CBP Updates Its C-TPAT Minimum Security Criteria for Rail Carriers to Include Information on Seal Procedures
U.S. Customs and Border Protection has posted a revised version of its Customs-Trade Partnership Against Terrorism (C-TPAT) minimum security for rail carriers.
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(CBP originally posted the minimum security criteria for rail carriers in August 2006. See ITT's Online Archives or 09/05/06 news, 06090510, for BP summary.)
Criteria Updated to Include Additional Information on Seal Procedures
The seals subsection of the "Conveyance Tracking and Monitoring Procedures" section has been updated to include additional information on controlling seal procedures.
The seals subsection now reads as follows:
The sealing of rail cars, and intermodal maritime containers, along with continuous seal integrity are crucial elements of a secure supply chain, and remains a critical aspect of a rail carrier's commitment to C-TPAT. To the extent practical, a high security seal should be affixed to all loaded rail cars bound for the U.S. All seals must meet or exceed the current PAS ISO 177121 standards for high security seals. Rail carriers crossing the U.S. border must also fully comply with seal verification rules and seal anomaly reporting requirements once promulgated and mandated by the U.S. government.
Clearly defined written procedures must stipulate how seals in the rail carrier's possession are to be controlled during transit. These written procedures should be briefed to all rail crewmembers and there should be a mechanism to ensure that these procedures are understood and are being followed. These procedures must include (information below is new):
- Verifying that the seal is intact, and if it exhibits evidence of tampering along the route.
- Properly documenting the original and second seal numbers.
- Verify that the seal number and location of the seal is the same as stated by the shipper on the shipping documents.
- If the seal is removed in-transit to the border, even by government officials, a second seal must be placed on the trailer, and the seal change must be documented.
- Rail crewmembers must immediately notify the dispatcher that a seal was broken; by whom, and the second seal number, which was placed on the rail car.
- The rail carrier must make immediate notification to the shipper, the customs broker and the importer of the placement of the second seal.
Written procedures must stipulate how unapplied seals in the rail carrier's possession are controlled. Rail carriers crossing the U.S. border must also fully comply with seal verification rules and seal anomaly reporting requirements once promulgated and mandated by the U.S. government.
1All maritime containers in transit to the U.S. that arrive by vessel at a port of entry in the U.S. are required to be sealed in accordance with PAS ISO 177121 for mechanical seals. (See ITT's Online Archives or 09/24/08 news, 08092410, for BP summary.)
(See ITT's Online Archives or 03/26/09 news, 09032610, for BP summary of CBP providing a C-TPAT update during a recent teleconference.)
Revised criteria (dated 04/06/09) available at http://www.cbp.gov/xp/cgov/trade/cargo_security/ctpat/security_criteria/sec_criteria_rail/rail_security_criteria.xmlConveyanceTrackingandMonitoringProcedures