CPSC Reports on Risk Assessment Plan for 100% of Shipments, New Port Staff
The Consumer Product Safety Commission has posted a report to Congress on the establishment of a Risk Assessment Methodology (RAM) to systematically analyze 100% of shipments within CPSC’s jurisdiction to ensure that adequate resources are dedicated to the highest risk shipments as indicated by targeting rules. CPSC believes that this system would result in less “port shopping” and more inspection and sampling, but would also allow consistently compliant products to move faster through the ports.
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CPSIA Requires RAM and Integration with CBP Systems
The Consumer Product Safety Improvement Act of 2008 requires CPSC to formulate the RAM, to thoroughly analyze how to integrate this system with other systems utilized by U.S. Customs and Border Protection, and to recommend any statutory changes required to fully implement it. CPSC seeks to improve the current model, which includes CPSC end-users manually using CBP applications or requesting ad hoc data extracts from CBP, in order to utilize standard, specified data interfaces that would align with CBP’s Automated Commercial Environment (ACE) modernization effort.
Wants $40M over 7 Years for Risk Technology, 100 More Port Investigators, Etc.
To achieve this in the most efficient manner, CPSC anticipates the need for a Commercial Off the Shelf (COTS) RAM solution, which it estimates would cost $40 million over a seven year timeframe (fiscal years 2013-2019). In addition, CPSC staff recommends that the number of compliance investigators at the ports be increased by 100 over a seven year timeframe and 234 support staff added (compliance officers, lab personnel, etc), at a total estimated cost of $250 million.
Predicts Product Inspections and Sampling Would Increase 500%
With increased staff and RAM technology, CPSC staff projects that product inspections would increase by 500%, from 7,000 to 42,000 inspections per year, and that the number of products sampled would increase from 1,750 to 10,500 per year, also a 500% increase.
Would Rotate Some Investigators to Prevent “Port Shopping”
In addition, a small number of the new port investigators would be staffed to cover on a rotational basis other medium-volume ports where CPSC staff would still not be permanently co-located. This would protect against importers intentionally sending products to ports without co-located port investigators (“port shopping”) and would provide additional coverage of special high-risk products that are imported at particular ports.
Hopes to Test the Concept in Fall 2011
In the fall of 2011, the CPSC is hoping to test a Limited Proof of Concept (LPOC) application. The goals for the LPOC are to provide easy access to the risk scores and analysis details of entry lines and enable Import Surveillance Investigators to review entry lines and transition them through the workflow. It is also intended to provide a single, shared view of entry line data and analysis and workflow transitions, and provide basic metrics and reports concerning workloads and entry line actions.
CPSC and CBP to Begin Adopting Processes, Data Management Improvements
CPSC and CBP staff would also have to revise existing processes and develop new ones to ensure effective use of the RAM technology. These new and revised processes would encompass Entry Line Evaluation, Entry Line Targeting, Request and Establishment of CBP Holds, Sample Collection, Sample Analysis, and Compliance Evaluation and Enforcement.
(See ITT’s Online Archives or 09/19/11 news, 11091916, for related BP summary of statutory changes suggested by CPSC to implement the RAM, strengthen its border enforcement authority, and allow it to operate more consistently with CBP.)