CTPAT Minimum Security Criteria – U.S. Importers | November 2019
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Minimum Security Criteria – U.S. Importers
November 2019
Note: Criteria ID numbers may not be sequential. ID numbers not listed are not applicable to U.S. Importers.
First Focus Area: Corporate Security
1. Security Vision & Responsibility – For a CTPAT Member’s supply chain security program to become and remain effective, it must have
the support of a company’s upper management. Instilling security as an integral part of a company’s culture and ensuring that it is a
companywide priority is in large part the responsibility of the company’s leadership.
ID Criteria Implementation Guidance
Must /
Should
1.1
In promoting a culture of security, CTPAT Members
should demonstrate their commitment to supply chain
security and the CTPAT program through a statement of
support. The statement should be signed by a senior
company official and displayed in appropriate company
locations.
Statement of support should highlight the importance of protecting the supply
chain from criminal activities such as drug trafficking, terrorism, human
smuggling, and illegal contraband. Senior company officials who should support
and sign the statement may include the president, CEO, general manager, or
security director. Areas to display the statement of support include the
company's website, on posters in key areas of the company (reception;
packaging; warehouse; etc.), and/or be part of company security seminars, etc.
Should
1.2
To build a robust Supply Chain Security program, a
company should incorporate representatives from all of
the relevant departments into a cross-functional team.
These new security measures should be included in
existing company procedures, which creates a more
sustainable structure and emphasizes that supply chain
security is everyone's responsibility.
Supply Chain Security has a much broader scope than traditional security
programs. It is intertwined with Security, in many departments such as Human
Resources, Information Technology, and Import/Export offices. Supply Chain
Security programs built on a more traditional, security department-based model
may be less viable over the long run because the responsibility to carry out the
security measures are concentrated among fewer employees, and, as a result,
may be susceptible to the loss of key personnel.
Should
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ID Criteria Implementation Guidance
Must /
Should
1.3
The supply chain security program must be designed
with, supported by, and implemented by an appropriate
written review component. The purpose of this review
component is to document that a system is in place
whereby personnel are held accountable for their
responsibilities and all security procedures outlined by
the security program are being carried out as designed.
The review plan must be updated as needed based on
pertinent changes in an organization’s operations and
level of risk.
The goal of a review for CTPAT purposes is to ensure that its employees are
following the company’s security procedures. The review process does not
have to be complex. The Member decides the scope of reviews and how in-
depth they will be - based on its role in the supply chain, business model, level
of risk, and variations between specific locations/sites.
Smaller companies may create a very simple review methodology; whereas, a
large multi-national conglomerate may need a more extensive process, and may
need to consider various factors such as local legal requirements, etc. Some
large companies may already have a staff of auditors that could be leveraged to
help with security reviews.
A Member may choose to use smaller targeted reviews directed at specific
procedures. Specialized areas that are key to supply chain security such as
inspections and seal controls may undergo reviews specific to those areas.
However, it is useful to conduct an overall general review periodically to ensure
that all areas of the security program are working as designed. If a Member is
already conducting reviews as part of its annual review, that process could
suffice to meet this criterion.
For Members with high-risk supply chains (determined by their risk
assessment), simulation or tabletop exercises may be included in the review
program to ensure personnel will know how to react in the event of a real
security incident.
Must
1.4
The company’s point(s) of contact (POC) to CTPAT must
be knowledgeable about CTPAT program requirements.
These individuals need to provide regular updates to
upper management on issues related to the program,
including the progress or outcomes of any audits,
security related exercises, and CTPAT validations.
CTPAT expects the designated POC to be a proactive individual who engages
and is responsive to his or her Supply Chain Security Specialist. Members may
identify additional individuals who may help support this function by listing
them as contacts in the CTPAT Portal.
Must
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2. Risk Assessment – The continuing threat of terrorist groups and criminal organizations targeting supply chains underscores the need
for Members to assess existing and potential exposure to these evolving threats. CTPAT recognizes that when a company has multiple
supply chains with numerous business partners, it faces greater complexity in securing those supply chains. When a company has
numerous supply chains, it should focus on geographical areas/supply chains that have higher risk.
When determining risk within their supply chains, Members must consider various factors such as the business model, geographic
location of suppliers, and other aspects that may be unique to a specific supply chain.
Key Definition: Risk – A measure of potential harm from an undesirable event that encompasses threat, vulnerability, and
consequence. What determines the level of risk is how likely it is that a threat will happen. A high probability of an occurrence will
usually equate to a high level of risk. Risk may not be eliminated, but it can be mitigated by managing it – lowering the vulnerability or
the overall impact on the business.
ID Criteria Implementation Guidance
Must /
Should
2.1
CTPAT Members must conduct and
document the amount of risk in their
supply chains. CTPAT Members must
conduct an overall risk assessment (RA)
to identify where security vulnerabilities
may exist. The RA must identify threats,
assess risks, and incorporate sustainable
measures to mitigate vulnerabilities.
The Member must take into account
CTPAT requirements specific to the
Member’s role in the supply chain.
assessment of the Member’s supply chain security practices, procedures, and policies within
the facilities that it controls to verify its adherence to CTPAT’s minimum-security criteria, and
an overall management review of how it is managing risk.
The second part of the RA is the international risk assessment. This portion of the RA includes
the identification of geographical threat(s) based on the Member’s business model and role in
the supply chain. When looking at the possible impact of each threat on the security of the
Member’s supply chain, the Member needs a method to assess or differentiate between levels
of risk. A simple method is assigning the level of risk between low, medium, and high.
CTPAT developed the Five Step Risk Assessment guide as an aid to conducting the
international risk assessment portion of a Member’s overall risk assessment, and it can be
found on U.S. Customs and Border Protection’s website at
https://www.cbp.gov/sites/default/files/documents/C-
TPAT%27s%20Five%20Step%20Risk%20Assessment%20Process.pdf.
For Members with extensive supply chains, the primary focus is expected to be on areas of
Must
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ID Criteria Implementation Guidance
Must /
Should
2.2
The international portion of the risk
assessment should document or map
the movement of the Member’s cargo
throughout its supply chain from the
point of origin to the importer’s
distribution center. The mapping should
include all business partners involved
both directly and indirectly in the
exportation/movement of the goods.
As applicable, mapping should include
documenting how cargo moves in and
out of transport facilities/cargo hubs
and noting if the cargo is “at rest” at
one of these locations for an extended
period of time. Cargo is more vulnerable
when “at rest,” waiting to move to the
next leg of its journey.
considered.
When documenting the movement of all cargo, the Member is to consider all applicable
involved parties - including those who will only be handling the import/export documents such
as customs brokers and others that may not directly handle the cargo, but may have
operational control such as Non Vessel Operated Common Carriers (NVOCCs) or Third Party
Logistics Providers (3PLs). If any portion of the transport is subcontracted, this may also be
considered because the more layers of indirect parties, the greater risk involved.
The mapping exercise involves looking more in-depth at how your supply chain works. Besides
identifying risks, it may also serve to find areas where a supply chain is inefficient, which may
result in finding ways to decrease costs or lead times for receiving products.
Should
2.3
Risk assessments must be reviewed
annually, or more frequently as risk
factors dictate.
year include an increased threat level from a specific country, periods of heightened alert,
following a security breach or incident, changes in business partners, and/or changes in
corporate structure/ownership such as mergers and acquisitions etc.
Must
2.4
CTPAT Members should have written
procedures in place that address crisis
management, business continuity,
security recovery plans, and business
resumption.
or a carrier driver being hijacked by armed individuals. Based on risk and where the Member
operates or sources from, contingency plans may include additional security notifications or
support; and how to recover what was destroyed or stolen to return to normal operating
conditions.
Should
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3. Business Partners – CTPAT Members engage with a variety of business partners, both domestically and internationally. For those
business partners who directly handle cargo and/or import/export documentation, it is crucial for the Member to ensure that these
business partners have appropriate security measures in place to secure the goods throughout the international supply chain. When
business partners subcontract certain functions, an additional layer of complexity is added to the equation, which must be
considered when conducting a risk analysis of a supply chain.
Key Definition: Business Partner – A business partner is any individual or company whose actions may affect the chain of custody
security of goods being imported to or exported from the United States via a CTPAT Member’s supply chain. A business partner may
be any party that provides a service to fulfil a need within a company’s international supply chain. These roles include all parties
(both directly and indirectly) involved in the purchase, document preparation, facilitation, handling, storage, and/or movement of
cargo for, or on behalf, of a CTPAT Importer or Exporter Member. Two examples of indirect partners are subcontracted carriers and
overseas consolidation warehouses – arranged for by an agent/logistics provider.
