Fall 2012

THE FORWARDER The Voice of Freight Forwarding in Canada

Celebrating Excellence ❯ New Security Requirements Air Cargo ❯ eManifest Critical Flaw ❯ Cargo Control & Sufferance Warehouse Modernization

Canadian International Freight Forwarders Association 170 Attwell Drive, Suite 480, Toronto, Ontario M9W 5Z5 Tel: 416-234-5100 • Toll Free: 866-282-4332 • Fax: 416-234-5152 • [email protected]

Gerry Kopelow

Connect. Located at the heart of North America, connecting Winnipeg to trade networks around the globe, Winnipeg Richardson International Airport is the third busiest Canadian airport in terms of cargo volume. Winnipeg Richardson International Airport is your gateway to economic opportunities. Visit www.waa.ca/business www.waa.ca/business to learn more.

Operational 24 hours a day, 365 days a year.

THE FORWARDER Fall 2012

At A Glance

ciffa.com

05

Editorial

25

Golf, Golf, Golf

06

New Security Requirements Air Cargo

28

FIATA World Congress Report

08

eManifest Critical Flaw

30

Mark Your 2013 Calendar Now

10

Cargo Control & Sufferance Warehouse Modernization: Modern or Medieval?

33

Meet Transport Canada’s Requirements for Handling Dangerous Goods with CIFFA Training

12

triOS College Delivers Supply Chain Interns with CIFFA Certificate

34

Western Region Christmas Lunch

35 14

FCA Winners and Sponsors

What New Members Say About CIFFA: AllCargo Express Inc. Becomes a Regular Member

17

News From the Annual General Meeting

36

Current Individuals Who Hold the CIFFA PFF Designation

20

Eastern Region Welcomes New Chair 37

20

CIFFA Seeks Volunteers to Join the Eastern Region Committee

Guidelines for Regular Membership in CIFFA: Building Strength From Within

38

Plan Your Advertising Budget with CIFFA

22

The Future Belongs to the Grads

THE FORWARDER The Voice of Freight Forwarding in Canada • Fall 2012 Canadian International Freight Forwarders Association 170 Attwell Drive, Suite 480, Toronto, Ontario M9W 5Z5 Tel: 416-234-5100 • Toll Free: 866-282-4332 • Fax: 416-234-5152 • Email: [email protected]

Thank You, 2012 National Sponsors One Sponsorship, Three Regions

CIFFA gratefully acknowledges the contribution and support of the 2012 National Sponsors in making the regional events a great success. W ith two levels of sponsorship - Diamond and Ruby tising reach. you can choose the extent of your adverrti

Diamond Sponsors

Ruby Sponsors

Media Sponsor:

Preferred Vendor:

For More Information: [email protected]

3

www.cratex·nd.com ISFMI 10. Compl i ant

THE FORWARDER Fall 2012

Editorial What do Maggie Thatcher, Angela Merkel and Donna Letterio all have in common? Yes, they are all first time female leaders. Donna joined the ranks of those august women when she became CIFFA’s first female President of the Board at the AGM in May. (OK, leader of CIFFA may not be quite the same as leader of the UK or Germany, but you get my drift.) Check out Donna’s bio in the pages on the Board updates. This year has seen brilliant gala FCA dinners, competitive and exhilarating golf tournaments, impressive graduation evenings and a fun boat cruise. This issue of The Forwarder celebrates the successes of our Regional volunteers in organizing and hosting these networking events that we count on to build community and promote the spirit of the association. We thank the volunteers and everyone who purchased tickets. Volunteers + National Sponsors + Event Sponsors + Member Participation = Success On a more sober note (no pun intended) the past six months has seen a big spike in activity by the association as we deal with regulatory and carrierrelated activity. During the summer we worked closely with freight forwarders in Montreal and with the CBSA in Ottawa to bring some reason into a CBSA requirement regarding seal numbers on re-manifest documents. The final result, to delay the requirement while CBSA national standards are reviewed with the new end vision in mind, was acceptable to everyone. Not all issues can be dealt with so easily or quickly. (If six months and serious head banging could be called quick or easy.) At fall consultations Transport Canada unveiled the final round of regulatory changes for the Air Cargo

