Planned Hazardous Waste Export Pilot - contact me. • Work with EPA and your software developers. Begin identifying PGA Message Set adjustments to your software (EPA will work with you on examples).
  • 63. Sample PGA Message Set 1 2 3 4 5 6 7 8 9 10 1 2 3 4 5 6 7 8 9 20 1 2 3 4 5 6 7 8 9 30 1 2 3 4 5 6 7 8 9 40 1 2 3 4 5 6 7 8 9 50 1 2 3 4 5 6 7 8 9 60 1 2 3 4 5 6 7 8 9 70 1 2 3 4 5 6 7 8 9 80 O I O F F M O S Q U I T O R E P E L L E N T P G 0 1 0 0 1 E P A P S 1 Y P G 0 2 P P G 0 7 O F F M O S Q U I T O R E P E L L E N T P G 1 4 2 E P 8 6 9 3 4 0 - 8 P G 1 9 E P N 0 1 2 3 4 5 C H N 0 0 2 P G 1 9 C B S U P E R C U S T O M S B R O K E R A G E C O M P A N Y 5 0 0 E A S T 1 7 T H S T R E E T P G 2 0 1 0 0 N E W Y O R K N Y U S 1 0 0 1 2 P G 2 1 C B J O H N S M I T H 2 0 2 2 3 4 5 6 7 8 J O H N . S M I T H @S U P E R B R O K E R A G E . C O M P G 1 9 I M B U G S P R A Y I M P O R T C O M P A N Y 3 4 5 N E WB E R R Y S T R E E T P G 2 0 2 0 3 B O S T O N M A U S 0 2 1 0 5 P G 2 1 I M J A N E S M I T H 6 1 7 2 3 4 5 6 7 8 J A N E . S M I T H @B U G S P R A Y I M P O R T . C O M P G 5 5 N P C I P G 1 9 O V M A R I T I M E I N D U S T R I A L S H I P P E R S 6 0 0 P O R T R D P G 2 0 N E WA R K N J U S 2 0 0 3 4 P G 2 1 O V J A Y S M I T H 4 1 0 1 1 2 3 4 5 6 J A Y . S M I T H @M A R I T I M E S H I P P E R S . C O M P G 1 9 D E Q S U P E R I O R S H I P P I N G C O M P A N Y 4 3 2 P O R T B O U L E V A R D P G 2 0 L A P U - L A P U C I T Y P H 3 2 3 4 0 2 4 8 6 P G 2 1 D E Q J O H N R E Y E S 6 3 3 2 4 1 1 5 8 0 0 J O H N . R E Y E S @S U P E R I O R S H I P P I N G . P H P G 1 9 L G F A M O U S S T O R A G E A N D WA R E H O U S E 1 2 3 4 5 J E R S E Y A V E P G 2 0 N E WA R K N J U S 0 7 3 1 0 P G 2 1 L G M A R K 6 6 3 2 4 5 7 7 8 3 3 M A R K . J I M@T I M E . C O M P G 2 2 9 4 4 C I E P 3 Y 0 2 1 1 2 0 1 4 P G 2 6 2 0 0 0 0 0 0 0 0 1 0 0 0 O Z P G 2 6 1 0 0 0 0 0 0 1 0 0 0 0 0 B O P G 2 9 K G 0 0 0 0 0 0 0 2 8 4 5 3 P G 0 2 C C A S 9 4 2 7 1 - 0 3 - 1 P G 0 4 Y D E E T 0 1 5 3 7 5 7 P G 0 2 C C A S 5 2 3 0 4 - 3 6 - 6 P G 0 4 Y I R 3 5 3 5 0 3 5 0 0 0 0 P G 0 2 C C A S 1 1 9 5 1 5 - 3 8 - 7 P G 0 4 Y P I C A R I D I N 0 0 5 5 0 0 0 P G 0 2 C P C 0 0 6 4 9 1 P G 0 4 Y B T M O C R Y 1 F 0 0 2 1 0 0 0 8/28/2012 U.S. Environmental Protection Agency 63
  • 64. Summary • EPA and CBP are testing in pilots – Moving to eFiling, automated processing • Need Trade volunteers to test – eReporting, early filing, messaging – Look for Federal Register Notice for pesticides pilot – Contact your Client Rep and me if you are interested 64
  • 65. 65 For More Information Roy Chaudet Office of Information Collection Office of Environmental Information U.S. Environmental Protection Agency 202-566-1703 chaudet.roy@epa.gov
  • 67. www.anderinger.com © 2013 A.N. Deringer, Inc. CPSC - ITDS Heritage of Trust Since 1919 • Introduction/perspective • Timing & resources necessary to participate in FSIS pilot • ACE conversion • Software development • Testing • Additional data fields • How many additional data fields required • Additional time required to process shipment
  • 68. One U.S. Government at the Border September 2014 68
  • 69. 13th Term COAC 1 US Government @ TB November 2013 Public Meeting Recommendations Unified Filing of Entry Information Entry and PGA data sent well in advance of cargo arrival CBP and PGA review data in advance of cargo arrival, screening for data accuracy, importer & product compliance etc. Clear PGA responses to filer at the line level Sound Risk Assessment methodologies employed (prefer to use data not 69
  • 70. 13th Term COAC 1 US Government @ TB Trusted Trader Program  Expedited clearance for known importers  Leverage CBP and Trade’s investment in C-TPAT, ISA or FS Single Window Efficiencies  Collect only the data required and utilize data collected for other purposes for the PGA data whenever possible Consider alternative method of identifying importers/exporters/foreign facilities – DUNS number?  Risk Assessment Methodology system must be robust, recognizing compliant importers, 70
  • 71. 13th Term COAC 1 US Government @ TB Single Window Challenges Ability to timely obtain the right data from the actual importer well in advance of cargo arrival Key entry errors – they will occur! The more data required, (especially free form, not table driven) the greater the chance for errors Management of data across all PGA message sets will be a challenge to the entry filer and the importer. Data creep is a major concern for the trade community When data anomalies occur, immediate feedback to the filer must be given in form of 71
  • 72. Business Needs & Realities The Global Supply Chain is constantly evolving – legitimate trade should be managed as efficiently as possible Non-resident Importers of Record are becoming more common. Business to Consumer (B2C) shipments are increasing Trade moves 24/7 – need the PGAs to make admissibility decisions well in advance of arrival to keep goods flowing.  Set High vs Medium vs Low Risk Priorities and perform post entry audits.  Staged implementation (similar to APHIS 72
  • 73. Keys to Success Vigorous Trade Participation in ACE The more you test, the more you learn about the system, the process and the data requirements, and the more efficient the trade will become in managing the data.  Participation in PGA Pilots by Importers and Brokers who will be affected by the PGA message set for that Agency is critical to the success of the PGA Pilot.  Data Quality Issues can be addressed  Mutual Understanding of the Data Requirements and Commercial Availability of the Data can be achieved  The Pilot is an important exercise to ensure 73
  • 74. Thank You One U.S. “Efficient” Government at the Border Is our GOAL! 74