ID Criteria Implementation Guidance
Must /
Should
3.1
CTPAT Members must have a written, risk based process for
screening new business partners and for monitoring current
partners. A factor that Members should include in this process is
checks on activity related to money laundering and terrorist
funding. To assist with this process, please consult CTPAT’s
Warning Indicators for Trade-Based Money Laundering and
Terrorism Financing Activities.
The following are examples of some of the vetting elements that
can help determine if a company is legitimate:
• Verifying the company’s business address and how long they
have been at that address;
• Conducting research on the internet on both the company and its
principals;
• Checking business references; and
• Requesting a credit report.
Examples of business partners that need to be screened are direct
business partners such as manufacturers, product suppliers,
pertinent vendors/service providers, and transportation/logistics
providers. Any vendors/service providers that are directly related
to the company’s supply chain and/or handle sensitive
information/equipment are also included on the list to be
screened; this includes brokers or contracted IT providers. How in-
depth to make the screening depends on the level of risk in the
supply chain.
Must
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ID Criteria Implementation Guidance
Must /
Should
3.4
The business partner screening process must take into account
whether a partner is a CTPAT Member or a Member in an
approved Authorized Economic Operator (AEO) program with a
Mutual Recognition Arrangement (MRA) with the United States
(or an approved MRA). Certification in either CTPAT or an
approved AEO is acceptable proof for meeting program
requirements for business partners, and Members must obtain
evidence of the certification and continue to monitor these
business partners to ensure they maintain their certification.
Business partners’ CTPAT certification may be ascertained via the
CTPAT Portal’s Status Verification Interface system.
If the business partner certification is from a foreign AEO program
under an MRA with the United States, the foreign AEO certification
will include the security component. Members may visit the
foreign Customs administration’s website where the names of the
AEOs of that Customs administration are listed, or request the
certification directly from their business partners.
Current United States MRAs include: New Zealand, Canada, Jordan,
Japan, South Korea, the European Union (28 Member states),
Taiwan, Israel, Mexico, Singapore, the Dominican Republic, and
Peru.
Must
3.5
When a CTPAT Member outsources or contracts elements of its
supply chain, the Member must exercise due diligence (via visits,
questionnaires, etc.) to ensure these business partners have
security measures in place that meet or exceed CTPAT’s Minimum
Security Criteria (MSC).
Importers and exporters tend to outsource a large portion of their
supply chain activities. Importers (and some exporters) are the
parties in these transactions that usually have leverage over their
business partners and can require that security measures are
implemented throughout their supply chains, as warranted. For
those business partners that are not CTPAT or accepted MRA
Members, the CTPAT Member will exercise due diligence to ensure
(when it has the leverage to do so) that these business partners
meet the program’s applicable security criteria.
To verify adherence to security requirements, importers conduct
security assessments of their business partners. The process to
determine how much information is to be gathered regarding a
business partner’s security program is based on the Member’s risk
assessment, and if numerous supply chains, high-risk areas are the
priority.
Must
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ID Criteria Implementation Guidance
Must /
Should
Determining if a business partner is compliant with the MSC can be
accomplished in several ways. Based on risk, the company may
conduct an onsite audit at the facility, hire a contractor/service
provider to conduct an onsite audit, or use a security
questionnaire. If security questionnaires are used, the level of risk
will determine the amount of detail or evidence required to be
collected. More details may be required from companies located in
high-risk areas. If a Member is sending a security questionnaire to
its business partners, consider requiring the following items:
•Name and title of the person(s) completing it;
•Date completed;
•Signature of the individual(s) who completed the document;
•*Signature of a senior company official, security supervisor, or
authorized company representative to attest to the accuracy of the
questionnaire;
•Provide enough detail in responses to determine compliance; and
•Based on risk, and if allowed by local security protocols, include
photographic evidence, copies of policies/procedures, and copies
of completed forms like Instruments of international traffic
inspection checklists and/or guard logs.
*Signatures may be electronic. If a signature is difficult to
obtain/verify, the respondent may attest to the questionnaire’s
validity via email, and that the responses and any supporting
evidence was approved by a supervisor/manager (name and title
are required).
CTPAT Minimum Security Criteria – U.S. Importers | November 2019
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ID Criteria Implementation Guidance
Must /
Should
3.6
If weaknesses are identified during business partners’ security
assessments, they must be addressed as soon as possible, and
corrections must be implemented in a timely manner. Members
must confirm that deficiencies have been mitigated via
documentary evidence.
CTPAT recognizes that there will be different timelines for making
corrections based on what is needed for the correction. Installing
physical equipment usually takes longer than a procedural change,
but the security gap must be addressed upon discovery. For
example, If the issue is replacing a damaged fence, the process to
purchase a new fence needs to start immediately (addressing the
deficiency) and the installation of the new fence (the corrective
action) needs to take place as soon as it is feasible.
Based on the level of risk involved and the importance of the
weakness found, some issues may require immediate attention. If
it is a deficiency that may jeopardize the security of a container, for
instance, it should be addressed as soon as possible.
Some examples of documentary evidence may include copies of
contracts for additional security guards, photographs taken of a
newly installed security camera or intrusion alarm, or copies of
inspection checklists, etc.
Must
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ID Criteria Implementation Guidance
Must /
Should
3.7
To ensure their business partners continue to comply with
CTPAT’s security criteria, Members should update their security
assessments of their business partners on a regular basis, or as
circumstances/risks dictate.
Periodically reviewing business partners’ security assessments is
important to ensure that a strong security program is still in place
and operating properly. If a Member never required updates to its
assessment of a business partner’s security program, the Member
would not know that a once viable program was no longer
effective, thus putting the Member’s supply chain at risk.
Deciding on how often to review a partner’s security assessment is
based on the Member’s risk assessment process. Higher risk supply
chains would be expected to have more frequent reviews than low
risk ones. If a Member is evaluating its business partner’s security
by in person visits, it may want to consider leveraging other types
of required visits. For example, cross-train personnel that test for
quality control to also conduct security verifications.
Circumstances that may require the self-assessment to be updated
more frequently include an increased threat level from a source
country, changes in source location, new critical business partners
(those that actually handle the cargo, provide security to a facility,
etc.).
Should
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ID Criteria Implementation Guidance
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3.9
CTPAT Members should have a documented social compliance
program in place that, at a minimum, addresses how the company
ensures goods imported into the United States were not mined,
produced or manufactured, wholly or in part, with prohibited
forms of labor, i.e., forced, imprisoned, indentured, or indentured
child labor.
The private sector’s efforts to protect workers’ rights in their
operations and supply chains can promote greater understanding
of labor laws and standards and mitigate poor labor practices.
These efforts also create an environment for better worker-
employer relations and improve a company’s bottom line.
Section 307 of the Tariff Act of 1930 (19 U.S.C. § 1307) prohibits the
importation of merchandise mined, produced or manufactured,
wholly or in part, in any foreign country by forced or indentured
child labor – including forced child labor.
Forced labor is defined by the International Labor Organization’s
Convention No. 29 as all work or service exacted from any person
under the menace of any penalty and for which the said person has
not offered himself voluntarily.
A social compliance program is a set of policies and practices
through which a company seeks to ensure maximum adherence to
the elements of its code of conduct that cover social and labor
issues. Social compliance refers to how a business addresses its
responsibilities in protecting the environment, as well as the
health, safety, and rights of its employees, the communities in
which they operate, and the lives and communities of workers
along their supply chains.
Should
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4. Cybersecurity – In today’s digital world, cybersecurity is the key to safeguarding a company’s most precious assets – intellectual
property, customer information, financial and trade data, and employee records, among others. With increased connectivity to the
internet comes the risk of a breach of a company’s information systems. This threat pertains to businesses of all types and sizes.
Measures to secure a company’s information technology (IT) and data are of paramount importance, and the listed criteria provide a
foundation for an overall cybersecurity program for Members.
Key Definitions: Cybersecurity – Cybersecurity is the activity or process that focuses on protecting computers, networks, programs,
and data from unintended or unauthorized access, change or destruction. It is the process of identifying, analyzing, assessing, and
communicating a cyber-related risk and accepting, avoiding, transferring, or mitigating it to an acceptable level, considering costs
and benefits taken.
Information Technology (IT) – IT includes computers, storage and networking devices and other physical devices, infrastructure and
processes used to create, process, store, secure, and/or exchange all forms of electronic data.
ID Criteria Implementation Guidance
Must /
Should
4.1
CTPAT Members must have comprehensive written
cybersecurity policies and/or procedures to protect
information technology (IT) systems. The written IT policy, at
a minimum, must cover all of the individual cybersecurity
criteria.