Security Program. For many of us who have been working on air cargo security since 2006, we continue to see challenges. The article submitted by Transport Canada ‘New Security Requirements in Air Cargo’ brings us up to date, while some of the smaller sidebar items draw Member attention to new changes scheduled for December 31, 2012 and December 31, 2013. As promised, in September the CBSA released the eManifest HBL eCCRD. The new forwarder HBL Portal and voluntary data submission will be available in April 2013 and eManifest HBL will be mandatory in all modes by July 2014. At the last eManifest Design Meeting in September, CIFFA became aware that the eManifest Design team is programming to today’s warehouse and cargo control polices – for a system that should be programmed to meet future policies and regulations. Our letter to the CBSA, ‘eManifest Critical Flaw’ gives a heads up to possible problems inherent in the design and calls upon the CBSA to find a solution before we are so far down the programming road that change is impossible. I hope you enjoy this Fall 2012 issue of The Forwarder.

Ruth Snowden, Executive Director

Register Now and Work Towards Your Certificate REGISTRATION NOW OPEN Essentials of Freight Forwarding (EFF) and Supply Chain Management and Marketing (SCMM) Deadline for January start is December 15th ONLINE OPTION ™ALL NEW COURSES: more videos, narration, additional industry site resources, and new layout.  Online workbooks for additional practice for exams ™ preparation.  Online exams - open book, receive grades instantly, and ™ take the exam from ANYWHERE.   ™Instructor- led reviews to answer all your questions or  review for exams via webinar or conference call. conference call. call. conference

CLASSROOM OPTION C ™ C Great instructor led courses once per week, group

 exercises, response cards, textbook(s). e New e ™ Online workbooks to replace paper-based  binders. b b ™Online exams - open book, receive grades instantly, and   take the exam from ANYWHERE. ™  Montreal - Toronto - Vancouver.

Register Online: http://ciffa.learning.com Register Online: http://ciffa.learning.com Register Online: http://ciffa.learning.com

5

THE FORWARDER Fall 2012

New Security Requirements Air Cargo Submitted by Transport Canada

On December 31, 2012, the minimum percentage provisions will expire along with Known and Unknown Shipper protocols. These changes will require Approved Participants and Air Carriers to secure 100% of cargo being loaded on domestic and international passenger flights departing CATSA designated airports. This means that all cargo transported on domestic and international passenger flights must come from a Registered Shipper or be actively screened using one of the approved screening methods in the Security Measures Respecting Air Cargo (SMRAC). Registered Shippers may tender directly to the Air Carrier or through an Approved Participant. These requirements, combined with the current 100% secure cargo requirements for transborder passenger flights, allow for the strengthening of the secure supply chain in Canada.

Whats Next Transport Canada is currently holding public consultations across the country to design the next phase of the Air Cargo Security (ACS) Program to align Canada's program with the programs of the United States and key trading partners. Focused on the development of regulations to enable shippers to screen their own goods and the certification of third party service providers, these regulations will expand the secure supply chain and allow convenient and cost effective screening. The regulations will be complemented by a set of standards that are also under development. More information on the proposed regulations and the consultations can be found at: www.tc.gc.ca/aircargosecurity

Get Ready for December 31, 2012 Freight forwarders – 1. Communicate with your agents and your customers. 2. Review your quotation processes and the fine print on your quotation forms. 3. Prepare now by training your customer-facing staff. Review your customer contracts, special rates and agency agreements. Remember that cargo from a shipper who is not a Registered Shipper could only be consolidated with secure cargo from a Registered Shipper after it has been screened by one of the four approved ‘active screening’ methods for international or domestic passenger flights. The screening must be done by the airline or by a Transport Canada approved screening facility (none of which exist at time of writing although some applications are in the queue at Transport Canada). Essentially, this means that

6

cargo from a shipper that is not a Registered Shipper cannot be consolidated with secure cargo from a Registered Shipper – or the entire consolidation must be ‘actively screened’. The exception might occur if the Approved Participant or its TPSP warehouse was approved to screen cargo and could screen before consolidation. Then, cargo from a shipper could be consolidated with cargo from a Registered Shipper and tendered as secure for a domestic or international flight. What no one would want is to have an entire consolidation screened by the airline simply because there is one shipment from a shipper who is not registered. Look at the language on your quotations. Do you mention the need for the shipper to be a Registered Shipper? Consider amending your quotations. Example: “Cargo from shippers not Registered with Transport Canada may not be eligible for consolidation”.

