CBP Provides Clarification on C-TPAT ISO Seal Standard for Truckers
U.S. Customs and Border Protection offered some clarifications on the Customs-Trade Partnership Against Terrorism (C-TPAT) International Organization for Standardization (ISO) seal standard for truckers, in a set of Frequently Asked Questions. The FAQs describe the continued use for seal standard ISO/PAS 17712. A new seal standard for containers was previously planned to be implemented by March 1, 2012, but CBP said in February an indeterminate delay was necessary for testing.
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The new questions are:
Q: In the less-than-truckload motor carrier environment, is each C-TPAT importer required to place a new ISO 17712 compliant seal on the trailer when the pickup and delivery (P&D) driver picks up freight?
A: Less than truckload (LTL) carriers must use 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 in order to limit the access of unauthorized individuals to the keys or combinations that can open these padlocks. After the freight from the pickup and delivery run is sorted, consolidated and loaded onto a line haul carrier destined to the cross the border into the U.S., the trailer must be sealed with a high security seal which meets or exceeds the current ISO/PAS 17712 standard for high security seals. Written procedures must be established to record the change in seals, as well as stipulate how the seals are controlled and distributed, and how discrepancies are noted and reported. Procedures should also exist for reporting compromised seals and/or trailers to U.S. Customs and Border Protection or the appropriate foreign authority. These written procedures should be maintained at the terminal/local level.
Q: For trucking operations where a truck makes several pickups and then heads straight for the U.S. border, what kinds of sealing or locking devices will be required?
A: 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 either an ISO PAS 17712 high security seal or a high security padlock or similarly appropriate locking device for the trailer or container at each stop. High security padlocks or similarly appropriate locking devices may be used between stops only if the pick-up and loading locations are within close proximity of each other to allow the company dispatcher to properly monitor the routing times and to identify any potential time or routing discrepancies. For extended, multiple LTL pick-ups where shipments will not be returned to a hub for consolidation or will be passed intact to another driver for cross border transportation, high security seals may be required between pick up stops depending on the time, number of stops and mileage involved.
Q: As a carrier, I already participate in the Customs Carrier Initiative -- is it duplication of effort to join C-TPAT?
A: No. C-TPAT is the primary CBP supply chain security program. CBP is looking for carriers to join C-TPAT to enhance existing security practices and better address the terrorism threat to international air, sea, and land cross-border shipping. C-TPAT participation requires that a Carrier Initiative Program (CIP) participant implement and document specific C-TPAT supply chain security guidelines or criteria. CIP participants should already ascribe to the importance of security from a narcotics-smuggling perspective and are well positioned to expand their security focus to encompass anti-terrorism.
(ISO states that the new ISO 17712:2010 establishes uniform procedures for the classification, acceptance and withdrawal of acceptance of mechanical freight container seals. The new standard provides a single source of information on mechanical seals which are acceptable for securing freight containers in international commerce. ISO 17712:2010 is available here.)
(See ITT's Online Archives 12020902 for summary of the February 7, 2012 notice advising C-TPAT partners that effective March 1, the current ISO high security mechanical seal standard ISO/PAS 17712 would be replaced with the new ISO 17712:2010. See ITT's Online Archives 12021625 for summary of the delay to implementation of the standard.)