Members are encouraged to follow cybersecurity protocols that are
based on recognized industry frameworks/standards. The *National
Institute of Standards and Technology (NIST) is one such organization
that provides a Cybersecurity Framework
(
https://www.nist.gov/cyberframework) that offers voluntary guidance
based upon existing standards, guidelines, and practices to help manage
and reduce cybersecurity risks both internally and externally. It can be
used to help identify and prioritize actions for reducing cybersecurity risk,
and it is a tool for aligning policy, business, and technological approaches
to managing that risk. The Framework complements an organization’s
risk management process and cybersecurity program. Alternatively, an
organization without an existing cybersecurity program can use the
Framework as a reference to establish one.
*NIST is a non-regulatory federal agency under the Department of
Commerce that promotes and maintains measurement standards, and it
is the technology standards developer for the federal government.
Must
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ID Criteria Implementation Guidance
Must /
Should
4.2
To defend Information Technology (IT) systems against
common cybersecurity threats, a company must install
sufficient software/hardware protection from malware
(viruses, spyware, worms, Trojans, etc.) and internal/external
intrusion (firewalls) in Members' computer systems.
Members must ensure that their security software is current
and receives regular security updates. Members must have
policies and procedures to prevent attacks via social
engineering. If a data breach occurs or another unseen event
results in the loss of data and/or equipment, procedures
must include the recovery (or replacement) of IT systems
and/or data.
Must
4.3
CTPAT Members using network systems must regularly test
the security of their IT infrastructure. If vulnerabilities are
found, corrective actions must be implemented as soon as
feasible.
A secure computer network is of paramount importance to a business,
and ensuring that it is protected requires testing on a regular basis. This
can be done by scheduling vulnerability scans. Just like a security guard
checks for open doors and windows at a business, a vulnerability scan
(VS) identifies openings on your computers (open ports and IP
addresses), their operating systems, and software through which a
hacker could gain access to the company’s IT system. The VS does this by
comparing the results of its scan against a database of known
vulnerabilities and produces a correction report for the business to act
upon. There are many free and commercial versions of vulnerability
scanners available.
The frequency of the testing will depend on various factors including the
company’s business model and level of risk. For example, companies
should run these tests whenever there are changes to a business’s
network infrastructure. However, cyber-attacks are increasing among all
sizes of businesses, and this needs to be considered when designing a
testing plan.
Must
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ID Criteria Implementation Guidance
Must /
Should
4.4
Cybersecurity policies should address how a Member shares
information on cybersecurity threats with the government
and other business partners.
Members are encouraged to share information on cybersecurity threats
with the government and business partners within their supply chain.
Information sharing is a key part of the Department of Homeland
Security's mission to create shared situational awareness of malicious
cyber activity. CTPAT Members may want to join the National
Cybersecurity and Communications Integration Center (NCCIC -
https://www.us-cert.gov/nccic). The NCCIC shares information among
public and private sector partners to build awareness of vulnerabilities,
incidents, and mitigations. Cyber and industrial control systems users can
subscribe to information products, feeds, and services at no cost.
Should
4.5
A system must be in place to identify unauthorized access of
IT systems/data or abuse of policies and procedures including
improper access of internal systems or external websites and
tampering or altering of business data by employees or
contractors. All violators must be subject to appropriate
disciplinary actions.
Must
4.6
Cybersecurity policies and procedures must be reviewed
annually, or more frequently, as risk or circumstances
dictate. Following the review, policies and procedures must
be updated if necessary.
An example of a circumstance that would dictate a policy update sooner
than annually is a cyber attack. Using the lessons learned from the attack
would help strengthen a Member’s cybersecurity policy.
Must
4.7
User access must be restricted based on job description or
assigned duties. Authorized access must be reviewed on a
regular basis to ensure access to sensitive systems is based
on job requirements. Computer and network access must be
removed upon employee separation.
Must
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ID Criteria Implementation Guidance
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Should
4.8
Individuals with access to Information Technology (IT)
systems must use individually assigned accounts.
Access to IT systems must be protected from infiltration via
the use of strong passwords, passphrases, or other forms of
authentication, and user access to IT systems must be
safeguarded.
Passwords and/or passphrases must be changed as soon as
possible if there is evidence of compromise or reasonable
suspicion of a compromise exists.
To guard IT systems against infiltration, user access must be safeguarded
by going through an authentication process. Complex login passwords or
passphrases, biometric technologies, and electronic ID cards are three
different types of authentication processes. Processes that use more
than one measure are preferred. These are referred to as two-factor
authentication (2FA) or multi-factor authentication (MFA). MFA is the
most secure because it requires a user to present two or more pieces of
evidence (credentials) to authenticate the person’s identity during the
log-on process.
MFAs can assist in closing network intrusions exploited by weak
passwords or stolen credentials. MFAs can assist in closing these attack
vectors by requiring individuals to augment passwords or passphrases
(something you know) with something you have, like a token, or one of
your physical features - a biometric.
If using passwords, they need to be complex. The National Institute of
Standards and Technology's (NIST) NIST Special Publication 800-63B:
Digital Identity Guidelines, includes password guidelines
(https://pages.nist.gov/800-63-3/sp800-63b.html
). It recommends the
use of long, easy to remember passphrases instead of words with special
characters. These longer passphrases (NIST recommends allowing up to
64 characters in length) are considered much harder to crack because
they are made up of an easily memorized sentence or phrase.
Must
4.9
Members that allow their users to remotely connect to a
network must employ secure technologies, such as virtual
private networks (VPNs), to allow employees to access the
company’s intranet securely when located outside of the
office. Members must also have procedures designed to
prevent remote access from unauthorized users.
VPNs are not the only choice to protect remote access to a network.
Multi-factor authentication (MFA) is another method. An example of a
multi-factor authentication would be a token with a dynamic security
code that the employee must type in to access the network.
Must
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ID Criteria Implementation Guidance
Must /
Should
4.10
If Members allow employees to use personal devices to
conduct company work, all such devices must adhere to the
company’s cybersecurity policies and procedures to include
regular security updates and a method to securely access the
company’s network.
Personal devices include storage media like CDs, DVDs, and USB flash
drives. Care must be taken if employees are allowed to connect their
personal media to individual systems since these data storage devices
may be infected with malware that could propagate using the company’s
network.
Must
4.11
Cybersecurity policies and procedures should include
measures to prevent the use of counterfeit or improperly
licensed technological products.
Computer software is intellectual property (IP) owned by the entity that
created it. Without the express permission of the manufacturer or
publisher, it is illegal to install software, no matter how it is acquired.
That permission almost always takes the form of a license from the
publisher, which accompanies authorized copies of software. Unlicensed
software is more likely to fail as a result of an inability to update. It is
more prone to contain malware, rendering computers and their
information useless. Expect no warranties or support for unlicensed
software, leaving your company on its own to deal with failures. There
are legal consequences for unlicensed software as well, including stiff
civil penalties and criminal prosecution. Software pirates increase costs
to users of legitimate, authorized software and decrease the capital
available to invest in research and development of new software.
Members may want to have a policy that requires product key labels and
certificates of authenticity to be kept when new media is purchased. CDs,
DVDs, and USB media include holographic security features to help
ensure you receive authentic products and to protect against
counterfeiting.
Should
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ID Criteria Implementation Guidance
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4.12
Data should be backed up once a week or as appropriate. All
sensitive and confidential data should be stored in an
encrypted format.
Data backups should take place as data loss may affect individuals within
an organization differently. Daily backups are also recommended in case
production or shared servers are compromised/lose data. Individual
systems may require less frequent backups, depending on what type of
information is involved.
Media used to store backups should preferably be stored at a facility
offsite. Devices used for backing up data should not be on the same
network as the one used for production work. Backing up data to a cloud
is acceptable as an “offsite” facility.
Should
4.13
All media, hardware, or other IT equipment that contains
sensitive information regarding the import/export process
must be accounted for through regular inventories. When
disposed, they must be properly sanitized and/or destroyed
in accordance with the National Institute of Standards and
Technology (NIST) Guidelines for Media Sanitization or other
appropriate industry guidelines.
Some types of computer media are hard drives, removable drives, CD-
ROM or CD-R discs, DVDs, or USB drives.
The National Institute for Systems and Technology (NIST) has developed
the government’s data media destruction standards. Members may
want to consult NIST standards for sanitization and destruction of IT
equipment and media.
