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Proactive Approaches
To Minimize
Supply Chain Security
Breaches in the Rail, Air, Ocean and Land Environment
Top Eight Rail PrinciplesTrack and monitor pulls on a 24 hour basis to determine location and status.
All loaded containers and cars bound for the United States must be affixed with high security seals (when applicable) that meet or exceed the current ISO PAS 17712 standards for high security seals. Company unique seals are a plus.
Ensure a systemic point inspection is performed and documented on all containers and instruments of traffic bound for the United States prior to loading at the point of origin. In addition, inspections should be conducted randomly while in route to the U.S. and at the last stop before entering the U.S.
Comprehensive screening should be performed on all business partners involved in your supply chains.
Top Eight Rail Principles (Cont’d)Ensure adequate hiring practices and employee background investigations are conducted on company employees and business partner employees.
Conduct risk assessments to determine threats involved and weak areas of the supply chain.
Have a visual audit trail for all containers or rail cars being loaded that are exported to the U.S. by insisting that loading bays and docks at the point of origin are monitored on a 24/7 basis by a CCTV System.
Conduct seizure investigations and risk analysis in the event the supply chain is compromised.
Tracking and Monitoring
An enhancement to GPS that uses a network of fixed, ground-based reference stations to broadcast the difference between the positions indicated by the satellite systems and the known fixed positions.
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(OR originates at the upperleft corner of the area
outlined and is sized to the full width or height of this
bounding box.)
Differential Global Positioning System (DGPS)
Tracking and Monitoring
An electronic recognition system used to identify rail equipment while en route to its destination.
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(OR originates at the upperleft corner of the area
outlined and is sized to the full width or height of this
bounding box.)
Automatic Equipment Identification (AEI)
Tracking and Monitoring
A device attached to the track which monitors passing trains for hot axles & reports via radio transmission.
Hotbox Detectors
High Security Seals
All loaded containers and cars bound for the United States must be affixed with High Security Seals (when applicable) that meet or exceed the current ISO PAS 17712 standards for high security seals.
Company unique seals are considered a best practice.
Image fills this entire area
(OR originates at the upperleft corner of the area
outlined and is sized to the full width or height of this
bounding box.)
Systemic Point Inspection
Ensure a Systemic Point Inspection is performed and documented on all containers and instruments of traffic bound for the United States prior to loading at the point of origin. In addition, inspections should be conducted randomly while in route to the U.S. and at the last stop before entering the U.S.
Familiarize yourself with the partner’s operation and production process to determine where the supply chain begins.
Determine the level of security at your partner’s facility; access controls, perimeter security, etc.
Determine level of security and procedures at the point of stuffing and during the sealing process.
Determine if partner conducts an extensive background investigation on employee’s.
Business Partner Screening
Request background checks for all employees involved in all supply chains. Subject temporary employees, vendors and third party contractors to the same background investigations as your company’s permanent employees.
Have partners conduct criminal background checks to ensure the integrity of persons having access to your facility and cargo.
Request random & periodic employee reinvestigations from business partners.
Require partners to verify authenticity of an official government photo ID for all employees and maintain a copy within their personnel file.
Adequate Hiring Practices
On an annual basis, and based on specific changes in operation, policy, or practices, the company should visit its partners directly involved in its supply chain to determine the efficiency of security measures at their site and/or at the points of stuffing.
Risk Assessments
Questionnaires provided in advance should be utilized toconfirm what is in place.
Evaluate risk levels at the site and during transit.
Companies should be provided feedback,recommendations, and/or ideas based on findings.
A scoring matrix should be utilized (for multiple partners) to categorize strengths, weaknesses, threats, and bestpractices.
On an annual basis and based on breaches of supply chain integrity, conduct a self-assessment on company practices to determine if there are weaknesses and/or vulnerabilities.
Risk Assessments
Follow the flow of cargo from your facilities to the border.
Evaluate security at each owned/leased facility.
Determine if practices that maintain conveyance securityintegrity are effective and that they are carried outefficiently.
