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New C-TPAT Standards for Highway and Sea Carriers
April 26, 2006


Customs and Border Protection has recently come out with new Security Criteria for Highway and Sea Carriers.  None of these security criteria are mandatory regulatory requirements, but rather are required of those who are members of C-TPAT or wish to become members of C-TPAT. 

Highway Carriers

             As of March 13, 2006, U.S./Canada and U.S./Mexico highway carriers who wish to participate in C-TPAT must comply with new security requirements.  However, current C-TPAT participants have a phased implementation.  The first phase of the implementation, which must be completed within 60 days of March 13, involves hardening of the physical supply chain (conveyance security such as seals and trailer security, physical access controls for employees and visitors, physical security such as fencing, lighting and parking).  The second phase, which must be completed within 120 days of March 13, 2006, involves personnel security such as background checks, procedural security such as documentation and manifesting procedures, security training and threat awareness, less-than-truck-load security/seal requirements, and information technology security such as passwords.  The third phase give highway carriers 180 days from March 13, 2006 to comply with the business partner screening requirements.  The new requirements are set out in full here.  

             Existing C-TPAT member highway carriers will not be required to provide a written certification that the security criteria have been met, nor will previously submitted and accepted security profiles need to be resubmitted. Instead, it is understood that highway carriers must meet or exceed these baseline security criteria by the end of each implementation phase. CBP will use validations to gauge whether or not highway carriers have adopted these security criteria. Those highway carriers found to be deficient may have benefits suspended, or be removed from the program entirely.

             However, Customs has specified that at a minimum yearly basis, or as circumstances dictate such as a security breach or incident, highway carriers must conduct a comprehensive assessment of their international supply chain security practices based upon the following C-TPAT minimum-security criteria. Where a highway carrier does not control a specific element of their supply chain, such as a trucking yard, terminal, handling of trailers, or process subject to these criteria, the highway carrier must work with these business partners to ensure that pertinent security measures are in place and adhered to throughout their supply chain.

Sea Carriers

             As of March 1, 2006, sea carriers who wish to participate in C-TPAT must comply with new security requirements.  However, current C-TPAT participants have 90 days from March 1, 2006 to implement all of the requirements:  business partner requirements (security procedures), container security (seals, container inspection, etc), physical access controls (boarding - disembarking of vessels, etc), personnel security (background checks, crewmember control, etc.), procedural security (passenger and crew, manifesting procedures, etc.), security training and awareness, physical security (fencing, lighting, parking, etc.), information technology (password, accountability), and security assessments, response and improvements.  The new requirements are set out in full here

             Existing C-TPAT member sea carriers will not be required to provide a written certification that the security criteria have been met, nor will previously submitted and accepted security profiles need to be resubmitted. Instead, it is understood that sea carriers must meet or exceed these baseline security criteria by the end the 90 day implementation period. CBP will use validations to gauge whether or not sea carriers have adopted these security criteria. Those sea carriers found to be deficient may have benefits suspended, or be removed from the program entirely.

             As with highway carriers, sea carriers must conduct a comprehensive assessment of their security practices based upon the C-TPAT minimum-security criteria. Where a sea carrier does not control a specific element of the cargo transportation service it has contracted to provide, such as marine terminal operator or a time chartered vessel with whom it has contracted, the sea carrier must work with these business partners to seek to ensure that pertinent security measures are in place and adhered to.  However, unlike for highway carriers, a minimum-yearly assessment has not been specified.

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