Media Sanitization:
https://www.nist.gov/publications/nist-special-publication-800-88-
revision-1-guidelines-media-sanitization
Must
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Second Focus Area: Transportation Security
5. Conveyance and Instruments of International Traffic Security – Smuggling schemes often involve the modification of conveyances
and Instruments of International Traffic (IIT), or the hiding of contraband inside IIT. This criteria category covers security measures
designed to prevent, detect, and/or deter the altering of IIT structures or surreptitious entry into them, which could allow the
introduction of unauthorized material or persons.
At the point of stuffing/loading, procedures need to be in place to inspect IIT and properly seal them. Cargo in transit or “at rest” is
under less control, and is therefore more vulnerable to infiltration, which is why seal controls and methods to track
cargo/conveyances in transit are key security criteria.
Breaches in supply chains occur most often during the transportation process; therefore, Members must be vigilant that these key
cargo criteria be upheld throughout their supply chains.
Key Definition: Instruments of International Traffic (IIT) – IIT includes containers, flatbeds, unit load devices (ULDs), lift vans, cargo
vans, shipping tanks, bins, skids, pallets, caul boards, cores for textile fabrics, or other specialized containers arriving (loaded or
empty), in use or to be used in the shipment of merchandise in international trade.
ID Criteria Implementation Guidance
Must /
Should
5.1
Conveyances and Instruments of International Traffic (IIT) must be
stored in a secure area to prevent unauthorized access, which could
result in an alteration to the structure of an Instrument of
International Traffic or (as applicable) allow the seal/doors to be
compromised.
The secure storage of conveyances and Instruments of
International Traffic (both empty and full) is important to guard
against unauthorized access.
Must
5.2
The CTPAT inspection process must have written procedures for both
security and agricultural inspections.
With the prevalence of smuggling schemes that involve the
modification of conveyances or Instruments of International
Traffic, it is imperative that Members conduct inspections of
conveyances and Instruments of International Traffic to look for
visible pests and serious structural deficiencies. Likewise, the
prevention of pest contamination via conveyances and IIT is of
paramount concern, so an agricultural component has been
Must
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ID Criteria Implementation Guidance
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added to the security inspection process.
Pest contamination is defined as visible forms of animals, insects
or other invertebrates (alive or dead, in any lifecycle stage,
including egg casings or rafts), or any organic material of animal
origin (including blood, bones, hair, flesh, secretions, excretions);
viable or non-viable plants or plant products (including fruit,
seeds, leaves, twigs, roots, bark); or other organic material,
including fungi; or soil, or water; where such products are not the
manifested cargo within instruments of international traffic (i.e.
containers, unit load devices, etc.).
5.3
CTPAT Members must ensure that the following systematic CTPAT
security and agricultural inspections are conducted. Requirements for
these inspections will vary depending upon if the supply chain is land-
based (Canada or Mexico) or if the supply chain originates overseas
(ocean and air modes). Prior to stuffing/packing, all empty
Instruments of International Traffic (IIT) must be inspected, and
conveyances must also be inspected when they are crossing land
borders into the United States.
Inspection requirements for CTPAT shipments via ocean, air, and land
borders (as applicable) by rail or intermodal freight:
A seven-point inspection must be conducted on all empty containers
and unit load devices (ULDs); and an eight-point inspection must be
conducted on all empty refrigerated containers and ULDs:
1. Front wall;
2. Left side;
3. Right side;
4. Floor;
5. Ceiling/Roof;
6. Inside/outside doors, including the reliability of the
locking mechanisms of the doors;
Security and agricultural inspections are conducted on
instruments of international traffic (IIT) and conveyances to
ensure their structures have not been modified to conceal
contraband or have been contaminated with visible agricultural
pests.
Expectations for overseas supply chains are to inspect all
instruments of IIT at the point of stuffing/packing. However, if an
ocean/air based supply chain is higher risk, it may warrant
including more extensive inspection procedures to include
conveyances and/or inspections at marine port terminals or air
logistics facilities. Usually, there are higher levels of risk involved
in shipments with land border crossings, which is why both the
conveyance and IIT undergo multiple inspections.
Some examples of IIT for various modes are ocean containers,
refrigerated containers/trailers, over-the-road trailers, flatbed
trailers, tank containers, rail/boxcars, hoppers, and unit load
devices (ULDs).
The Public Library Section of the CTPAT Portal contains training
material on security and agricultural conveyance/Instruments of
International Traffic inspections.
Must
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ID Criteria Implementation Guidance
Must /
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7. Outside/Undercarriage; and
8. Fan housing on refrigerated containers.
Additional inspection requirements for land border crossings via
highway carriers:
Inspections of conveyances and IIT must be conducted at
conveyance/IIT storage yards.
Where feasible, inspections must be conducted upon entering and
departing the storage yards and at the point of loading/stuffing.
These systematic inspections must include 17-point inspections:
Tractors:
1. Bumper/tires/rims;
2. Doors, tool compartments and locking mechanisms;
3. Battery box;
4. Air breather;
5. Fuel tanks;
6. Interior cab compartments/sleeper; and
7. Faring/roof.
Trailers:
1. Fifth wheel area - check natural compartment/skid plate;
2. Exterior - front/sides;
3. Rear - bumper/doors;
4. Front wall;
5. Left side;
6. Right side;
7. Floor;
8. Ceiling/roof;
9. Inside/outside doors and locking mechanisms; and
10.Outside/Undercarriage.
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ID Criteria Implementation Guidance
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5.4
Conveyances and Instruments of International Traffic (as appropriate)
must be equipped with external hardware that can reasonably
withstand attempts to remove it. The door, handles, rods, hasps,
rivets, brackets, and all other parts of a container’s locking mechanism
must be fully inspected to detect tampering and any hardware
inconsistencies prior to the attachment of any sealing device.
Consider using containers/trailers with tamper resistant hinges.
Members may also place protective plates or pins on at least two
of the hinges of the doors and/or place adhesive seal/tape over
at least one hinge on each side.
Must
5.5
The inspection of all conveyances and empty Instruments of
International Traffic should be recorded on a checklist. The following
elements should be documented on the checklist:
• Container/Trailer/Instruments of International Traffic number;
• Date of inspection;
• Time of inspection;
• Name of employee conducting the inspection; and
• Specific areas of the Instruments of International Traffic that were
inspected.
If the inspections are supervised, the supervisor should also sign the
checklist.
The completed container/Instruments of International Traffic
inspection sheet should be part of the shipping documentation
packet. The consignee should receive the complete shipping
documentation packet prior to receiving the merchandise.
Should
5.6
All security inspections should be performed in an area of controlled
access and, if available, monitored via a CCTV system.
Should
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ID Criteria Implementation Guidance
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5.8
Based on risk, management personnel should conduct random
searches of conveyances after the transportation staff have
conducted conveyance/Instruments of International Traffic
inspections.
The searches of the conveyance should be done periodically, with a
higher frequency based on risk. The searches should be conducted at
random without warning, so they will not become predictable. The
inspections should be conducted at various locations where the
conveyance is susceptible: the carrier yard, after the truck has been
loaded, and en route to the United States border.
Supervisory searches of conveyances are conducted to counter
internal conspiracies.
As a best practice, supervisors can hide an item (like a toy or
colored box) in the conveyance to determine if the field test
screener/conveyance operator finds it.
Supervisory personnel could be a security manager, held
accountable to senior management for security, or other
designated management personnel.
Should
5.14
CTPAT Members should work with their transportation providers to
track conveyances from origin to final destination point. Specific
requirements for tracking, reporting, and sharing of data should be
incorporated within terms of service agreements with service
providers.
Should
5.16
For land border shipments that are in proximity to the United States
border, a “no-stop” policy should be implemented with regard to
unscheduled stops.
Cargo at rest is cargo at risk. Scheduled stops would not be
covered by this policy, but would have to be considered in an
overall tracking and monitoring procedure.
Should
5.29
If a credible (or detected) threat to the security of a shipment or
conveyance is discovered, the Member must alert (as soon as feasibly
possible) any business partners in the supply chain that may be
affected and any law enforcement agencies, as appropriate.
Must
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6. Seal Security – The sealing of trailers and containers to attain continuous seal integrity, continues to be a crucial element of a secure
supply chain. Seal security includes having a comprehensive written seal policy that addresses all aspects of seal security, such as using
the correct seals per CTPAT requirements; properly placing a seal on IIT, and verifying that the seal has been affixed properly.
ID Criteria
Implementation
Guidance
Must /
Should
6.1
CTPAT Members must have detailed, written high-security seal procedures that
describe how seals are issued and controlled at the facility and during transit.
