CBP says more vigilance needed by C-TPAT members, outlines additional measures
July 24, 2009
World Trade\Interactive
U.S. Customs and Border Protection has issued a security bulletin urging Customs-Trade Partnership Against Terrorism members to increase their vigilance over their supply chains and outlining various measures such companies can take to meet that objective. CBP states that while this bulletin is focused on operations along the U.S.-Mexico border, all C-TPAT members are highly encouraged to review their established security processes at this time.
The bulletin explains that during the past few months there have been several large narcotics seizures involving commercial shipments linked to C-TPAT members. These seizures have occurred across the entire southwest border and involved both dry goods and fresh produce. In many instances C-TPAT members were utilizing the services of non-C-TPAT service providers.
CBP has identified two primary factors that have enabled these supply chain security breaches: failing to follow established security procedures, and lack of corporate oversight ultimately resulting in significant levels of subversion of established supply chain security procedures via internal conspiracies. CBP is reminding members that they are expected to use C-TPAT partners to the extent possible and to conduct extensive screening of non-C-TPAT partners. Given the current threat from Mexico, the bulletin states, non-C-TPAT partners must be afforded higher levels of scrutiny, and C-TPAT members are expected to verify the security measures being utilized.
CBP has also listed the following additional steps that C-TPAT members may want to take to mitigate threats to their supply chain corridors.
• ensure adequate oversight and accountability of the cargo loading and sealing process
• use cameras and/or other suitable monitoring devices or processes at cargo loading areas
• ensure that all conveyance hardware and fastening devices are inspected for overall security and deterrence of unauthorized access; where deficiencies are present, taking steps to mitigate the risk and/or harden all fastening/access devices
• consider the use of more stringent security devices to secure trailer doors
• audit and verification of employee screening processes, to include periodic reviews
• consider rotating personnel assigned to operationally sensitive positions, such as dispatcher
• review established processes for oversight of the transportation component and assess areas of potential weaknesses and vulnerability, with specific attention on addressing potential delays and/or opportunities for security breach
• work with service providers to develop written and verifiable procedures to track conveyances from point of origin to final destination
• establish route times from the manufacturing site to various points in the transportation flow, develop written and verifiable procedures to address those instances in which a driver does not check in within established time parameters, and prohibit drivers from making unauthorized stops
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