Chapter-6:

Security Compliance: C-TPAT

Customs-Trade Partnership Against Terrorism (C-TPAT)
The C-TPAT is a United States “Customs and Border Protection” (CBP) initiative
that stands for “Customs-Trade Partnership Against Terrorism”. It is an initiative
of the US customs service in the wake of the events of September 11 in order to
upgrade the security of commercial shipments against terrorist in filtration. C-
TPAT is a voluntary program where participants work to protect supply chains
from the concealment of terrorist weapons including weapons of mass destruction.
It is also a Government/trade joint initiative to build cooperative relationships that
result in the strengthening of overall supply chain and border security.
C-TPAT is recognition that customs cannot provide the high level of security
without involving the ultimate owners of the supply chain (importers, carriers,
customs brokers, terminal operators, foreign manufacturers etc.).
The customs service is asking business partner to implement improved and
transparent physical security practices and communicate their requirement to
their business partners within supply chain. Areas of consideration include:
Procedural Security, Physical Security, Personal Security, Access Control, Training
etc.
Companies wishing to be C-TPAT participants must complete an application and
conduct a self-assessment of their supply chain security procedures against the C-
TPAT criteria or guidelines jointly developed by CBP and the trade community.
Upon satisfactory completion of the online application, U.S. Customs and Border
Protection, C-TPAT Supply Chain Security Specialist will contact the participant to
begin the validation process.

How it works
When companies join the partnership, companies sign an agreement to work with
CBP to protect the supply chain, identify security gaps, and implement specific
security measures and best practices. Additionally, partners provide CBP with a
security profile outlining the specific security measures the company has in place.
Applicants must address a broad range of security topics and present security
profiles that list action plans to align security throughout their supply chain.
C‐TPAT members are considered low‐risk and are therefore less likely to be
examined. This designation is based on a company’s past compliance history,
security profile.

C-TPAT Conduct
(a) Packing Area (Physical Security):
1) All entry to be restricted in the packing area other than authorized personnel.
2) The entry authorization in the packing area is hanged in the entrance with
photography.
3) The persons working in the packing area to be noted in the register maintained
by security.
4) The entry and exit of persons working in the packing area to be noted in the
register maintained by security.
5) All packed goods to be checked by needle detector before packing.
6) Packing area to be kept under lock & key when not in use.
7) The packing area to be kept under physical security monitoring.
8) The packing area to be kept under the supervision of Close Circuit Camera
(CCTV) and to be recorded with a recording device.

(b) Loading & Unloading Area (physical security)

1) The loading / unloading area must be separated from other/private vehicle

area. No other private vehicle can enter in the loading /unloading area. The
private /other vehicle must be separated from loading /unloading and shipping
vehicle area. There must be physical and visible barrier along with active guard
to monitor which will keep the loading/unloading and shipping area separated
and secured from any kind of unwanted entry .That will ensure safety of the
goods, containers etc. The loading /unloading and shipping area to be
addressed as “Restricted Area “ and unauthorized personnel entry is not
accepted in any circumstances. Both physical, visible barrier and the presence
of security guard jointly must add value to ensure this protection and safety .
2) All Entries to be restricted in loading/unloading area other than authorized
person.
3) Loading & unloading area to be kept under physical security monitoring .
4) The loading & unloading area to be kept under the supervision of Close Circuit
Camera (CCTV) along with a recording device.
5) Before loading any container the following should be considered;
(a) The condition of the container.
(b) The Fitness of the transport.
(c) The valid ‘Driving License’ of the Driver.
6) The loading & unloading of the container to be checked and maintained by
security.
7) Container to be sealed by prescribed seal after loading.
8) All labels and seal of the container to be examined while loading & unloading.
9) The container itself to be checked as per the following criteria (7 point checking
system).
(a) Right side.
(b) Left side.
(c) Front side.
(d) Outside.
(e) Inside.
(f) Ceiling.
(g) Floor.

(c) Access Control

1) Strict monitoring is done in order to improve the access control of the factory.
2) No unauthorized entry of person /vehicle is allowed in the factory
3) For permanent employee of the factory the individual ID Card is checked while
entry to the factory.
4) If anybody of such employee fails or forgets to bring ID, then he / she is
identified by department head before entry.
5) All visitors are to show their Photo ID Card in the security gate to prove their
identity.
6) After their identity is proved then they are to register their name in security
register.
7) After the entry of their name of in the security register they are issued with a
visitor’s card which to be carried by them while visiting.
8) All the vehicle to be checked before entry.
9) All the belongings/bags of visitors to be checked by hand detector.
10) After the end of visiting, the visitor’s card to be handed over to the security gate
before departure.
11) In spite of above, if we find any unauthorized, unidentified person in the
premises, to be dealt with very rapid and definite procedure. Any person entering
or exiting the premises or acting suspiciously or found improperly badged to be
questioned/interrogated.
Primarily this is the job of security personnel of the factory. If security
personnel can find any such suspicious person/outsider/improperly badged
person in the factory to be captured/arrested and preliminary investigation to be
done by security department in consultation with GM (Admin). After preliminary
investigation, the suspicious/ unauthorized person to be handed over to the
security agencies for further disposal. Nevertheless, it is the responsibility of all
members also of the factory to challenge any one found
suspicious/outsider/improperly badged. If any member other than the security
personnel of the factory finds any such suspicious/outsider/ improperly badged
person they will report immediately to the security personnel through their
departmental heads.