Procedures must provide the steps to take if a seal is altered, tampered with, or
has the incorrect seal number, including documentation of the event,
communication protocols to partners, and investigation of the incident. The
findings from the investigation must be documented, and any corrective actions
must be implemented as quickly as possible.
These written procedures must be maintained at the local operating level so
that they are easily accessible. Procedures must be reviewed at least once a
year and updated as necessary.
Written seal controls must include the following elements:
Controlling Access to Seals:
• Management of seals is restricted to authorized personnel.
• Secure storage.
Inventory, Distribution, & Tracking (Seal Log):
• Recording the receipt of new seals.
• Issuance of seals recorded in log.
• Track seals via the log.
• Only trained, authorized personnel may affix seals to Instruments of
International Traffic (IIT).
Controlling Seals in Transit:
• When picking up sealed IIT (or after stopping) verify the seal is intact with no
signs of tampering.
• Confirm the seal number matches what is noted on the shipping documents.
Must
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ID Criteria
Implementation
Guidance
Must /
Should
Seals Broken in Transit:
• If a load is examined, record the replacement seal number.
• The driver must immediately notify dispatch when a seal is broken, indicate
who broke the seal, and provide the new seal number.
• The carrier must immediately notify the shipper, broker, and importer of the
seal change and the replacement seal number.
• The shipper must note the replacement seal number in the seal log.
Seal Discrepancies:
• Retain altered or tampered seals to aid in investigations.
• Investigate the discrepancy; follow-up with corrective measures (if
warranted).
• As applicable, report compromised seals to CBP and the appropriate foreign
government to aid in the investigation.
6.2
All CTPAT shipments that can be sealed must be secured immediately after
loading/stuffing/packing by the responsible party (i.e. the shipper or packer
acting on the shipper’s behalf) with a high-security seal that meets or exceeds
the most current International Organization for Standardization (ISO) 17712
standard for high-security seals. Qualifying cable and bolt seals are both
acceptable. All seals used must be securely and properly affixed to Instruments
of International Traffic that are transporting CTPAT Members’ cargo to/from the
United States.
The high-security seal used must be placed on the
secure cam position, if available, instead of the right
door handle. The seal must be placed at the bottom of
the center most vertical bar of the right container
door. Alternatively, the seal could be placed on the
center most left-hand locking handle on the right
container door if the secure cam position is not
available. If a bolt seal is being used, it is
recommended that the bolt seal be placed with the
barrel portion or insert facing upward with the barrel
portion above the hasp.
Must
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ID Criteria
Implementation
Guidance
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Should
6.5
CTPAT Members (that maintain seal inventories) must be able to document that
the high-security seals they use meet or exceed the most current ISO 17712
standard.
Acceptable evidence of compliance is a copy of a
laboratory testing certificate that demonstrates
compliance with the ISO high-security seal standard.
CTPAT Members are expected to be aware of the
tamper indicative features of the seals they purchase.
Must
6.6
If a Member maintains an inventory of seals, company management or a
security supervisor must conduct a seal audit that includes periodic inventory of
stored seals and reconciliation against seal inventory logs and shipping
documents. All audits must be documented.
As part of the overall seal audit process, dock supervisors and/or warehouse
managers must periodically verify seal numbers used on conveyances and
Instruments of International Traffic.
Must
6.7
CTPAT’s seal verification process must be followed to ensure all high-security
seals (bolt/cable) have been affixed properly to Instruments of International
Traffic, and are operating as designed. The procedure is known as the VVTT
process:
V – View seal and container locking mechanisms; ensure they are OK;
V – Verify seal number against shipment documents for accuracy;
T – Tug on seal to make sure it is affixed properly;
T – Twist and turn the bolt seal to make sure its components do not unscrew,
separate from one another, or any part of the seal becomes loose.
When applying cable seals, they need to envelop the
rectangular hardware base of the vertical bars in order
to eliminate any upward or downward movement of
the seal. Once the seal is applied, make sure that all
slack has been removed from both sides of the cable.
The VVTT process for cable seals needs to ensure the
cables are taut. Once it has been properly applied, tug
and pull the cable in order to determine if there is any
cable slippage within the locking body.
Must
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7. Procedural Security – Procedural Security encompasses many aspects of the import-export process, documentation, and cargo
storage and handling requirements. Other vital procedural criteria pertain to reporting incidents and notification to pertinent law
enforcement. Additionally, CTPAT often requires that procedures be written because it helps maintain a uniform process over time.
Nevertheless, the amount of detail needed for these written procedures will depend upon various elements such as a company’s
business model or what is covered by the procedure.
CTPAT recognizes that the technology used in supply chains continues to evolve. The terminology used throughout the criteria
references written, paper-based procedures, documents, and forms. Electronic documents and signatures, and other digital
technologies, however, are also acceptable ways to document required procedures.
The CTPAT program is not designed to be a “one size fits all” model. Each company must decide (based on its risk assessment) how
to implement and maintain procedures. However, it is more effective to incorporate security processes within existing procedures
rather than create a separate manual for security protocols. This creates a more sustainable structure and helps emphasize that
supply chain security is everyone’s responsibility.
ID Criteria Implementation Guidance
Must /
Should
7.1
When cargo is staged overnight, or for an extended period of time,
measures must be taken to secure the cargo from unauthorized access.
Must
7.2
Cargo staging areas, and the immediate surrounding areas, must be
inspected on a regular basis to ensure these areas remain free of visible
pest contamination.
Preventative measures such as the use of baits, traps, or
other barriers can be used as necessary. Removal of weeds
or reduction of overgrown vegetation may help in the
elimination of pest habitat within staging areas.
Must
7.4
The loading/stuffing of cargo into containers/IIT should be supervised by a
security officer/manager or other designated personnel.
Should
7.5
As documented evidence of the properly installed seal, digital
photographs should be taken at the point of stuffing. To the extent
feasible, these images should be electronically forwarded to the
destination for verification purposes.
Photographic evidence may include pictures taken at the
point of stuffing to document evidence of the cargo
markings, the loading process, the location where the seal
was placed, and properly installed seal.
Should
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ID Criteria Implementation Guidance
Must /
Should
7.6
Procedures must be in place to ensure that all information used in the
clearing of merchandise/cargo is legible; complete; accurate; protected
against the exchange, loss, or introduction of erroneous information; and
reported on time.
Must
7.7
If paper documents are used, forms and other import/export related
documentation should be secured to prevent unauthorized use.
Measures, such as using a locked filing cabinet, can be taken
to secure the storage of unused forms, including manifests,
to prevent unauthorized use of such documentation.
Should
7.8
The shipper or its agent must ensure that bill of ladings (BOLs) and/or
manifests accurately reflect the information provided to the carrier, and
carriers must exercise due diligence to ensure these documents are
accurate. BOLs and manifests must be filed with U.S. Customs and Border
Protection (CBP) in a timely manner. BOL information filed with CBP must
show the first foreign location/facility where the carrier takes possession
of the cargo destined for the United States. The weight and piece count
must be accurate.
When picking up sealed Instruments of International Traffic,
carriers may rely on the information provided in the
shipper's shipping instructions.
Requiring the seal number to be electronically printed on
the BOL or other export documents helps guard against
changing the seal and altering the pertinent document(s) to
match the new seal number.
However, for certain supply chains, goods may be examined
in transit, by a foreign Customs authority, or by CBP. Once
the seal is broken by the government, there needs to be a
process to record the new seal number applied to the IIT
after examination. In some cases, this may be handwritten.
Must
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ID Criteria Implementation Guidance
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7.10
Personnel must review the information included in import/export
documents to identify or recognize suspicious cargo shipments.
Relevant personnel must be trained on how to identify information in
shipping documents, such as manifests, that might indicate a suspicious
shipment.
Based on risk, CTPAT Members should take into account those CTPAT key
warning indicators for money laundering and terrorism financing activities
most applicable to the functions that they and/or their business entities
perform in the supply chain. A document on key warning indicators is
available in the CTPAT Portal (Public Library section).
Highway carrier personnel must be trained to review manifests and other
documents in order to identify or recognize suspicious cargo shipments
such as those that:
• Originate from or have unusual destination locations;
• Are paid by cash or a certified check;
• Use unusual routing methods;
• Exhibit unusual shipping/receiving practices;
• Provide vague, generalized, or a lack of information.
Must
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ID Criteria Implementation Guidance
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7.23
CTPAT Members must have written procedures for reporting an incident,
which includes a description of the facility's internal escalation process.
