C-TPAT Foreign Manufacturer Security Recommendations Foreign manufacturers should develop and implement a comprehensive plan to enhance security procedures throughout their operations. These are general recommendations that should be followed on a case-by-case basis depending on the company's size and structure and may not be applicable to all. The company should have written security procedures in place that addresses the following: Physical Security: All buildings should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include:
Access Controls: Unauthorized access to the shipping, loading dock and cargo areas should be prohibited. Controls should include:
- Adequate locking devices for external and internal doors, windows, gates and fences.
- Segregation and marking of international, domestic, high-value and dangerous goods cargo within the facility by a safe, caged or otherwise fenced-in area.
- Adequate lighting provided inside and outside the facility to include parking areas.
- Separate parking area for private vehicles separate from the shipping/loading dock and cargo areas.
- Having internal/external communications systems in place to contact internal security personnel or local law enforcement.
Procedural Security: Measures for the handling of incoming and outgoing goods should include the protection against the introduction, exchange, or loss of any legal or illegal material. Security controls should include:
- The positive identification, recording and tracking of all employees, visitors and vendors.
- Procedures for challenging unauthorized/unidentified persons.
Education and Training Awareness: A security awareness program should be provided to employees and include instruction on how to recognize internal conspiracies, maintaining product integrity, and determining and addressing unauthorized access. These programs should offer incentives for active employee participation in security controls.
- Having a designated security officer to supervise the introduction/removal of cargo.
- Properly marked, weighed, counted and documented products.
- Procedures for affixing, replacing, recording, tracking and verifying seals on containers, trailers and railcars.
- Procedures for detecting and reporting shortages and overages.
- Procedures for tracking the timely movement of incoming and outgoing goods.
- Proper storage of empty and full containers/trailers/railcars to prevent unauthorized access.
- Procedures to notify Customs and Border Protection in cases where anomalies or illegal activities are detected or suspected by the company.
Threat Awareness: A threat awareness program should be established and maintained by security personnel to recognize and foster an awareness of the threat posed by terrorists and contraband smugglers at each point in the foreign-based logistical chain. This program should include routine briefings and issuance of memoranda illustrating smuggling trends, seizures and information on terrorist threats along routes or areas along the logistical chain.