Security Procedures
For those business partners eligible for C-TPAT certification (carriers, ports, terminals, brokers, consolidators, etc.) the importer must have documentation
(e.g., C-TPAT certificate, SVI number, etc.) indicating whether these business partners are or are not C-TPAT certified.
For those business partners not eligible for C-TPAT certification, importers
must require their business partners to demonstrate that they are meeting C-TPAT security criteria via written/electronic confirmation (e.g., contractual obligations; via a letter from a senior business
partner officer attesting to compliance; a written statement from the business partner demonstrating their compliance with C-TPAT security criteria or an equivalent WCO accredited security program
administered by a foreign customs authority; or, by providing a completed importer security questionnaire).Based upon a documented risk assessment process, non-C-TPAT eligible business partners must be
subject to verification of compliance with C-TPAT security criteria by the importer.
Point of Origin
Importers must ensure business partners develop security processes
and procedures consistent with the C-TPAT security criteria to enhance the integrity of the shipment at point of origin. Periodic reviews of business partners' processes and facilities should be conducted
based on risk, and should maintain the security standards required by the importer.
Participation / Certification in
Foreign Customs Administrations Supply Chain Security Programs
Current or prospective business partners who have obtained a certification in a supply chain security program being administered by foreign Customs Administration
should be required to indicate their status of participation to the importer.
Other Internal Criteria for Selection
Internal requirements, such as financial soundness, capability of meeting contractual security requirements, and the
ability to identify and correct security deficiencies as needed, should be addressed by the importer. Internal requirements should be assessed against a risk-based process as determined by an internal
management team.
Container Security
Container integrity must be maintained to protect against the introduction of unauthorized material and/or persons. At point of
stuffing, procedures must be in place to properly seal and maintain the integrity of the shipping containers. A high security seal must be affixed to all loaded containers bound for the U.S. All seals must
meet or exceed the current PAS ISO 17712 standards for high security seals.
Container Inspection
Procedures must be in place to verify the physical integrity of the container structure prior to stuffing, to include the reliability of the locking
mechanisms of the doors. A seven-point inspection process is recommended for all containers:
. Front wall
. Left side
. Right side
. Floor
. Ceiling/Roof
. Inside/outside doors
. Outside/Undercarriage
. Container Seals
Written procedures must stipulate how seals are to be controlled and affixed to loaded containers - to include procedures for recognizing and reporting
compromised seals and/or containers to U.S. Customs and Border Protection or the appropriate foreign authority. Only designated employees should distribute container seals for integrity purposes.
Container Storage
Containers must be
stored in a secure area to prevent unauthorized access and/or manipulation. Procedures must be in place for reporting and neutralizing unauthorized entry into containers or container storage areas.
Physical Access Controls
Access controls
prevent unauthorized entry to facilities, maintain control of employees and visitors, and protect company assets. Access controls must include the positive identification of all employees, visitors, and
vendors at all points of entry.
Employees
An employee identification system must be in place for positive identification and access control purposes. Employees should only be given access to those secure areas
needed for the performance of their duties. Company management or security personnel must adequately control the issuance and removal of employee, visitor and vendor identification badges. Procedures for the
issuance, removal and changing of access devices (e.g. keys, key cards, etc.) must be documented.
Visitors
Visitors must present photo identification for documentation purposes upon arrival. All visitors should be escorted and visibly
display temporary identification.
Deliveries (Including Mail)
Proper vendor ID and/or photo identification must be presented for documentation purposes upon arrival by all vendors. Arriving packages and mail should be periodically
screened before being disseminated.
Challenging and Removing Unauthorized Persons
Procedures must be in place to identify, challenge and address unauthorized/unidentified persons.
Personnel Security
Processes must be in place to screen prospective employees
and to periodically check current employees.
Pre-Employment Verification
Application information, such as employment history and references must be verified
prior to employment.
Background Checks / Investigations
Consistent with foreign, federal, state, and local regulations, background checks and investigations should be conducted for prospective employees. Once employed,
periodic checks and reinvestigations should be performed based on cause, and/or the sensitivity of the employee's position.
Personnel Termination Procedures
Companies must have procedures in place to
remove identification, facility, and system access for terminated employees.
Procedural Security
Security measures must be in place to ensure the integrity and security of processes relevant to the transportation, handling, and storage of cargo in the
supply chain.
Documentation Processing
Procedures must be in place to ensure that all information used in the clearing of merchandise/cargo, is legible, complete, accurate, and protected against the
exchange, loss or introduction of erroneous information. Documentation control must include safeguarding computer access and information.
Manifesting Procedures
To help ensure the integrity of cargo received from
abroad, procedures must be in place to ensure that information received from business partners is reported accurately and timely.
Shipping & Receiving
Arriving cargo should be reconciled against
information on the cargo manifest. The cargo should be accurately described, and the weights, labels, marks and piece count indicated and verified. Departing cargo should be verified against purchase or
delivery orders. Drivers delivering or receiving cargo must be positively identified before cargo is received or released.
Cargo Discrepancies
All shortages, overages, and other significant
discrepancies or anomalies must be resolved and/or investigated appropriately. Customs and/or other appropriate law enforcement agencies must be notified if illegal or suspicious activities are detected - as
appropriate.
Security Training and Threat Awareness
A threat awareness program should be established and maintained by security personnel to recognize and foster awareness of the threat posed by terrorists at each point
in the supply chain. Employees must be made aware of the procedures the company has in place to address a situation and how to report it. Additional training should be provided to employees in the shipping
and receiving areas, as well as those receiving and opening mail.
Additionally, specific training should be offered to assist employees in maintaining cargo integrity, recognizing internal
conspiracies, and protecting access controls. These programs should offer incentives for active employee participation.
Physical Security
Cargo handling and storage facilities in domestic and foreign locations must have physical barriers
and deterrents that guard against unauthorized access. Importers should incorporate the following C-TPAT physical security criteria throughout their supply chains as applicable.
Fencing
Perimeter fencing should enclose the areas around cargo
handling and storage facilities. Interior fencing within a cargo handling structure should be used to segregate domestic, international, high value, and hazardous cargo. All fencing must be regularly
inspected for integrity and damage.
Gates and Gate Houses
Gates through which vehicles and/or personnel enter or exit must be manned and/or monitored. The number of gates should be kept to the minimum necessary for proper
access and safety.
Parking
Private passenger vehicles should be prohibited from parking in or adjacent to cargo handling and storage areas.
Building Structure
Buildings must be constructed of materials that resist unlawful entry. The integrity of structures must
be maintained by periodic inspection and repair.
Locking Devices and Key Controls
All external and internal windows, gates and fences must be secured with locking devices. Management or security personnel must control the issuance of all
locks and keys.
Lighting
Adequate
lighting must be provided inside and outside the facility including the following areas: entrances and exits, cargo handling and storage areas, fence lines and parking areas.
Alarms Systems & Video Surveillance Cameras
Alarm systems and video surveillance cameras should be utilized to monitor premises and prevent unauthorized access to cargo handling and storage areas. |
