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Minimum-Security Criteria for C-TPAT Foreign Manufacturers Mfg Co 2
C-TPAT English
Introduction These minimum security criteria are fundamentally designed to be C-TPAT Foreign Manufacturer
Security Criteria
the building blocks for foreign manufacturers to institute effective security
C-TPAT C-TPAT
practices designed to optimize supply chain performance to mitigate the risk of
CONTAINER SECURITY
loss, theft, and contraband smuggling that could potentially introduce terrorists and implements
of terrorism into the global supply chain. The determination and scope of criminal elements Minimum-Security Criteria for
targeting world commerce through internal conspiracies requires companies, and in particular, C-TPAT Foreign Manufacturers
foreign manufacturers to elevate their security practices. At a minimum, on a yearly basis, or as in English
Minimum-Security Criteria for
circumstances dictate such as during periods of heightened alert, security breach or incident,
C-TPAT Foreign Manufacturers
foreign manufacturers must conduct a comprehensive assessment of their international supply
C-TPAT Importer Criteria
chains based upon the following C-TPAT security criteria. Where a foreign manufacturer
Chinese
out-sources or contracts elements of their supply chain, such as another foreign facility, min security criteria chinese
warehouse, or other elements, the foreign manufacturer must work with these business partners -(C-TPAT)
to ensure that pertinent security measures are in place and are adhered to throughout their
supply chain. The supply chain for C-TPAT purposes is defined from point of origin C-TPAT-
Schedule management
(manufacturer/supplier/vendor) through to point of distribution and recognizes the diverse
C-TPAT Importer Criteria
business models C-TPAT members employ. C-TPAT recognizes the complexity of international
Chinese
supply chains and security practices, and endorses the application and implementation of
C-TPAT 20080428
security measures based upon risk1. Therefore, the program allows for flexibility and the
customization of security plans based on the members business model. Appropriate security
measures, as listed throughout this document, must be implemented and maintained throughout
the Foreign manufacturers supply chains - based on risk2.
Page 1 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
Business Partner Requirements Foreign manufacturers must have written and verifiable processes
for the selection of business partners including, carriers, other manufacturers, product suppliers
and vendors (parts and raw material suppliers, etc). Security procedures For those business
partners eligible for C-TPAT certification (carriers, importers, ports, terminals, brokers,
consolidators, etc.) the foreign manufacturer 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, the foreign manufacturer must
require that 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 World Customs
Organization (WCO) accredited security program administered by a foreign customs authority; or,
by providing a completed foreign manufacturer security questionnaire). Based upon a
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documented risk assessment process, non-CTPAT eligible business partners must be subject to
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verification of compliance with C-TPAT security criteria by the foreign manufacturer. Point of
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Origin Foreign manufacturers must ensure that business partners develop security processes and
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procedures consistent with the C-TPAT security criteria to enhance the integrity of the shipment
at point of origin, assembly or manufacturing. Periodic reviews of business partners processes
and facilities should be conducted based on risk, and should maintain the security standards
required by the foreign manufacturer. Participation/Certification in a Foreign Customs
Administration Supply Chain Security Program 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 foreign
manufacturer. Security Procedures On U.S. bound shipments, foreign manufacturers should
monitor that C-TPAT carriers that subcontract transportation services to other carriers use other
C-TPAT approved carriers, or non-C-TPAT carriers that are meeting the C-TPAT security criteria as
outlined in the business partner requirements. As the foreign manufacturer is responsible for
loading trailers and containers, they should work with the carrier to provide reassurance that
there are effective security procedures and controls implemented at the point-of-stuffing.
Page 2 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
Container and Trailer Security Container and trailer integrity must be maintained to protect
against the introduction of unauthorized material and/or persons. At the point-of-stuffing,
procedures must be in place to properly seal and maintain the integrity of the shipping
containers and trailers. A high security seal must be affixed to all loaded containers and trailers
bound for the U.S. All seals must meet or exceed the current PAS ISO 17712 standard for high
security seals. In those geographic areas where risk assessments warrant checking containers or
trailers for human concealment or smuggling, such procedures should be designed to address
this risk at the manufacturing facility or point-of-stuffing. 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 Trailer Inspection Procedures must be in place to
verify the physical integrity of the trailer structure prior to stuffing, to include the reliability of the
locking mechanisms of the doors. The following ten-point inspection process is recommended
for all trailers: ? Fifth wheel area - check natural compartment/skid plate ? Exterior - front/sides ?
Rear - bumper/doors ? Front wall ? Left side ? Right side ? Floor ? Ceiling/Roof ? Inside/outside
doors ? Outside/Undercarriage Container and Trailer Seals The sealing of trailers and containers,
to include continuous seal integrity, are crucial elements of a secure supply chain, and remains a
critical part of a foreign manufacturers commitment to C-TPAT. The foreign manufacturer must
affix a high security seal to all loaded trailers and containers bound for the U.S. All seals must
meet or exceed the current PAS ISO 17712 standards for high security seals. Written procedures
must stipulate how seals are to be controlled and affixed to loaded containers and trailers, to
include procedures for recognizing and reporting compromised seals and/or containers/trailers
to US Customs and Border Protection or the appropriate foreign authority. Only designated
employees should distribute seals for integrity purposes. Container and Trailer Storage
Containers and trailers under foreign manufacturer control or located in a facility of the foreign
manufacturer must be stored in a secure area to prevent unauthorized access and/or
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manipulation. Procedures must be in place for reporting and neutralizing unauthorized entry into
containers/trailers or container/trailer storage areas.
Page 3 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
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 should 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.
Page 4 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
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 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 employees
position. Personnel Termination Procedures Companies must have procedures in place to remove
identification, facility, and system access for terminated employees.
Page 5 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
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, procedures must be in place to ensure that information received from business
partners is reported accurately and timely. Shipping and Receiving Departing cargo being
shipped 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.
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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. Procedures
should also be established to track the timely movement of incoming and outgoing goods. 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 anomalies, illegal or suspicious activities are detected - as
appropriate.
Page 6 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
Physical Security Cargo handling and storage facilities in international locations must have
physical barriers and deterrents that guard against unauthorized access. Foreign manufacturer
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 and 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.
Page 7 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
Information Technology Security Password Protection Automated systems must use individually
assigned accounts that require a periodic change of password. IT security policies, procedures
and standards must be in place and provided to employees in the form of training. Accountability
A system must be in place to identify the abuse of IT including improper access, tampering or the
altering of business data. All system violators must be subject to appropriate disciplinary actions
for abuse.
Page 8 of 9
Minimum-Security Criteria for C-TPAT Foreign Manufacturers
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 and contraband smugglers at each point in the supply chain. Employees must be made
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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.
Foreign manufacturers shall have a documented and verifiable process for determining risk
throughout their supply chains based on their business model (i.e., volume, country of origin,
routing, C-TPAT membership, potential terrorist threat via open source information, having
inadequate security, past security incidents, etc.). Foreign manufacturer shall have a documented
and verifiable process for determining risk throughout their supply chains based on their
business model (i.e., volume, country of origin, routing, potential terrorist threat via open source
information, etc.)
Page 9 of 9
C-TPAT Security Criteria English
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