The Commercial Operations Advisory Committee (COAC), working with the Department of Homeland Security’s Customs and Border Protection (CBP), has completed draft versions of rules governing highway and ocean carriers’ compliance with Customs-Trade Partnership Against Terrorism (C-TPAT). Common to both drafts is a requirement that, where a carrier does not control a segment of its supply chain, the carrier must assess and certify partners’ compliance with C-TPAT.
Carriers must have written and verifiable processes to screen partners, says the highway carriers draft. The supply chain carriers will be responsible for extends from the point of origin, from “the yard or where the tractors and trailers are stored, through pickup at the manufacturer/supplier/vendor, through to the point of distribution.” Wherever the carrier doesn’t control a yard, terminal etc., it must work with its partner to ensure proper security measures are in place to protect against introduction of unauthorized personnel and material. Included in the procedures for access control and positive identification of employees, visitors, vendors and service partners.
Conveyance security procedures include inspection of tractors and trailers. Carriers must visually inspect all empty trailers, including interior and exterior, at the truck yard and at the point of loading if possible.
Ocean carriers have similar requirements, including inspection of equipment prior to loading. Those inspections also require verifying the reliability of locking mechanisms.
The drafts described the carriers’ supply chains as extending from point of origin through pickup and loading and on to point of distribution. The ocean carrier draft also stated the sea carrier has ultimate responsibility for all cargo loaded onboard their vessels.
Air and rail mode criteria are also being developed.