Sanders Brokerage

CONTAINER SECURITY – CONTAINER TRAILER SEALING PROCESSES:

As a member of C-TPAT (Customs Trade Partnership Against Terrorism) it is our duty to inform the importing public of the importance of Security Criteria.  U.S. Customs brokers in the U.S.A. do not play a significant roll in stuffing, loading, transporting or distributing the merchandise while overseas.  The Customs Broker does however play a big part in the supply chain of goods moving to the United States.  While we can do little overseas to assure security and safety of the goods overseas we must do our best in educating the public of (at very least) a minimum amount of security standards and encourage that members within the supply chain become educated and participate in C-TPAT.

C-TPAT recognizes the complex nature of the international supply chain and the security practices within which make it function.  C-TPAT endorses the application of security measures which are based upon “risk” within the supply chain.  The supply chain being moving the goods from point of origin (such as the manufacturer, supplier or vendor) through it the goods final point of distribution.  Further to this C-TPAT understand the diversity in members business models, and to that end the C-TPAT program allows for flexibility and certain amounts of customization of security plans, dependent upon the participants business model.

As a requirement of C-TPAT, and obligation and desire to convey to our business partners, customers, importers, foreign importers and exporters  the criticality of having security procedures in place at the point of origin to insure proper inspection, proper sealing and maintenance of integrity of the container and/or trailers.

Under the C-TPAT program the following guidelines are recommended for Container and Trailer Seals:

• All U.S. bound containers and trailers must have a PAS ISO 17712 high security seal affixed;
• There must be in place procedures to recognize and report compromised seals to CBP or proper foreign government authority;

Container & Trailer Security:

For Container and Trailer Security there must be in place, procedures to determine the physical integrity of the container prior to stuffing.  This includes the process of checking the physical integrity of the doors locking mechanism.  C-TPAT has developed and recommends a 7 (seven) point inspection for all containers.  The 7 points follow for your review:

1. Inspect the undercarriage of the container.  The support beams should be visible, if covered or obscured they may contain compartments for storage of contraband.  Look for anomalous structures such as a solid plate between the beams.
2. Inspect the top, side and front of the container for any obvious patched areas that are not consistent with the structure of the box.  Patches may not be just patches, they may be doors made for storing contraband or stowaways.  Repaired or patched areas are easily identified as they are usually not consistent in color with the remainder of the containers walls.
3. V.V.T.T.  Verify seal and container locking mechanism / Verify seal number / Tug on the seal/ Twist the seal.  Inspect the outside of the doors for consistency in construction.  Look for patches in the doors.  Check the rivets and haps for discrepancies.  The rivets should be welded and consistent in appearance.  Make sure there are rivets and not a bolt or screw.  Look for putty around rivets.  Sometimes putty is used to hold rivets in place that were drilled out for access to the container without breaking the seal.  Check the door locking bars for any inconsistency in construction.  Verify the seal number and that it matches the paperwork for the container.  Tug on the seal to make sure the seal was not broken and then later glued back together.  Twist the seal as it should rotate within its housing.  If the seal comes apart when twisting, it could have been pulled apart, the shaft and housing threaded and screwed back together.  If you cannot twist the seal there is a possibility that the seal was pulled apart and glued back together
4. After you have opened the container door, check the front wall.  The lift block housing and vents should be visible and the same color.  Smugglers have been known to build false walls in the front of containers.  Measure the length of the container to ensure that a false wall and storage area have not be constructed in the container.
5. Look at the ceiling to ensure the lift blocks and air vets are visible.  Smugglers build false ceilings and lift blocks to hide contraband.  The ceiling and lift blocks should be consistent in color.  If there is a patch in the ceiling that was not evident by your roof inspection, this may be also indicate a false ceiling or compartment.  Measure the floor to ceiling to ensure it is the proper height.
6. Look at the floor to make sure there are no step-ups.  The floor should be a uniform structure.  If there are patches in the floor make sure the same patches are visible beneath the container.  Measure the floor to ceiling to ensure it is the proper height.
7. Look at the container walls for anomalous structures which you looked for in the ceiling and floor.  Use a small hammer and tap the walls to make sure they are not hollow.  If you do not hear a hollow sound, there may be contraband between the walls.  Measure the distance between the walls to ensure the width of the container is proper.

Tractor & Trailer Security:

The below listed systematic practices should be considered when conducting training on conveyances.  Highway carriers need to visually inspect all empty trailers in their care including the interior of the trailer at the truck yard, if possible again at the point of loading.  The following inspection process are recommended for all trailers and tractors.

Tractors:

• Bumpers / Tires / Rims
• Doors / Tool Compartments
• Battery Box
• Air Breather
• Fuel Tanks
• Interior Cab Compartments / Sleeper
• Fairing / Roof

Trailers:

• Fifth Wheel Area – check natural compartments / skid plate
• Exterior – front / sides
• Rear – bumper / doors
• Front Wall
• Left Side
• Right Side
• Floor
• Ceiling Roof
• Inside / outside doors
• Outside / Undercarriage

Less-than Truck Loads (LTL):

LTL carriers must us a high security padlock or similarly appropriate locking device when picking up local freight in an international LTL environment.  LTL carriers must ensure strict controls to lime the access to keys or combinations that can open padlocks.  After the freight from the pickup and delivery run is sorted, consolidated and loaded onto the line haul carrier destined to cross the border into the U.S.A., the trailer must be sealed with a high security seal which meets the current PAS ISO 17712 standard for high security seals.

In LTL or Pickup and Delivery (P & D) operations that do not use consolidation hubs to sort or consolidate freight prior to crossing the U.S. border, the importer and/or highway carrier must use ISO 17712 high security seals for the trailer at each stop, and to cross the border

Written procedures must be established to record the change in seals, as wall a stipulate how the seals are controlled and discrepancies are noted and reported.  These written procedures should be maintained at the terminal / local level.  In the LTL and non-LTL environment procedures should also exist for recognizing and report compromised seals and/or trailers to U.S. Customs and Border Protection Services or the appropriate foreign government authority.

Please don’t hesitate to contact our company for additional information regarding C-TPAT requirements.