THE FORWARDER Fall 2012

Where are the Screening Facilities?

How to Become a Member of the ACS Program Shippers can apply to the ACS Program to become a Registered Shipper. If a shipper is not part of the ACS Program, their cargo must be screened by an Approved Participant or an Air Carrier prior to uplift on a passenger flight. Freight forwarders, screening facilities and cargo handling agents can apply to the ACS Program to become Approved Participants. This includes any entity that intends to accept cargo for transportation by air, screen in accordance with prescribed methods and/or tender the cargo as secure prior to uplift on a passenger flight. Apply online at www.tc.gc.ca/aircargosecurity or contact the ACS Support Centre toll-free at 1-866-375-7342 or by email at [email protected]. The ACS Program is working with industry to develop a program that meets the highest standards, reduces risks to the safety and security of the traveling public, and keeps goods moving in and out of Canada efficiently – helping our economy and positioning Canada as a strong partner in global efforts against terrorism. ■

During the public consultations Transport Canada held across the country this fall, we learned that some freight forwarder Approved Participants (AP) have applied to conduct active screening. Some Third Party Service Providers have also applied to become Approved Participants. Once AP, these companies could also apply for approval to conduct active cargo screening. CIFFA encourages Transport Canada to move quickly to get these AP and TPSP AP screening facilities up and running before the December 31, 2012 deadline. Nobody in the air export world can afford uncertainty or delays.

More Regulatory Change Expected At public consultations in September and October Transport Canada drew a picture of the final vision of Air Cargo Security in Canada. The Security Measures Regarding Air Cargo, affectionately known as the SMRAC will receive their fifth amendment as we go to print with this magazine. Not expected to be significant, these amendments will likely introduce minor changes, such as updated security requirements for human remains. More significant will be the draft regulatory changes to the Canadian Aviation Security Regulations which are expected in the Canada Gazette Part I in the spring of 2013. Here we will see air cargo security in its near final form, with changes to language and to participants. Some things we might expect to see for January 2014: • Approved Participant to be re-named Regulated Agent

CIFFA Endorses Direct Regulation of Third Party Service Providers Last July CIFFA prepared a submission to Transport Canada regarding the fall consultations on the changes to the Security Measures Respecting Air Cargo and the regulating of Third Party Services Providers (TPSPs). The Association and its Members strongly support bringing TPSP’s under the regulations, responsible to Transport Canada in their own right. The submission at www.ciffa.com/issues_air_cargo_security.asp fully explains the reasoning behind this position.

• Registered Shipper to re-apply and may become an Account Consignor • TPSP may be eligible to apply for direct oversight by Transport Canada as a Certified Agent • Those few shippers who are willing and able to conduct physical search of their goods while doing final packaging, may apply to become Known Consignors – under the direct oversight of Transport Canada and subject to training requirements, background checks and other security requirements. Full details are on the Transport Canada website.

7

THE FORWARDER Fall 2012

eManifest Critical Flaw Dear CBSA Directors General As you may know, CIFFA represents some 250 international freight forwarding companies in Canada. On behalf of our Members, we have been actively engaged with the eManifest project since the inception and have participated at every design meeting since 2008. We were disappointed that at the September Design Working Group meeting, after a gap of one year without any formal meeting of this group, certain elements were no longer in line with previous commitments from the CBSA. A listing with additional background of some of CIFFA’s concerns is provided on the ANNEX at the end of this letter.

aligned across the CBSA’s functional silos, it will be difficult, if not impossible, for CIFFA Member firms to make business decisions affecting company plans over the next few years. Many CIFFA Member firms also hold sufferance CW warehouse licenses and are now having to plan and budget both money and resources for potentially three system changes over the next two years without having clear rules in place to base their business decisions on. Our fear is that unless policies are aligned today to meet tomorrow’s needs, we will fail to achieve the benefit of eManifest.

This close to the end of an arduous design process, it is also shocking to learn that eManifest is being programmed to meet today’s warehouse, cargo control and import policies and regulations – and not being designed for the future. Industry has collaborated with the CBSA to create what we thought would be an eManifest design for the 21st century. We have been working towards a system that provides the data needed to keep Canadians safe and which allows for efficient processing of Canada’s inbound cargo. It is not too late, but the CBSA must act decisively and act now to avoid creating a critical flaw with eManifest.