A notification protocol must be in place to report any suspicious activities
or security incidents (such as drug seizures, discovery of stowaways, etc.)
that take place anywhere around the world and which affects the security
of the Member’s supply chain. As applicable, the Member must report
any global incidents to its Supply Chain Security Specialist, the closest port
of entry, any pertinent law enforcement agencies, and business partners
that may be part of the affected supply chain. Notifications
to CBP must
be made as soon as feasibly possible and in advance of any conveyance or
IIT crossing the border.
Notification procedures must include the accurate contact information
that lists the name(s) and phone number(s) of personnel requiring
notification, as well as for law enforcement agencies. Procedures must be
periodically reviewed to ensure contact information is accurate.
Examples of incidents warranting notification to U.S.
Customs and Border Protection include (but are not limited
to) the following:
• Discovery of tampering with a container/IIT or high-
security seal;
• Discovery of a hidden compartment in a conveyance or
IIT;
• An unaccounted new seal has been applied to an IIT;
• Smuggling of contraband, including people; stowaways;
• Unauthorized entry into conveyances, locomotives,
vessels, or aircraft carriers;
• Extortion, payments for protection, threats, and/or
intimidation;
• Unauthorized use of a business entity identifier (i.e.,
Importer of Record (IOR) number, Standard Carrier Alpha
(SCAC) code, etc.).
Must
7.24
Procedures must be in place to identify, challenge, and address
unauthorized/unidentified persons. Personnel must know the protocol to
challenge an unknown/unauthorized person, how to respond to the
situation, and be familiar with the procedure for removing an
unauthorized individual from the premises.
Must
7.25
CTPAT Members should set up a mechanism to report security related
issues anonymously. When an allegation is received, it should be
investigated, and if applicable, corrective actions should be taken.
Internal problems such as theft, fraud, and internal
conspiracies may be reported more readily if the reporting
party knows the concern may be reported anonymously.
Members can set up a hotline program or similar
mechanism that allows people to remain anonymous if they
fear reprisal for their actions. It is recommended that any
report be kept as evidence to document that each reported
item was investigated and that corrective actions were
taken.
Should
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ID Criteria Implementation Guidance
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7.27
All shortages, overages, and other significant discrepancies or anomalies
must be investigated and resolved, as appropriate.
Must
7.28
Arriving cargo should be reconciled against information on the cargo
manifest. Departing cargo should be verified against purchase or delivery
orders.
Should
7.29
Seal numbers assigned to specific shipments should be transmitted to the
consignee prior to departure.
Should
7.30
Seal numbers should be electronically printed on the bill of lading or other
shipping documents.
Should
7.37
Members must initiate their own internal investigations of any security-
related incidents (terrorism, narcotics, stowaways, absconders, etc.)
immediately after becoming aware of the incident. The company
investigation must not impede/interfere with any investigation conducted
by a government law enforcement agency. The internal company
investigation must be documented, completed as soon as feasibly
possible, and made available to CBP/CTPAT and any other law
enforcement agency, as appropriate, upon request.
Must
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8. Agricultural Security – Agriculture is the largest industry and employment sector in the U.S. It is also an industry threatened by
the introduction of foreign animal and plant contaminants such as soil, manure, seeds, and plant and animal material which may
harbor invasive and destructive pests and diseases. Eliminating contaminants in all conveyances and in all types of cargo may
decrease CBP cargo holds, delays, and commodity returns or treatments. Ensuring compliance with CTPAT’s agricultural
requirements will also help protect a key industry in the U.S. and the overall global food supply.
Key Definition: Pest contamination – The International Maritime Organization defines pest contamination as visible forms of
animals, insects or other invertebrates (alive or dead, in any lifecycle stage, including egg casings or rafts), or any organic material
of animal origin (including blood, bones, hair, flesh, secretions, excretions); viable or non-viable plants or plant products
(including fruit, seeds, leaves, twigs, roots, bark); or other organic material, including fungi; or soil, or water; where such products
are not the manifested cargo within instruments of international traffic (i.e. containers, unit load devices, etc.).
ID Criteria Implementation Guidance
Must /
Should
8.1
CTPAT Members must, in
accordance with their
business model, have written
procedures designed to
prevent visible pest
contamination to include
compliance with Wood
Packaging Materials (WPM)
regulations. Visible pest
prevention measures must be
adhered to throughout the
supply chain. Measures
regarding WPM must meet
the International Plant
Protection Convention’s
(IPPC) International Standards
for Phytosanitary Measures
No. 15 (ISPM 15).
WPM is defined as wood or wood products (excluding paper products) used in supporting, protecting,
or carrying a commodity. WPM includes items such as pallets, crates, boxes, reels, and dunnage.
Frequently, these items are made of raw wood that may not have undergone sufficient processing or
treatment to remove or kill pests, and therefore remain a pathway for the introduction and spread of
pests. Dunnage in particular has been shown to present a high risk of introduction and spread of pests.
The IPPC is a multilateral treaty overseen by the United Nation’s Food and Agriculture Organization
that aims to secure coordinated, effective action to prevent and to control the introduction and spread
of pests and contaminants.
ISPM 15 includes internationally accepted measures that may be applied to WPM to reduce
significantly the risk of introduction and spread of most pests that may be associated with WPM. ISPM
15 affects all wood packaging material requiring that they be debarked and then heat treated or
fumigated with methyl bromide and stamped or branded with the IPPC mark of compliance. This mark
of compliance is colloquially known as the "wheat stamp". Products exempt from the ISPM 15 are
made from alternative materials, like paper, metal, plastic or wood panel products (i.e. oriented strand
board, hardboard, and plywood).
Must
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Third Focus Area: People and Physical Security
9. Physical Security – Cargo handling and storage facilities, Instruments of International Traffic storage areas, and facilities where
import/export documentation is prepared in domestic and foreign locations must have physical barriers and deterrents that guard
against unauthorized access.
One of the cornerstones of CTPAT is flexibility, and security programs should be customized to fit each company’s circumstances.
The need for physical security can vary greatly based on the Member’s role in the supply chain, its business model, and level of risk.
The physical security criteria provides a number of deterrents/obstacles that will help prevent unwarranted access to cargo,
sensitive equipment, and/or information, and Members should employ these security measures throughout their supply chains.
ID Criteria Implementation Guidance
Must /
Should
9.1
All cargo handling and storage facilities, including trailer yards and
offices must have physical barriers and/or deterrents that prevent
unauthorized access.
Must
9.2
Perimeter fencing should enclose the areas around cargo handling
and storage facilities. If a facility handles cargo, interior fencing
should be used to secure cargo and cargo handling areas. Based
on risk, additional interior fencing should segregate various types
of cargo such as domestic, international, high value, and/or
hazardous materials. Fencing should be regularly inspected for
integrity and damage by designated personnel. If damage is found
in the fencing, repairs should be made as soon as possible.
Other acceptable barriers may be used instead of fencing, such as
a dividing wall or natural features that are impenetrable or,
otherwise, impede access such as a steep cliff or dense thickets.
Should
9.4
Gates where vehicles and/or personnel enter or exit (as well as
other points of egress) must be manned or monitored. Individuals
and vehicles may be subject to search in accordance with local and
labor laws.
It is recommended that the number of gates be kept to the
minimum necessary for proper access and safety. Other points of
egress would be entrances to facilities that are not gated.
Must
9.5
Private passenger vehicles should be prohibited from parking in or
adjacent to cargo handling and storage areas, and conveyances.
Locate parking areas outside of fenced and/or operational areas -
or at least at substantial distances from cargo handling and
storage areas.
Should
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ID Criteria Implementation Guidance
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9.6
Adequate lighting must be provided inside and outside the facility
including, as appropriate, the following areas: entrances and exits,
cargo handling and storage areas, fence lines, and parking areas.
Automatic timers or light sensors that automatically turn on
appropriate security lights are useful additions to lighting
apparatus.
Must
9.7
Security technology should be used to monitor premises and
prevent unauthorized access to sensitive areas.
Electronic security technology used to secure/monitor sensitive
areas and access points includes: burglary alarm systems
(perimeter and interior) –these are also known as Intrusion
Detection Systems (IDS); access control devices; and video
surveillance systems (VSS) -including Closed Circuit Television
Cameras (CCTVs). A CCTV/VSS system could include components
such as Analog Cameras (coax-based), Internet Protocol-based
(IP) cameras (network-based), recording devices, and video
management software.
Secure/sensitive areas, which would benefit from video
surveillance, may include: cargo handling and storage areas,
shipping/receiving areas where import documents are kept, IT
servers, yard and storage areas for Instruments of International
Traffic (IIT), areas where IIT are inspected, and seal storage areas.
