need serious upgrading. C-TPAT directives get very spe-cific
about tools, techniques, and processes related to securing people, property, product, and information.
The security protocol for importers is much the same as the
protocol spelled out for carriers. And much of that deals with
business partner requirements and security procedures, conveyance security and inspection, trailer and container security
and seals, and conveyance tracking and monitoring.
It also contains a series of requirements for physical access
controls that include facilities, and cover employees, visitors,
vendors, and service providers. Processes are spelled out for
pre-employment verification, background checks, and termination, as well.
Critically, the protocol specifies procedural security measures to ensure the integrity of processes related to cargo handling and storage, including those that restrict access during
conveyance and that require reporting anomalies involving
truck drivers (including the screening of their luggage and personal effects).
More detail is added for documentation processing, document review, bill of lading/manifesting procedures, and cargo
marking.
As for facilities themselves, they are required to employ physical barriers and other deterrents to unauthorized access,
including fencing, gates and gate houses, separate private vehicle parking, locking devices and key controls, lighting (with
specific requirements regarding placement and brightness),
and monitoring/alarm systems for the premises.
There are additional specifications for information and technology security—and accountability. [N.B. The GSA (General
Services Administration) publishes standards for federal facilities, which provide a good reference point for security processes and practices.]
Summing up
C-TPAT certification is not a journey for the faint of heart, but
it might become a necessity in the not-very-distant future.
Despite its carrier focus, it could well have important implications for warehouses and distribution centers, probably operationally positive and quite possibly a lot of work to implement.
Those industries likely to be affected earliest and deepest are
automotive, aerospace, textiles, and retailing.
For those companies that have not considered what it will
take to undergo the process, outside assistance can help to steer
them around the inevitable bumps in the road. It can also
reduce the risk of unpleasant surprises at a later time—like discovering two years after the fact that the initial certification
could not be validated.
And by the way, those old basics of protecting people, product, property, and information are still vitally important, too. ;
Note: The authors are indebted to Les Glick, partner at
Porter Wright Morris & Arthur LLP, and Michael Regan, CEO
of Tranzact Technologies, for their insights into supply chain
security issues.
