Tuesday, July 28, 2009

Message from the C-TPAT Director

C-TPAT Members:

As we maintain our vigilance against extremist attacks originating from locations far from our borders, we must also recognize that many threats we face are much closer.

Over the course of the past few months law enforcement on both sides of the US/Mexico border have made several large narcotics seizures involving commercial shipments linked to C-TPAT members. The seizures have occurred across the entire southwest border and involved both dry goods as well as fresh produce. In most cases the narcotics were commingled with the commercial merchandise. Of particular note is that in many instances C-TPAT members were utilizing the services of non-C-TPAT service providers.

CBP reminds members that they are expected to use C-TPAT partners to the extent possible and to conduct extensive screening of their non-C-TPAT business partners. Members must have written and verifiable processes in place to ensure this screening takes place on a consistent basis. Given the current threat from Mexico, non-C-TPAT business partners must be afforded higher levels of scrutiny. C-TPAT members are expected to verify the security measures being utilized.

Comprehensive reviews of recent events have clearly identified two primary causative factors having enabled supply chain security breaches;

Companies had established security procedures in place yet failed to follow them.
Lack of corporate oversight ultimately resulting in significant levels of subversion of established supply chain security procedures via internal conspiracies.

It is imperative that C-TPAT partners perform internal risk assessments to identify inherent threats to supply chain corridors and augment established security procedures accordingly. We have taken this opportunity to identify other causative factors which you may wish to consider as you evaluate the risk factors unique to your supply chain and further, the steps that you can take to mitigate these risks. Areas of consideration include:

Ensuring there is adequate oversight and accountability of the cargo loading and sealing process.

Employing the use of cameras and/or other suitable monitoring devices or processes at the cargo loading areas.

Ensuring that all conveyance hardware and fastening devices are inspected for overall security and deterrence of unauthorized access. Where deficiencies are present, steps must be taken 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 the established processes for oversight of the transportation component. Areas of potential weaknesses and vulnerability should be assessed. Specific attention and focus should be provided towards addressing potential delays and/or opportunities for security breach.

Members should work with service providers to develop written and verifiable procedures to track conveyances from the point of origin to the final destination.

Establishment of route times from the manufacturing site to various points in the transportation flow will help monitor and ensure that drivers are arriving at designated locations within established time parameters.

Members should work with service providers to develop written and verifiable procedures to address those instances that a driver does not check in within established time parameters. Drivers should not be allowed to make unauthorized stops.

While the focus of this security bulletin is directed toward operations along the South West Border of the United States, all C-TPAT members are highly encouraged to take this opportunity to review their established security processes. Continued supply chain security is dependent upon your continued vigilance.

You are encouraged to contact your assigned Supply Chain Security Specialist to discuss ways in which your company can help CBP address this issue or if you have specific concerns that need to be addressed.

In closing, the program relays its continued appreciation of your diligent and continued efforts in securing the international supply chain.


Bradd M. Skinner
Director
C-TPAT/ Industry Partnership Programs
U.S. Customs and Border Protection

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For any question on C-TPAT, please contact Custom Trade Solutions at info@customtrade.us