Should
9.8
Members who rely on security technology for physical security
must have written policies and procedures governing the use,
maintenance, and protection of this technology.
At a minimum, these policies and procedures must stipulate:
• That access to the locations where the technology is controlled
or managed is limited to authorized personnel;
• The procedures that have been implemented to test/inspect the
technology on a regular basis;
• That the inspections include verifications that all of the
equipment is working properly, and if applicable, that the
Security technology needs to be tested on a regular basis to
ensure it is working properly. There are general guidelines to
follow:
• Test security systems after any service work and during and
after major repairs, modifications, or additions to a building or
facility. A system’s component may have been compromised,
either intentionally or unintentionally.
• Test security systems after any major changes to phone or
internet services. Anything that might affect the system’s ability
to communicate with the monitoring center should be double-
checked.
Must
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ID Criteria Implementation Guidance
Must /
Should
equipment is positioned correctly;
• That the results of the inspections and performance testing is
documented;
• That if corrective actions are necessary, they are to be
implemented as soon as possible and the corrective actions are
documented;
• That the documented results of these inspections be maintained
for a sufficient time for audit purposes.
If a third party central monitoring station (off-site) is used, the
CTPAT Member must have written procedures stipulating critical
systems functionality and authentication protocols such as (but
not limited to) security code changes, adding or subtracting
authorized personnel, password revisions, and systems access or
denials.
Security technology policies and procedures must be reviewed and
updated annually, or more frequently, as risk or circumstances
dictate.
• Make sure video settings such as motion activated recording;
motion detection alerts; images per second (IPS), and quality
level, have been set up properly.
• Make sure camera lenses (or domes that protect the cameras)
are clean and lenses are focused. Visibility should not be limited
by obstacles or bright lights.
• Test to make sure security cameras are positioned correctly and
remain in the proper position (cameras may have been
deliberately or accidentally moved).
9.9
CTPAT Members should use licensed/certified resources when
considering the design and installation of security technology.
Today’s security technology is complex and evolves rapidly.
Oftentimes companies purchase the wrong security technology
that proves to be ineffective when needed and/or pay more than
necessary. Seeking qualified guidance will help a buyer select the
right technology options for their needs and budget.
According to the National Electrical Contractors Association
(NECA), in the U.S. 33 states currently have licensing
requirements for professionals engaged in the installation of
security and alarm systems.
Should
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9.10
All security technology infrastructure must be physically secured
from unauthorized access.
Security technology infrastructure includes computers, security
software, electronic control panels, video surveillance or closed
circuit television cameras, power and hard drive components for
cameras, as well as recordings.
Must
9.11
Security technology systems should be configured with an
alternative power source that will allow the systems to continue to
operate in the event of an unexpected loss of direct power.
A criminal trying to breach your security may attempt to disable
the power to your security technology in order to circumnavigate
it. Thus, it is important to have an alternative source of power
for your security technology. An alternative power source may
be an auxiliary power generation source or backup batteries.
Backup power generators may also be used for other critical
systems such as lighting.
Should
9.12
If camera systems are deployed, cameras should monitor a
facility’s premises and sensitive areas to deter unauthorized
access. Alarms should be used to alert a company to unauthorized
access into sensitive areas.
Sensitive areas, as appropriate, may include cargo handling and
storage areas, shipping/receiving areas where import documents
are kept, IT servers, yards and storage areas for Instruments of
International Traffic (IIT), areas where IIT are inspected, and seal
storage areas.
Should
9.13
If camera systems are deployed, cameras must be positioned to
cover key areas of facilities that pertain to the import/export
process.
Cameras should be programmed to record at the highest picture
quality setting reasonably available, and be set to record on a 24/7
basis.
Positioning cameras correctly is important to enable the cameras
to record as much as possible of the physical “chain of custody”
within the facility’s control.
Based on risk, key areas or processes may include cargo handling
and storage; shipping/receiving; the cargo loading process; the
sealing process; conveyance arrival/exit; IT servers; container
inspections (security and agricultural); seal storage; and any
other areas that pertain to securing international shipments.
Must
9.14
If camera systems are deployed, cameras should have an
alarm/notification feature, which would signal a “failure to
operate/record” condition.
A failure of video surveillance systems could be the result of
someone disabling the system in order to breach a supply chain
without leaving video evidence of the crime. The failure to
operate feature can result in an electronic notification sent to
predesignated person(s) notifying them that the device requires
immediate attention.
Should
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9.15
If camera systems are deployed, periodic, random reviews of the
camera footage must be conducted (by management, security, or
other designated personnel) to verify that cargo security
procedures are being properly followed in accordance with the
law. Results of the reviews must be summarized in writing to
include any corrective actions taken. The results must be
maintained for a sufficient time for audit purposes.
If camera footage is only reviewed for cause (as part of an
investigation following a security breach etc.), the full benefit of
having cameras is not being realized. Cameras are not only
investigative tools. If used proactively, they may help prevent a
security breach from occurring in the first place.
Focus the random review of the footage on the physical chain of
custody to ensure the shipment remained secure and all security
protocols were followed. Some examples of processes that may
be reviewed are the following:
• Cargo handling activities;
• Container inspections;
• The loading process;
• Sealing process;
• Conveyance arrival/exit; and
• Cargo departure, etc.
Purpose of the review: The review is intended to evaluate overall
adherence and effectiveness of established security processes,
identify gaps or perceived weaknesses, and prescribe corrective
actions in support of improvement to security processes. Based
on risk (previous incidents or an anonymous report on an
employee failing to follow security protocols at the loading dock,
etc.), the Member may target a review periodically.
Items to include in the written summary:
• The date of the review;
• Date of the footage that was reviewed;
• Which camera/area was the recording from;
• Brief description of any findings; and
• If warranted, corrective actions.
Must
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9.16
If cameras are being used, recordings of footage covering key
import/export processes should be maintained on monitored
shipments for a sufficient time to allow an investigation to be
completed.
If a breach were to happen, an investigation would need to be
conducted, and maintaining any camera footage that covered the
packing (for export) and loading/sealing processes would be of
paramount importance in discovering where the supply chain
may have been compromised.
For monitoring, the CTPAT program recommends allotting at
least 14 days after a shipment has arrived at its first point of
distribution. This is where the container is first opened after
clearing Customs.
Should
10. Physical Access Controls – Access controls prevent unauthorized access into facilities/areas, help maintain control of employees and
visitors, and protect company assets. Access controls include the positive identification of all employees, visitors, service providers,
and vendors at all points of entry.
ID Criteria Implementation Guidance
Must /
Should
10.1
CTPAT Members must have written procedures governing how
identification badges and access devices are granted, changed,
and removed.
Where applicable, a personnel identification system must be in
place for positive identification and access control purposes.
Access to sensitive areas must be restricted based on job
description or assigned duties. Removal of access devices must
take place when the employees separate from the company.
Access devices include employee identification badges, visitor and
vendor temporary badges, biometric identification systems,
proximity key cards, codes, and keys. When employees are
separated from a company, the use of exit checklists help ensure
that all access devices have been returned and/or deactivated.
For smaller companies, where personnel know each other, no
identification system is required. Generally, for a company with
more than 50 employees, an identification system is required.
Must
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10.2
Visitors, vendors, and service providers must present photo
identification upon arrival, and a log must be maintained that
records the details of the visit. All visitors should be escorted. In
addition, all visitors and service providers should be issued
temporary identification. If temporary identification is used, it
must be visibly displayed at all times during the visit.
The registration log must include the following:
• Date of the visit;
• Visitor's name;
• Verification of photo identification (type verified such as license
or national ID card). Frequent, well known visitors such as regular
vendors may forego the photo identification, but must still be
logged in and out of the facility;
• Time of arrival;
• Company point of contact; and
• Time of departure.
Must
10.3
Drivers delivering or receiving cargo must be positively identified
before cargo is received or released. Drivers must present
government-issued photo identification to the facility employee
granting access to verify their identity. If presenting a
government-issued photo identification is not feasible, the facility
employee may accept a recognizable form of photo identification
issued by the highway carrier company that employs the driver
picking up the load.
Must
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10.4
A cargo pickup log must be kept to register drivers and record the
details of their conveyances when picking up cargo. When drivers
arrive to pick up cargo at a facility, a facility employee must
register them in the cargo pickup log. Upon departure, drivers
must be logged out. The cargo log must be kept secured, and
drivers must not be allowed access to it.
The cargo pickup log should have the following items recorded:
• Driver's name;
• Date and time of arrival;
• Employer;
• Truck number;
• Trailer number;
• Time of departure;
• The seal number affixed to the shipment at the time of
departure.
