C-TPAT

Thank you for your interest for information concerning the U.S. Customs and Border Patrol’s Customs-Trade Partnership Against Terrorism (C-TPAT). As a business of Celanese Corporation, Ticona is committed to protecting the environment, preserving the health and safety of our employees and communities, and assuring the safe operations of our processes.

Ticona’s parent company, Celanese, is a member of the American Chemistry Council (ACC). Following the terrorist attacks of Sept. 11, 2001, without waiting for legislation or other federal directives, ACC initiated its mandatory Responsible Care® Security Code (RCSC) to protect member company communities, employees, products, and facilities. The code covers site, cyber, and transportation security. On December 8, 2004, the U.S. Office of Customs and Border Protection (CBP) determined that the ACC’s RCSC meets key requirements. Further, per Robert Jacksta, Executive Director, Border Security and Facilitation:

"CBP commends ACC members for taking immediate and significant action through the Responsible Care Security Code to enhance the security and safety of their facilities and supply chains.. “ACC members, in fulfilling their obligations under the Responsible Care Security Code, are implementing a documented and verifiable security/safety program to enhance security procedures throughout the supply chain.”

As a business of Celanese Corporation, Ticona follows the guidelines provided by the ACC’s RCSC.  Our evaluation of C-TPAT shows that converting to C-TPAT would not be a positive step in the right direction with the current success of RCSC.  Based on the CBP’s Cost/Benefit Survey from 8/2007:

• For importers, like Ticona, supply chain average annual expenditures doubled, with the median increasing 5 fold with the implementation of C-TPAT.
• Less than one-third (32.6%) stated the benefits of C-TPAT outweighed the costs.
• Only about one-third (35.4%) reported that their participation in C-TPAT has decreased their number of CBP inspections.
• Less than one-quarter (24.3%) indicated that their participation in C-TPAT has increased their ability to predict lead-time.
• Less than 3 out of 10 (28.9%) reported that their participation in C-TPAT has decreased the disruptions in their supply chain.

The following are pertinent links to information about ACC, RCSC, C-TPAT, and our commitment to secure operations:

American Chemistry Council’s RCSC/C-TPAT Press Release http://www.americanchemistry.com/s_acc/sec_news_article.asp?CID=206&DID=2351

U.S. Custom’s and Border Protection C-TPAT Cost/Benefit Survey http://www.cbp.gov/linkhandler/cgov/import/commercial_enforcement/ctpat/ctpat_cost_survey.ctt/ctpat_cost_survey.pdf

Celanese ESHA http://www.celanese.com/index/about_index/ehs.htm

American Chemistry Council RCSC http://www.americanchemistry.com/s_responsiblecare/doc.asp?CID=1298&DID=5085

Based on our extensive analysis, we have decided not to pursue C-TPAT certification at this time.  We will instead continue to meet high security standards throughout our supply chain under the guidance of Responsible Care.

Any further questions may be directed to Thomas Hannigan, Leader, Quality Management at Ticona or to Celanese / Ticona media relations departments.

Sincerely.

Donald V. Shattuck

Ticona Supply Chain PI Manager