After years of extensive industry / government collaboration we have an opportunity with eManifest to bring Canada’s inbound supply chains to a new level of efficiency, creating value for industry and improving Canada’s competitive trade position. We have an opportunity to create transformational change. These policy issues, if not addressed quickly, could create critical flaws that wipe out the commercial advantage eManifest should be designed to create. To validate the massive investments of time and dollars from all stakeholders and Canada’s tax payers, the CBSA at the highest levels must get it right and must get it right now.

The CBSA units responsible for warehouse, cargo control and import policies have known for years that change was coming. eManifest has not been designed in a vacuum. It has not been a secret that the CBSA was designing eManifest for a paperless future. Urgent policy revisions, aligned with the eManifest vision are needed. The eManifest design team must have the authority to program eManifest to the future end state vision.

We strongly urge the leadership of the CBSA to address the crossfunctional policy revisions that must be made now in order to make eManifest effective in 2014 and beyond. We welcome the opportunity to discuss our concerns together with CBSA to ensure the success of the eManifest project.

At the last Design Working Group meeting, the CBSA eManifest team issued various ECCRD documents with programming requirements based on warehouse policies as they exist today. CBSA, through the BCCC Sub-Committee on warehousing, has already recognized that these current policies and processes are archaic and were written to reflect commercial practices in place over twenty years ago and no longer reflect today’s quite different business needs. Until policies are

Sincerely, CIFFA

H. Ruth Snowden Executive Director

E E

Annex 1. We learned that the HBL eCCRD contains different definitions of Shipper and Consignee in Appendices A and B, and that neither of these definitions is as previously discussed and agreed. In addition, CBSA advised at the DWG meeting these definitions would be aligned as one consistent definition within a second ECCRD on multi-modal HBL due to be updated in July 2014. These definitions will apparently be decided by CBSA lawyers. Our concern is that these definitions will not be in line with how CIFFA conducts business based on Contract of Carriage rules we are legally required to adhere to as previously presented to CBSA.

8

Paul Hughes Paul Hughes Paul Hughes Customs Committee Chair Customs Committee Chair Customs Committee Chair

Annex Annex

M

M

2. At the previous DWG meetings in September 2011 we were presented with the understanding that if cargo is to be released at M an inland port the HBL data gives that Port (i.e. 395) and a related sub-location code; that if a container is consigned to Toronto it will M go to Toronto where it will be unloaded. If there are 10 HBLs on that container, 5 for Toronto and 5 for Montreal the 5 Toronto HBLs will have Port 495 and a Toronto sub-location code while the 5 Montreal HBLs will have Port 395 and a Montreal sub-location code. There is no need for re-manifesting in this scenario and this is how we have been informing CIFFA Members in presentations throughout the last year.

THE FORWARDER Fall 2012

A year later without any further consultation with Trade, CBSA informs us this will not be the case and this will be covered by electronic Re-Manifesting as a direct result of the work of the CC&SWM unit not tying into the work of the eManifest design group. 3. Another example concerns commercial examinations and where they would occur. If the new system is designed to meet today’s policies, we could potentially face gridlock at every First Port of Arrival. Health, Safety and Security (HSS) needs dictate examination at FPOA. However the policy on what constitutes HSS versus what constitutes commercial examination at designated release port / sub-location code requires clear definition for clarity to Trade. ■

eManifest eManifest Design Advance Working Group Commercial (Highway) Information Air eManifest Advance Stakeholder Commercial Partnership Information Network Marine (eSPN)

After years in development voluntary participation in the freight forwarder HBL eManifest will pop up with the tulips in April 2013 and will become mandatory for all modes in July 2014. This is not just a tweek to ACI Air and Marine. This is significant change. The HBL eCCRD was released in September and is available now from the CBSA at [email protected] Last spring CIFFA held eManifest information sessions across Canada in Montreal, Toronto and Vancouver to introduce eManifest to the broader community. The sessions were moderated by CIFFA Executive Director, Ruth Snowden with presenters Ralph Bishop, Director Stakeholder Consultations and Implementation Division eManifest & Major Projects Directorate, Programs Branch CBSA and consultant Oryst Dydynsky, Descartes Systems Group. Participants at the Montreal eManifest session raised several issues. Some things to think about as we head into voluntary implementation: • Mandatory 10 digit HS# for importer Advance Trade Data when ATD becomes mandatory • Sufferance warehouse and cargo movement

