Industry News

Draft C-TPAT Minimum Standards

Nov. 22, 2004


Customs Floats Minimum Security Standards

by Diane A. MacDonald

Customs has recently released a draft of minimum standards that importers must meet when conducting comprehensive self-assessments as part of their C-TPAT obligations. A link to the proposal is provided at the end of this article. These minimum security standards, dated November 11, 2004, must be implemented and maintained throughout the importer’s supply chain, which Customs has defined for C-TPAT purposes as the point of origin by manufacture, supply, or vendor, through U.S. distribution.

Additionally, Customs’ draft states that if an importer outsources any element of its supply chain, the importer must ensure that the security measures are in place and functioning for each business partner. Business partners include manufacturers, product suppliers, vendors, carriers, terminal operators, brokers, and consolidators. The importer must document the procedures in place at the location of each business partner in its C-TPAT Security Profile submission.

The minimum security standards must include the following elements:

Importers must have written and verifiable processes for the selection of each business partner. Theses processes must include the evaluation and verification of a written security questionnaire that addresses the partner’s current security procedures; the status of the partner’s participation in various Customs-Industry partner programs such as C-TPAT and the Business Anti-Smuggling Coalition; and other requirements used in the selection of the partner, such as financial soundness.

Importers must ensure that container security procedures are in place, including security procedures for the stuffing and sealing of containers, and companies must verify the physical integrity of the container prior to stuffing via a seven-point inspection process. Additionally, all seals must meet or exceed the current PAS ISO 17712 standard for high-security mechanical seals.

Importers must maintain physical access controls to prevent unauthorized entry to facilities. These controls must include the positive identification of all employees, visitors, and vendors at all points of entry. Importers must also have an employee screening process in place, for both new and long-standing employees.

Importers must also maintain security processes to ensure that the transportation, handling, and storage of cargo are properly monitored; these processes should cover document processing; manifest procedures; shipping and receiving; and cargo discrepancies. Additionally, importers must establish and maintain security training and threat awareness for employees in all of these areas and all areas related to physical security.

All cargo handling and storage facilities in domestic and foreign locations must have physical barriers and other deterrents to control unauthorized access, including, where applicable, fencing; gates and gate houses; locking devices and key controls; and alarms systems and video surveillance cameras.

Finally, importers must also ensure that they maintain security procedures for information technology systems, including password systems; accountability for access to information; and employee training.

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