bp c-tpat

1
bp c-tpat validation experience

• Presentation to the ABA International Law Section
  
• 13 April 2005
• Aaron GothelfCustoms AttorneyBP America, Inc.

2
bp c-tpat validation experience

• About BP
• C-TPAT The Right Thing To Do
• BPs Experience in the Process (2003)
• BPs Experience Now

3
introduction to bp

• Statistics
• 200 billion Market Capitalization
• 174 billion Revenues
• 110,000 employees in 100 countries
• Well-established operations
• Europe, North South America, Asia, Australasia
  and Africa
• In business since
• Amoco 1889
• ARCO 1866
• BP 1909
• BP Amoco 1998

4
introduction to bp

• Statistics
• Daily production 1.9 million barrels of crude
  oil 8.6 billion cubic feet of natural gas
• Daily sales 6.2 million barrels of refined
  products
• Service stations 26,800 (USA 15,500, Rest of
  World 11,300)
• Exploration Active in 21 countries. Production
  activities in 22 countries
• Refineries (owned or part-owned) 21 (5 in USA, 15
  in rest of the world)
• Refinery capacity (BP share) 3.3 million
  barrels of crude oil a day

5
introduction to bp

• Supply Chain
• BP's transport network criss-crosses the globe.
• Own/operate 25,700 miles of pipeline, much of it
  in the US.
• Control an international tanker fleet of more
  than 40 vessels, either fully owned or on
  long-term charter.
• Once refining is completed
• Different products are moved to storage terminals
  by ship, barge, pipeline or rail.
• From there they are usually delivered to
  customers by road tankers.

6
bp and c-tpat

• History
• Decision to join made by BP Americas President
• Charter Member (1 of 7)
• First Member to become C-TPAT certified
• First to be Validated

7
bp and c-tpat

• Why?
• Good corporate thing to do
• Access to other Customs programs
• ISA
• Being in the Known Bucket
• Ease in applying our existing position

8
bp and c-tpat

• BPs participation
• Voluntary
• Challenged against Customs overbroad use of
  CF-28s to push participation
• BP was contacted in early January 2003 and asked
  if it would agree to be one of the initial C-TPAT
  validations.
• BP volunteered to be first and asked Customs to
  show up the following week.

9
the bp validation experience

• Customs team
• People
• Michael Pfeiffer, USCS Supervisory Inspector
• Jose de Jesus Lopez, USCS Chief Inspector
• Qualifications
• BP team
• Director of Customs
• Head of Tax
• Customs Attorney (Tax) Law Department
• Security Department Heads and Facility Managers
• HR

10
bp validation process

• C-TPAT
• Membership process already complete
• MOU signed (1/15/2002)
• Security profile reviewed
• Customs C-TPAT office reviewed the profile
• Possible results for any participant
• Accepted acknowledgement sent
• Rejected additional information is needed

11
bp validation process initial meeting

• Opening Meeting
• Held February 3, 2003
• Customs and BP teams met for the afternoon
• Presented the company background and supply chain
• BP concerns explained
• Compromised vessel or crew or port of unlading
  for bulk cargo
• Compromised containers for other heavy bulk
  materials

12
bp validation process site visits

• Site visits
• Purposes
• prove security profile is true
• Obtain suggestions from Customs for improvements
• Process
• Visit 2 sites 1 domestic and 1 foreign tour
  all aspects of security
• West Coast Refinery
• Included Refinery, Ship Terminal and Pipeline
  start
• Belgium chemical plant
• Included plant and tours of Antwerp shipping
  terminals and EU Customs officers

13
bp validation process site visits

• Site visits
• Results
• West Coast
• Proved security profile was true
• Security process and procedures found all in
  place
• Strengths and weaknesses in Customs perspective
  discussed
• Customs suggestions promised to be considered
• Belgium
• Same results
• Waiting on written report of findings
• Customs verbal comments

14
observations lessons learned

• Positive experience overall
• Spirit of partnership did exist
• Validated per the submitted profile
• Useful exchanges of ideas information
• Voluntary ness is still questionable

15
observations lessons learned

• Participation was not as difficult as it first
  seemed
• Processes exist for almost every company
• Security
• Procurement
• HR
• HSE
• Compare
• Corporate processes vs. Customs recommendations
• Fill in the gaps

16
observations lessons learned

• Control must be clearly identified
• What is in the companys control
• Internal security
• Site security
• What is not in the companys control
• External area
• Neighbors
• Geography

17
open issues

• Foreign visits
• Scheduling
• Cost effective for Customs
• Cost effective for participant
• Failure to obtain permission to enter
• Mexico Honduras
• Other companies being validated have noted
  several failures by Customs to obtain proper
  permission to enter certain countries including
  Honduras and Mexico, thus ending any possibility
  of validating those sites
• No explanation given as to whether this puts the
  validation on hold

18
the bp future with c-tpat

• Participation will continue
• Strong belief C-TPAT is the right thing
• Desire to improve the program
• Expressed concerns
• Improve C-TPAT program
• Aspire to participate to the fullest extent
• Desire to maintain program within the bounds of
  the law
• Voluntary program nothing to lose

19
future at international level

• Many countries working on similar programs.
• World Customs Organization 161 customs agencies.
• Working on advance manifest data
• Development of a standardized C-TPAT type of
  program.

20
thank you

• QA