The Departmental Advisory Committee on Customs and Border Protection?s (COAC) ? Customs ? Trade Partnership Against Terrorism (C-TPAT) Subcommittee has released copies of new draft minimum security standards being developed by the Department of Homeland Security?s (DHS) Bureau of Customs and Border Protection (CBP).The new criteria affectshighway and sea carriers.

The proposed new C-TPAT criteria for highway and ocean carriers appears to track the voluntary program set for importers that went into effect in late March of this year (Notice, April 1).

Proposed Land (Highway) C-TPAT Criteria

Under the draft plan, carriers that choose to become certified in C-TPAT must conduct a comprehensive assessment of their international supply chain security practices.Where a carrier does not control a specific segment of their supply chain, such as trucking yard, terminal, handling of trailers or process subject to the criteria, the highway carrier must work with its business partners to ensure that specific security measures are in place and adhered to throughout the supply chain.The supply chain for highway carriers is defined from point of origin — from the yard or where the tractors and trailers are stored, through pickup at the manufacturers/supplier/ vendor to the point of distribution.

As with the C-TPAT requirements for importers, highway carriers must have written and verifiable processes for the screening of their business partners.Many importers found this step difficult to adhere to and were given 180 days (after this criteria became operational) to put this provision into effect.

Another section titled ?Conveyance Security? must be maintained to protect against the introduction of unauthorized personnel and material.

Other areas covered in the new criteria include: trailer security; container security; conveyance tracking and monitoring procedures; trailer seals; less than truckload (LTL); physical access controls (employees, visitors/vendors/service providers); personnel security; procedural security (documentation processing, document review, bill of lading/manifesting procedures, cargo); physical security (fencing, gates and gate houses, parking, building structure, locking devices, and key controls, lighting, alarm systems and video surveillance cameras); security training and threat awareness; information and technology security; accountability; and Free and Secure Trade (FAST) transportation controls.

For a complete copy of the draft C-TPAT critiera for highway carriers, click here.

DraftSea Carrier C-TPAT Criteria
The new draft criteria for sea carriers follows the outline in place for importers and the draft rules for highway carriers. ?Business Partner Requirements? also must have written and verifiable processes for the screening of business partners.

As for ?container security? the draft states that all containers in the sea carrier?s custody (including container integrity) must be maintained to protect against the introduction of unauthorized material and/or persons.

Sea carriers under this section, must ?recognize the importance of a comprehensive container inspection process prior to loading to include the reliability of the locking mechanisms of the doors.?The criteria notes that since the responsibility for inspecting all containers prior to loading rests with the importers, sea carriers, ?must visually inspect all empty containers to include the interior of the container, at the foreign port of lading.A seven point inspection process is recommended for all empty containers:

* front wall;
* left side;
* right side;
* floor;
* ceiling/roof;
* inside/outside doors; and,
* outside/undercarriage.?

With regard to seals, the sea carrier criteria states that written procedures must stipulate how seals in the sea carrier?s possession are to be controlled.Storage of containers also must be in a secure area to prevent unauthorized access and/or manipulation.

For a complete copy of the draft C-TPAT criteria for sea carriers, click here.

CBP noted in providing these drafts that the air carrier criteria has not been released and that rail carrier criteria is now being finalized.

Source: Logistics Management

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