CCTV
Have a visual audit trail for all containers or rail cars being loaded that are exported to the U.S. by insisting that loading bays and docks at the point of origin are monitored on a 24/7 basis by a CCTV System.
Seizure ResponseEngage with CBP and/or local authorities
Inform SCSS and POE if seizure occurs on foreign side orwithin the U.S.
Risk analysis and investigations
Determine vulnerable spots along supply chain throughimmediate investigations.
Share risk analysis findings along with seizure investigation findings with local authorities, CBP, and/or other agencies.
Seizure Response (Cont’d)Communication between rail companies (US & Mexico)
Share investigation findings with critical partners.
Share intelligence with partners to help combatsmuggling/terrorism.
Security Measures
in an
Air Cargo
environment.
C-TPAT and currentAir Security measures
C-TPAT acknowledges that air carriers are already subject to defined security mandates created through public laws and regulations, such as the Aviation and Transportation Security Act (PL 107-71) . It is not the intention of C-TPAT to duplicate these requirements, rather, C-TPAT seeks to build upon established foundations and require additional security measures and practices which enhance the overall security throughout the international supply chain.
Where an air carrier does not control a specific element of the cargo transportation service it has contracted to provide, such as an airport terminal, direct handling of cargo containers or Unit Load Device (ULD).
1. The air carrier must work with these business partners to ensure that pertinent security measures are in place and adhered to.
2. The air carrier is responsible for exercising prudent oversight for all cargo loaded on board its aircraft.
Air Cargo Security RisksPotential risks associated with air cargo security include:
1. Introduction of explosive and incendiary devices in cargo placedaboard aircraft.
2. Shipment of undeclared or undetected hazardous materials aboard aircraft.
3. Cargo crime including theft and smuggling.
4. Aircraft hijackings and sabotage by individuals with access to aircraft.
C-TPAT Security CriteriaAir Carriers
Business Partner Requirements
Container or Unit Load Devices (ULD) Security
Physical Access Controls
Personnel Security
Procedural Security
Security Training and Threat Awareness
Physical Security
Information Technology (IT) Security
Air carriers must have written and verifiable processes for the screening of business partners, including carrier’s agents and service providers.
Air carriers must also have screening procedures for new customers, beyond financial soundness issues to include indicators of whether the customer appears to be a legitimate business or poses to be a security risk.
Site Verification Verify Business Partners Portal Verification
Business Partner Requirements
Container or Unit Load Devices Container or Unit Load Devices (ULD) Security(ULD) Security
Challenges for air cargo.
Contaminated ULD(s) and Carts
Cargo Screening and InspectionParticipation in the Known Shipper Program
X-RAYS
K –9’s
High Security SealsContainer Seals
When containers/ULDs are used, written procedures must stipulate how seals in the air carrier’s possession are to be controlled, and only designated employees must distribute seals for integrity purposes. Procedures should also exist for recognizing and reporting compromised seals and/or containers/ULDs to U.S. Customs and Border Protection or the appropriate foreign authority.
Personnel SecurityBackground Checks
Pre-Employment Verification
Background checks / Social Economic
Personnel Termination Procedures
Physical Security
Physical Access ControlsAccess controls prevent unauthorized entry to aircraft and facilities, maintain control of employees and visitors, and protect company assets. Access controls must include the positive identification of all employees, visitors, service providers, and vendors at all points of entry.
ConclusionC-TPAT recognizes the complexity of international supply chains and security practices, and endorses the application and implementation of security measures based upon risk.
Therefore, the program allows for flexibility and the customization of security plans based on the member’s business model. Appropriate security measures, as listed in the C-TPAT criteria, must be implemented and maintained.
Air carriers shall have a documented and verifiable process to secure their cargo and facilities and to determine 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, ports identified by TSA as having inadequatesecurity, past security incidents, etc.).
