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.”