(d) Personal Security Related to C-TPAT

1) Personal document to be checked strictly before recruitment.
2) Police investigation of any individual can be obtained if required after
recruitment.
3) Person who is identified as mentally imbalanced cannot be recruited.
4) Addicted person to be identified.
5) All member to show their ID card while entry and will carry ID card in the entire
duty period to prove their identity completely.
6) In case of employee termination, the designation / identification of terminated
employee are recorded immediately.
The list of terminated employee (if any) to be handed over to security department
with photo and security department has to keep record of it. Special attention is to
be given on his (terminated employee) access to the factory after termination. The
security check posts are to be made alert about his access to the factory. In the
event of such access the clearance of factory top management to be taken prior the
entry. Re-employment of terminated employee is not done normally. However, the
re-employment can be done with the approval from Chairman/MD/Director of
company in special cases.

(e) Procedural Security (integrity of data)

In the event of shipment, the packing in-charge sends the final packing list to
commercial department and concerned merchandiser for approval. After receiving
the approved packing list from commercial department the packing in-charge
informs to GM (production), GM (admin), Store Manager, Finishing Manager. Store
Manager loads the cargo/container as per the finally approved packing list. The
finally approved packing list is a classified document and it remains with only
authorized department (store), commercial, finishing and merchandising
department.
No unauthorized entry to this document is accepted. No change of this
document is allowed. If any changes to be made, it has to be permitted from
commercial department of head office. Any unauthorized changes of finally
approved packing list to be dealt with severe administrative action against the
individual/department. If there had been any change by commercial department,
the written document / permission to be obtained and record to be maintained.

f) Material Security Related to C-TPAT

1) No material will entry in exit out from the factory without authorized “challan’’.
2) No materials will entry inside factory without security check.
3) In case of chemical, strict adherence to be mentioned. No unauthorized chemical
will enter in the factory without MSDS.
4) All items of the factory to be maintained as per maintenance schedule.
5) Materials to be kept under lock & key when not in use.

(g) Information security Related to C-TPAT

1) Information circulation in the factory should be on “need to know” basis.
2) Every computer must have a password to open.
3) The password to be selected and given by IT manager.
4) Password to be changed quarterly.
5) All member to be motivated and instructed, so that they understand about not
disclosing the factory internal information to outside people.
(h) Usage of seal for Covered Van /Container Security
1) All export & import transport carry shipment goods / imported goods must have
security seal.
2) The security seals are issued by commercial department.
3) This security seals is fixed in the presence of store representative (Store In-
charge), security personnel (Security Supervisor) and Driver of the transport
during export. This security seal is also removed in presence of same group of
personnel in the time of import.
4) In case of broken security seal found in the time of import, the incident to be
informed immediately to commercial department, C&F agent and transport agency.
5) These seals are to be kept under lock & key and strict surveillance to be kept so
that it does not fall on the hand of any unauthorized person.
6) The truck drivers are strictly prohibited from participating in the loading. The
truck drivers cannot enter in to the loading/unloading area as it is declared as
“Restricted’’ for all unauthorized personnel entry. The truck drivers to be kept
away from the designated any restricted loading/unloading area which to be
monitored and guarded by security personnel so that they cannot entry in that
above mentioned restricted area. That will ensure to protect the integrity of the
goods and lower the risk of unauthorized person accessing or tempering with or
damaging goods for shipment.

(i) The C-TPAT Regulation During loading

1) In case of any shipment the store department will prepare three copies of
‘challan’ and all three copies to be sent to security. Security in-charge then hand
over one photocopy of ‘challan’ to the security guard on duty.
2) After the transport is found fit in all respect that will be sent to the loading area.
3) After packing of transport to the loading area the security in-charge and guard
to be present physically.
4) The duty guard will allow the goods to be loaded in the transport as per
‘challan’. He will also check style no, name of buyer, carton no, weight of the
carton before loading into the transport. Any kind of difference in compare to
‘challan’ the security guard will immediately inform the security in-charge.
5) After the termination of loading of all cartons in the transport again the security
in-charge and security guard will finally check it physically and confirm by
counting against ‘challan’.
6) If all clear then the transport will be sealed with authorized seal.
7) The security in-charge and guard will note the vehicle registration no, name of
driver, license no of the driver and exit time in a register and will give permission of
departure of the transport.
8) The escort nominated by factory will accompany with each transport up to the
destination of shipment. Before the departure of the transport the escort is handed
over a copy of ‘challan’. The other two copies remain in the factory.
9) At the time of vehicle departure, the C&F agent to be informed about the details
of shipment vehicle, time, driver particulars etc.