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Customs Trade Partnership Against Terrorism (CTPAT) Program Issues Changes to Security Criteria

Physical security measures among changes that members and their suppliers are required to implement.

The US government’s Customs Trade Partnership Against Terrorism (CTPAT) program has issued changes to their minimum security criteria for the first time since they were first issued over a decade ago. CTPAT, a voluntary program that provides trade benefits for companies that become certified, has over 11,400 members. Members include some of the largest importers in the country across a wide range of industries, and companies are quickly getting up to speed on the new requirements.

Management commitment to supply chain security is one of the major areas where the criteria are changing. Member companies are now required to have a documented security review policy to help ensure that they are maintaining supply chain security at all times. This will require oversight from a dedicated point of contact for supply chain security issues, with support from logistics, supply chain, procurement, and IT teams. Members are also required to assess where risks exist in their supply chains on an annual basis or as risks change, another task that will require management review and commitment.

The new minimum security criteria also includes changes to the physical security measures that members and their suppliers are required to implement. If surveillance cameras are used, for instance, members must commit to properly maintaining them and ensuring that they cover crucial areas for container security, such as the loading and unloading dock. Of course, there is a continued emphasis on the security of containers and other instruments of international traffic, though there is now a new requirement to check for possible agricultural pests and contaminants.

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Some members may have difficulty juggling all of these new requirements, and a gap assessment and training can help guide companies in complying. Companies with extended supply chains may need additional help assessing their business partners. Supplier Compliance Audit Network (SCAN) is a non-profit association, which permits members to share security audits conducted at suppliers’ facilities. This audit sharing program works to reduce audit fatigue at the supplier level and allows members to reduce costs in their supply chain.

How does SCAN work? If a factory produces product for five vendors, five different security audits would be conducted based on each vendors’ needs and requirements. In SCAN, all members have worked together on industry-standard security criteria to create an assessment that meets or exceeds minimum security criteria set by U.S. Customs’ CTPAT Program. If that factory’s five vendors are SCAN members, only one security audit is needed instead of the five separate audits.

As of April 2019, SCAN has 32 members. They represent many industries such as retail, apparel, food, sporting goods, and logistics. These members serve on the Association’s board of directors and committees that include topics such as audit criteria, information technology, membership, and marketing. While the members may be industry competitors, they all share a common goal to secure their global supply chain. Participating in these committees allows the members to benchmark security concerns and opportunities with fellow members instead of managing security audits in a silo.

Armed with new training, an honest assessment of your company’s current supply chain security program, and the assistance that organizations such as SCAN can provide, companies can ensure their compliance with the new CTPAT criteria and continue raising the bar for security worldwide.

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