End Vision

Secondary Reporting

eManifest Highway

(2015)

(March 2013)

Importer ATD (2014)

eCCRD (Fall 2012)

2004

HBL eManifest Arrives Next Spring!

eManifest Design Working Group (Secondary Reporting)

2006

2008

2010

2012

2013

2014

2015

Cargo Control & Sufferance Warehouse Modernization

• policies, inland commercial examinations, electronic arrivals / RNS (see CC&SWM) • Release at First Port Of Arrival (FPOA) – impacts on consolidations • NVOCC and Co-Loaders: Non-Bonded 8000 data providers can’t move cargo beyond FPOA • Co-loaders MUST be bonded 8000 • Should CIFFA provide a list of 8000 bonded forwarders on the site • New definition of freight forwarder and impacts of regulatory change • Freight forwarder will be ‘a person’ under the Customs Act, responsible for books and records • Agency agreements, use of your bonded 8000 # • Who will do your data entry • ACI Marine or Air + port of clearance + subloc code + on your 8000

9

THE FORWARDER Fall 2012

Cargo Control & Sufferance Warehouse Modernization

Modern or Medieval? Now that eManifest is becoming a reality, Highway eManifest becomes mandatory November 1, 2012, the CBSA has suddenly realized that radical change is needed to the way we handle and report bonded cargo in this country. Last spring, the CBSA created the Cargo Control & Sufferance Warehouse Modernization unit, with a corresponding BCCC Sub-Committee. Wayne Bibeau, OEC Group and Ruth Snowden represent the freight forwarders on this CC & SWM Sub-Committee.

CIFFA’s Cargo Control & Sufferance Warehouse Modernization Working Group Wayne Bibeau, OEC Overseas Express Consolidators (Canada) Inc.

The CBSA is grappling with significant change and to date, has not moved forward on revisions to policy and regulations that will adequately prepare the ground for eManifest. The agency seems to struggle with the final word of the title – Modernization. The industry and the country must have guidance now on fundamental questions that will shape policy for the future. And that future is less than two years away. Modernization must mean simplification, red tape reduction and efficiency. How will the CBSA conduct cargo examination in the future? How will goods be ‘arrived’ and ‘released’? Will sufferance warehouses exist? How will goods be moved ‘beyond the border’? The work of the CBSA’s new Cargo Control & Sufferance Warehouse Modernization unit is seen as critical to our industry – and to the full implementation of eManifest. We need to achieve efficiencies and modernization in order to achieve the benefits. The CBSA cannot be allowed to design an eManifest system based on today’s cargo control and warehouse policies and regulations which are outdated, redundant and inefficient. Eleven industry representatives provide CIFFA’s input to the CBSA, through participation on the CIFFA CC & SWM Working Group and have shared the following.

CIFFA’s Guiding Principles for CC & SWM • Must keep the cost down to our clients (importers and exporter) • Must ensure the integrity of the freight we handle so as to limit loss, damage and delay • Must avoid moving the freight unnecessarily. Any additional handling must be eliminated where possible. • Must give the freight forwarder the flexibility to provide consolidation and deconsolidation services in locations that meets its business needs. • Must allow competition across a level playing field • Must reduce administrative burden throughout the inbound supply chain

10

Ferris Abraham, Simard Westlink Inc. Daniel Bineau, Groupe LaFrance Gus Pazmino, Interactive Freight & Warehousing Ltd. Romas Krilavicius, Rutherford Global Logistics Rodrigo Gomez, Traffic Tech Inc. Chris McGuiness, DHL Global Forwarding (Canada) Inc. Ryan Henriques, Panalpina Inc. Sally Richardson, Overseas Container Forwarding Inc. Bruce Allan, DB Schenker Tish Kumar, TDK METRO Terminals

“The line between disorder and order lies in logistics.” - Sun Tzu (b. 544 BC)

“We draw the line.” Supply Chain Managemen Managementt - Freight Forwarding - Field Logistics Staffing - Courier - Cargo Services Services