Proactive Approaches
To Minimize
Supply Chain Security
Breaches in the Marine Environment
The Top Five Marine PrinciplesEnsure a Seven Point Inspection is performed and documented on all containers bound for the United States prior to loading at the point of origin.Have a visual audit trail for all containers being loaded for export to the U.S. by insisting that loading bays and docks at the point of origin are monitored on a 24/7 basis by a CCTV System. All loaded containers bound for the United States must be affixed with a High Security Seal that meets or exceeds the current ISO PAS 17712 standards for high security seals. Company unique seals are a plus.Know your Trucking Company’s Drivers. They are the weak link in the supply chain.Insist that thorough Background Checks are performed on all personnel involved in your supply chains.
Seven Point Inspection
CCTV SystemCCTV System
Trap Doors
Have a visual audit trail for all containers being loaded.
Avoid this situation:
High Security Seals
Container Seals
Must meet or exceed current ISO PAS 17712 standards; Documented procedures for how seals are controlled and affixed; Verify seal numbers match shipping documentation. Company unique seals are a plus.
Background ChecksRequire background checks for all employees involved in your supply chains. Subject temporary employees, vendors and third party contractors to the same background investigations as your company’s permanent employees.
Conduct criminal background checks to ensure the integrity of persons who have access to your facility and cargo.
Randomly subject employees to periodic reinvestigations.
Verify authenticity of an official government photo ID for all employees and maintain a copy within their personnel file.
Truck DriversMaintain communication with drivers. Require your highway carriers to issue cell phones or radios to all their drivers. Have them call their dispatchers and document it on a regular basis, particularly at arrival at foreign customs or U.S. CBP and their ultimate destination.
Utilize multiple monitoring methods. Track conveyances by timing the driver’s movements, fuel consumption and….
GPS. Today’s modern highway carriers have GPS and text messaging in all their tractors. This enables the driver to communicate with their dispatchers. GPS will detect anomalies, unscheduled stops, route variances and enable drivers to quickly send a distress message.
Proactive Approaches
To Minimize
Supply Chain Security
Breaches in the Land Border Environment
Land Border Container/Trailer Security
Freight transportation
7-point container/trailer inspection
Types of seals
Tamper proof nuts and bolts
Narcotic detector dogs
Unannounced visits
Land Border Container/Trailer Security
Who moves the freight at points along the Supply Chain?
C-TPAT Certified Companies
Non-CTPAT Certified Companies
Is the 7-point container/trailer inspection conducted?
This inspection must be documented
Company must get a copy of the inspection
Land Border Container/Trailer Security
Types of seals
Plastic
Metal
Bolt - ISO/PAS 17712
Cable – ISO/PAS 17712
Locking Bar with cable seal – ISO/PAS 17712
Tamper Evident Security Tape
Plastic, Metal and Cable Seals
Locking Bar and Bolt Seal
Image fills this entire area(OR originates at the upper
left corner of the area outlined and is sized to the full width or height of this
bounding box.)
Try to make multiple images approximately the same sizeAlign and group images in an
organized manner
Tamper Evident Security Tape
Tamper Proof nuts and boltsThe use of tamper proof nuts and bolts will help deter unauthorized
entry.
Trailer door hinge
Trailer door hinge pins
Door hasp
Door bar lock assembly
Work with companies during site visits.
Show them which trailers are in need of repair.
Weld the bolts if no other option exists.
Tamper Proof nuts and bolts
Hasp Manipulation
Narcotic Detector Dogs
Narcotic detector dogs are available at most Mexican / U.S. border crossings.
Located on the Mexican side prior to crossing into the U.S.
Dogs are taught to detect concealed narcotics.
Most companies also conduct trailer inspection.
All inspections are documented.
Can go to the company facility or trailer terminal.
Drivers should not know when they have to be inspected.
Low cost per trailer.
K-9 Inspection
Unannounced Site Visits
Company will not have time to prepare for your visit.
You can verify what the company tells you they are doing.
Use caution when crossing the border.
Be aware of your surroundings.
Know how to get to and out of the place you are visiting.
Know the language.
Make sure the company is aware that an unannounced visit is possible.
Have a plan!
