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Reminder: Phase 1 of the New C-TPAT Criteria for Highway Carriers Takes Effect for Existing Members on May 12th

In March 2006, U.S. Customs and Border Protection (CBP) issued its new Customs-Trade Partnership Against Terrorism (C-TPAT) minimum security criteria for highway carriers. CBP had also issued an associated implementation plan, which included a three-phase implementation schedule for existing members.

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In its implementation plan, CBP had stated that its new minimum security criteria were effective March 13, 2006 for highway carriers wishing to join the C-TPAT program on or after that date.

For highway carriers that were already C-TPAT members as of that date, having completed and received the memorandum of agreement signed by CBP, CBP had stated that implementation would occur in three phases, as follows:

Phase 1 - Hardening of the Physical Supply Chain (May 12, 2006)

Under the first phase, existing member highway carriers have 60 days from the March 13, 2006 (approximately May 12, 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 (July 12, 2006)

Under phase two, current members will have 120 days from the March 13, 2006 effective date (approximately July 12, 2006) 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 (Sept 12, 2006)

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 (approximately September 12, 2006) to ensure compliance to the following:

Business Partner Requirements

(See ITT's Online Archives or 03/14/06 news, 06031405, for BP summary of the new C-TPAT security criteria for highway carriers, which provides details for the bullet points above.

See ITT's Online Archives or 03/14/06 news, 06031410 for previous BP summary of its implementation plan, including the phased implementation for existing members.)

C-TPAT criteria for highway carriers, implementation plan, FAQ (all dated 03/13/06) available at http://www.cbp.gov/xp/cgov/import/commercial_enforcement/ctpat/security_criteria/hwy_carrier_criteria/

Note: The C-TPAT online application process is temporarily suspended pending implementation of the C-TPAT Security Link Portal. (See ITT's Online Archives or 04/27/06 news, 06042710 for BP summary.)