A visitor log may double as a cargo log as long as the extra
information is recorded in it.
Must
10.7
Prior to arrival, the carrier should notify the facility of the
estimated time of arrival for the scheduled pick up, the name of
the driver, and truck number. Where operationally feasible,
CTPAT Members should allow deliveries and pickups by
appointment only.
This criterion will help shippers and carriers to avoid fictitious
pickups. Fictitious pick-ups are criminal schemes that result in the
theft of cargo by deception that includes truck drivers using fake
IDs and/or fictitious businesses set up for the purpose of cargo
theft.
When a carrier has regular drivers that pick up goods from a
certain facility, a good practice is for the facility to maintain a list
of the drivers with their pictures. Therefore, if it is not feasible to
let the company know which driver is coming, the company will
still be able to verify that the driver is approved to pick up cargo
from the facility.
Should
10.8
Arriving packages and mail should be periodically screened for
contraband before being admitted.
Examples of such contraband include, but are not limited to,
explosives, illegal drugs, and currency.
Should
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10.9
Delivery of goods to the consignee or other persons accepting
delivery of cargo at the partner’s facility should be limited to a
specific monitored area.
Should
10.10
If security guards are used, work instructions for security guards
must be contained in written policies and procedures.
Management must periodically verify compliance and
appropriateness with these procedures through audits and policy
reviews.
Though guards may be employed at any facility, they are often
employed at manufacturing sites, seaports, distribution centers,
storage yards for Instruments of International Traffic,
consolidator, and forwarders operating sites.
Must
11. Personnel Security – A company’s human resource force is one of its most critical assets, but it may also be one of its weakest
security links. The criteria in this category focus on issues such as employee screening and pre-employment verifications.
Many security breaches are caused by internal conspiracies, which is where one or more employees collude to circumvent security
procedures aimed at allowing an infiltration of the supply chain. Therefore, Members must exercise due diligence to verify that
employees filling sensitive positions are reliable and trustworthy. Sensitive positions include staff working directly with cargo or its
documentation, as well as personnel involved in controlling access to sensitive areas or equipment. Such positions include, but are
not limited to, shipping, receiving, mailroom personnel, drivers, dispatch, security guards, any individuals involved in load
assignments, tracking of conveyances, and/or seal controls.
ID Criteria Implementation Guidance
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Should
11.1
Written processes must be in place to screen prospective
employees and to periodically check current employees.
Application information, such as employment history and
references, must be verified prior to employment, to the extent
possible and allowed under the law.
CTPAT is aware that labor and privacy laws in certain countries may
not allow all of the application information to be verified.
However, due diligence is expected to verify application
information when permitted.
Must
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11.2
In accordance with applicable legal limitations, and the availability
of criminal record databases, employee background screenings
should be conducted. Based on the sensitivity of the position,
employee vetting requirements should extend to temporary
workforce and contractors. Once employed, periodic
reinvestigations should be performed based on cause, and/or the
sensitivity of the employee’s position.
Employee background screening should include verification of the
employee’s identity and criminal history, encompassing city, state,
provincial, and country databases. CTPAT Members and their
business partners should factor in the results of background
checks, as permitted by local statutes, in making hiring decisions.
Background checks are not limited to verification of identity and
criminal records. In areas of greater risk, it may warrant more in-
depth investigations.
Should
11.5
CTPAT Members must have an Employee Code of Conduct that
includes expectations and defines acceptable behaviors. Penalties
and disciplinary procedures must be included in the Code of
Conduct. Employees/contractors must acknowledge that they
have read and understood the Code of Conduct by signing it, and
this acknowledgement must be kept in the employee’s file for
documentation.
A Code of Conduct helps protect your business and informs
employees of expectations. Its purpose is to develop and maintain
a standard of conduct that is acceptable to the company. It helps
companies develop a professional image and establish a strong
ethical culture. Even a small company needs to have a Code of
Conduct; however, it does not need to be elaborate in design or
contain complex information.
Must
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12. Education, Training and Awareness – CTPAT’s security criteria are designed to form the basis of a layered security system. If one
layer of security is overcome, another layer should prevent a security breach, or alert a company to a breach. Implementing and
maintaining a layered security program needs the active participation and support of several departments and various personnel.
One of the key aspects to maintaining a security program is training. Educating employees on what the threats are and how their
role is important in protecting the company’s supply chain is a significant aspect to the success and endurance of a supply chain
security program. Moreover, when employees understand why security procedures are in place, they are much more likely to
adhere to them.
ID Criteria Implementation Guidance
Must /
Should
12.1
Members must establish and maintain a security training and
awareness program to recognize and foster awareness of the
security vulnerabilities to facilities, conveyances, and cargo at
each point in the supply chain, which could be exploited by
terrorists or contraband smugglers. The training program must be
comprehensive and cover all of CTPAT’s security requirements.
Personnel in sensitive positions must receive additional
specialized training geared toward the responsibilities that the
position holds.
One of the key aspects of a security program is training.
Employees who understand why security measures are in place
are more likely to adhere to them. Security training must be
provided to employees, as required, based on their functions and
position on a regular basis, and newly hired employees must
receive this training as part of their orientation/job skills training.
Members must retain evidence of training such as training logs,
sign in sheets (roster), or electronic training records. Training
records should include the date of the training, names of
attendees, and the topics of the training.
Training topics may include protecting access controls, recognizing
internal conspiracies, and reporting procedures for suspicious
activities and security incidents. When possible, specialized training
should include a hands-on demonstration. If a hands-on
demonstration is conducted, the instructor should allow time for
the students to demonstrate the process.
For CTPAT purposes, sensitive positions include staff working
directly with import/export cargo or its documentation, as well as
personnel involved in controlling access to sensitive areas or
equipment. Such positions include, but are not limited to, shipping,
receiving, mailroom personnel, drivers, dispatch, security guards,
any individuals involved in load assignments, tracking of
conveyances, and/or seal controls.
Must
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12.2
Drivers and other personnel that conduct security and agricultural
inspections of empty conveyances and Instruments of
International Traffic (IIT) must be trained to inspect their
conveyances/IIT for both security and agricultural purposes.
Refresher training must be conducted periodically, as needed
after an incident or security breach, or when there are changes to
company procedures.
Inspection training must include the following topics:
• Signs of hidden compartments;
• Concealed contraband in naturally occurring compartments; and
• Signs of pest contamination.
Must
12.4
CTPAT Members should have measures in place to verify that the
training provided met all training objectives.
Understanding the training and being able to use that training in
one’s position (for sensitive employees) is of paramount
importance. Exams or quizzes, a simulation exercise/drill, or regular
audits of procedures etc. are some of the measures that the
Member may implement to determine the effectiveness of the
training.
Should
12.6
Specialized training should be provided annually to personnel who
may be able to identify the CTPAT Warning Indicators of Trade-
Based Money Laundering and Terrorism Financing.
Examples of personnel who should receive this training include
those responsible for trade compliance, security, procurement,
finance, shipping, and receiving. Members may take into account
the CTPAT Warning Indicators for Trade-Based Money Laundering
and Terrorism Financing Activities document.
Should
12.7
Training must, in accordance with the Member’s business model,
be provided to applicable personnel on preventing visible pest
contamination. Training must encompass pest prevention
measures, regulatory requirements applicable to wood packaging
materials (WPM), and identification of infested wood.
U.S. Customs and Border Protection has collaborated with the U.S.
Department of Agriculture to develop training on visible pest
contamination. Different training modules have been developed for
the different trade environments: air, sea, and land border (rail and
highway carrier). These training modules are available to all
Members via the CTPAT Portal.
Must
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12.8
As applicable, based on their functions and/or positions,
personnel must be trained on the company's cybersecurity
policies and procedures. This must include the need for
employees to protect passwords/passphrases and computer
access.
Quality training is important to lessen vulnerability to cyberattacks.
A robust cybersecurity training program is usually one that is
delivered to applicable personnel in a formal setting rather than
simply through emails or memos.
Must
12.9
Personnel operating and managing security technology systems
must receive operations and maintenance training in their specific
areas. Prior experience with similar systems is acceptable. Self-
training via operational manuals and other methods is acceptable.
Must
12.10
Personnel must be trained on how to report security incidents
and suspicious activities.
Procedures to report security incidents or suspicious activity are
extremely important aspects of a security program. Training on
how to report an incident can be included in the overall security
training. Specialized training modules (based on job duties) may
have more detailed training on reporting procedures, including
specifics on the process, such as, what to report, to whom, how to
report the incident, and what to do after the report is completed.
Must
Publication Number 0991-1119