CBP Issues its Implementation Plan for the New C-TPAT Security Criteria for Highway Carriers (to be Phased-In for Existing Members)

(See today's ITT, 06031405, for BP summary of the new C-TPAT security criteria for highway carriers.)

CBP states that these new minimum security criteria for highway carriers are effective as of March 13, 2006.

For New Highway Carriers Wishing to Join C-TPAT

According to CBP, highway carriers wishing to join the C-TPAT program on or after March 13, 2006, will need to meet or exceed the security criteria before they will be 'certified' and eligible for benefits.

Applications for new membership will only be accepted electronically, via the C-TPAT web-based online application for highway carriers (with the submission of a completed, comprehensive security-profile that is required at time of application.)

For Existing C-TPAT Member Highway Carriers

For highway carriers who are already a member of the C-TPAT program, having completed and received the memorandum of agreement signed by CBP, a gradual, phased implementation approach will be followed which provides existing members more time to address the security measures outlined in the criteria.

The components outlined in the security criteria document have been segmented into three distinct phases, each with their own timeline.

Phase 1 - Hardening of the Physical Supply Chain (60 days)

Under the first phase, existing member highway carriers will have 60 days from the March 13, 2006 effective date to address the following three security areas:

Conveyance Security (seals, trailer security, etc)

Physical Access Controls (employees, visitors, etc)

Physical Security (fencing, lighting, parking, etc.)

Phase 2 - Internal and/or Procedural Elements (120 days)

CBP states that Phase two will address more internal and/or procedural elements. Specifically, under phase two, current members will have 120 days from the March 13, 2006 effective date to ensure compliance with the following criteria:

Personnel Security (background checks, employee hiring, etc.),

Procedural Security (documentation, manifesting procedures, etc.)

Security Training and Threat Awareness

Less-Than Truck Load (LTL)

Information Technology Security (passwords, FAST, etc.)

Phase 3 - Leveraging Security Throughout the Business Partners (180 days)

Phase three will address the remaining and more cumbersome requirement of leveraging security throughout the business partners. Specifically, under phase three highway carriers will have 180 days from the March 13, 2006 effective date to ensure compliance to the following:

Business Partner Requirements

Certifications

CBP states that existing C-TPAT member highway carriers will not be required to provide a written certification that the security criteria have been met, nor will previously submitted and accepted security profiles need to be resubmitted. It will be understood that highway carriers must meet or exceed these baseline security criteria by the end of each implementation phase.

CBP will continue to use validations to gauge whether or not highway carriers have adopted these security criteria. Those highway carriers found to be deficient may have benefits suspended, or be removed from the program entirely.

Highway carriers failing to meet security criteria as evidenced through a validation, or from a resulting seizure due to compromised supply chain security, will have their Free and Secure Trade (FAST) program benefits immediately suspended until notification from the C-TPAT office.

CBP notes that as a voluntary, incentive based supply chain security program, the new C-TPAT security criteria for highway carriers are risk based, flexible, and designed to help CBP achieve its twin goals of security and facilitation. CBP will continue to work with members who demonstrate a commitment towards strengthening their entire supply chain and benefits will be provided accordingly.

Implementation plan for highway carriers (dated 03/13/06) available at

http://www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/hwy_carrier_criteria/criteria_implement_plan.xml.

Information on C-TPAT for U.S.-Canada highway carriers available at http://www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/onlinectpat_app_process/us_canada/.

Information on C-TPAT for U.S.-Mexico highway carriers available at http://www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/onlinectpat_app_process/us_mexico/.