Sludge Watch ==> Trash and Sludge Trucks into USA - will need new Security Clearance Program

[maureen.reilly at sympatico.ca]

Sludgewatch Admin:

Looks like Toronto sludge and trash needs to make new arrangements for 
border clearance, since the current automated border cargo release program 
is expiring next month.

This story is a bit technical...so there is an expanation of the terms below 
the story. Sending sludge into the US looks like it will be more difficult.

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http://www.todaystrucking.com/news.cfm?intDocID=16510


Truckers hauling waste to U.S. granted reprieve from PAPS switch
07/27/2006
TORONTO -- U.S. Customs will delay terminating solid waste shipments from 
the BRASS "line-release" clearance program.
Thanks to lobbying by the Ontario Trucking Association, CBP has granted a 
one month extension -- from July 31, to Sept. 1, 2006 -- for carriers 
hauling municipal solid waste shipments of "Common Commodity Classification 
Codes" to switch to PAPS when transporting to the U.S.

At that point all C-4 codes using the MUW (Municipal Solid Waste), WQC 
(Sewage Sludge) and CS3 (Construction Debris 2) product identifier will be 
removed from the BRASS database.



Providing the supply chain only three weeks notice for a
policy change such as this was simply not practical, says OTA
It is rumored that the phasing out of BRASS for trash shipments was 
expedited, in part, for political reasons. Last week, the Senate passed a 
bill -- at the urging of Michigan legislators -- requiring CBP to review its 
screening process for municipal solid waste. If a system isn't developed 
soon, the proposal would require Homeland Security to stop trash trucks from 
entering the U.S. altogether.
Politicians are concerned that BRASS does not provide Customs with the 
advance cargo information needed to conduct a proper risk assessment.

CBP will continue to allow the use of BRASS for municipal solid waste during 
the extension, but will provide notices to drivers reminding them of the 
change.

"The trucking industry has known for sometime that BRASS would be phased 
out; but the schedule for phase-out has been a significant unknown," said 
OTA president David Bradley. "Providing the supply chain with three weeks 
notice for a policy change such as this was simply not practical from a 
training and awareness perspective -- drivers need to be educated on the 
PAPS system and custom brokers and their customers have to make adjustments. 
The one month delay will allow a smoother transition for all involved in the 
municipal waste supply chain."

Another issue is that shippers will have to make new arrangements with 
brokers to ensure PAPS transmissions are filed within the time window that 
CBP allows before cargo arrives at the border. This was arguably the largest 
hurdle for non FAST-approved carriers and their customers when PAPS began 
replacing BRASS at some major border crossings earlier this year.

OTA also pointed out the need for a similar communication process whenever 
CBP is planning to introduce changes impacting carrier operations.

"OTA appreciates the complexity of introducing changes that may impact 
multiple parties in the supply chain. And I think we have a reasonable 
appreciation, from the outside, of the sorts of pressures the agency is 
under to get things done," added Bradley. "We have in the past, and will 
continue in the future, to offer to work with CBP in the development of 
meaningful but realistic timelines that recognize the challenges inherent in 
the supply chain."






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http://www.livingstonintl.com/traderesourcesb.cfm?name=BRASS&pageid=2996&action=published

GLOSSARY > WHAT IS THE BORDER RELEASE AND SELECTIVITY SYSTEM (BRASS)?


Border Release and Selectivity System (formerly known as Line Release) is an 
automated cargo release system implemented by U.S. Customs and Border 
Protection (CBP) for the release of merchandise that Customs deems to be 
repetitive, low risk and high volume. With bar code technology, cargo 
release processing is completed in a matter of minutes.

BRASS Processing
The bar code technology used in this program incorporates a label, commonly 
referred to as a C-4.  Information on the C-4 label includes the shipper or 
manufacturer, importer of record, customs broker and tariff classification 
for the invoiced merchandise. The label is stapled to each export commercial 
invoice and is scanned by CBP upon arrival at the border, providing 
sufficient information to permit cargo release to occur within minutes.

A single C-4 bar code label may accommodate a range of tariff classification 
within a four-digit heading, allowing for multiple commodities within the 
same shipment to be released under a single bar code label.  In cases where 
a shipment consists of multiple tariffs (outside the four digit heading), 
multiple C-4 bar code labels can be used.

Merchandise imported under BRASS is generally released without further CBP 
processing. However, Customs and Border Protection can choose to inspect any 
BRASS shipment. Examinations may either be specified by the Customs officer 
or random.

Caution must be used to ensure the C-4 bar code is attached only on 
shipments containing the commodities covered within the approved tariff 
classification range of the C-4 label. Failure to do so can result in 
penalties and revocation of BRASS privileges.

Current Status
CBP is not currently accepting new applications for BRASS.  Those importers 
who are currently using BRASS may continue to do so.  However, to remain in 
the program the importer must have a minimum of 50 entries per year, and 
must maintain its compliance level with CBP.