[email protected]

www.bbex.co www.bbex.com m

THE FORWARDER Fall 2012

triOS College Delivers Supply Chain Interns with CIFFA Certificate triOS College, a CIFFA educational partner, is dedicated to preparing students for success in their career, including freight forwarding. The college offers a 50-week supply chain diploma program that integrates a 16-week internship. The internship is a hallmark of the school’s success and commitment to its vision of “sharing our knowledge and passion for excellence”. Benefit from this dedication by hiring a triOS supply chain intern. CIFFA: In 2011 triOS was recognized as one of Canada’s top 50 Best Managed Companies. What sets you apart from the other players in the private college industry? triOS: It was certainly an honour to be one of the only companies in the education sector to have ever been selected, for two years running, as one of Canada’s 50 Best Managed companies. As the largest Canadian-owned Career College in Ontario, we offer: • Highly flexible learning options for students who wish to enroll in our programs • Frequent program start dates so that students don’t have to wait to start their new career • Internships with virtually every program so that our students gain great work experience prior to graduation • Close partnerships with employers in Canada so that we can save employers time and money when they recruit our graduates.

❯

CIFFA: Can you briefly describe the goals for the triOS Supply Chain & Logistics (+ Internship) program? triOS: Our goal for students is that they graduate from this program with the competencies and motivation to work in a variety of careers in the supply chain sector. Our goal for employers is that they benefit from combined transferable skills as well as the newly acquired skills that our students can bring into their organizations. triOS graduates are educated to work specifically in this sector. Our students are prepared, immediately upon graduation, to fill the skills gap of today and can become the future leaders of tomorrow. CIFFA: What are the benefits for CIFFA member firms to participate in the triOS internship program? triOS: During the four-month internship, our students become integral members of the organization’s team and help complete projects that otherwise would not have been completed. Providing students with an internship can be a great way to recruit future talent. Many organizations leverage the internship as a four-month interview to hire the right individuals into their company. Providing internships is also a great way for an organization to market their company and its services. Providing

Our employer partnerships are critical to our program development. We want to ensure that our programs offer the leading skills employers need to hire for their teams. CIFFA: One of your stated goals is “to prepare job-ready graduates for successful careers in their chosen fields”. How do you go about achieving this goal and how do you measure this?

Suite 2700, The Exchange Tower | 130 King Street West | Toronto, Ontario M5X 1C7 T: 416.860.0001 | F: 416.860.0003 | www.mccagueborlack.com

triOS: We designed the learning outcomes of this program with a Program Advisory Council from the supply chain industry. The courses developed for the program are mapped to the job role requirements of the sector. Each course was designed to measure the students’ practical application of the knowledge acquired. We include several case studies and projects to evaluate how the students can apply the skills have learned. The program builds on the students’ knowledge throughout the program. First, we lay a foundation of a solid understanding of logistics and transportation and the sector as a whole. Then, we concentrate on key supply chain specialized areas such as purchasing, inventory management, and transportation. One of the most critical components of our program is our CIFFA training and certification. Many of our employers and students alike acknowledge this is a key contributing factor why many of our Supply Chain and Logistics graduates are getting hired. This broad spectrum of competencies allows the student to start his/her new career in any facet of the supply chain sector.

OUR TRANSPOR TRANSPORTATION RT TATI TION ION AND MARINE LA LAW AW W PRACTICE GROUPS PROVIDE: PRA ACTICE GR OUPS PR OVIDE: ‡ ([SHUWLVHLQ/LWLJDWLRQ 'LVSXWH5HVROXWLRQ       ‡ &RPSUHKHQVLYH5LVN0DQDJHPHQW6HUYLFHV     ‡ 2QH1XPEHU$FFHVVWRRXU1RUWK$PHULFD:LGH         (PHUJHQF\5HVSRQVH7HDP1-877-247-3659    McCague Borlack LLP is a member of CLC, a Nationwide Affiliation of Independent Law Firms.

12

www.clcnow.com

THE FORWARDER Fall 2012

students with a meaningful internship can be a very rewarding experience for an organization. Often, this internship experience is how a student gains a critical reference for his/her future employer. Students who have great internship experiences share positive feedback and help to promote the company with which they have worked. CIFFA: Is there a monetary cost for CIFFA member firms to participate? triOS: There is no cost for CIFFA members to host a student intern. All of the WSIB and liability coverage is provided by triOS College while the student is on an internship. In exchange, the organization agrees to provide the student with training, guidance and mentoring so that he/she is applying the skills learned in the classroom while “on the job”.

can become

CIFFA: How many and how often are interns available?

87