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April
15 , 2002
We
have received a copy of the questionnaire which C-TPAT (Customs-Trade
Partnership Against Terrorism) importer participants are requested
to complete.
While
Customs is offering participants great benefits in applying to the
program, the importer without a security program may find itself
targeted for extensive improvements.
We
suggest that an importer review and create written plans for implementing
security procedures or improvements to existing security procedures,
prior to completing the C-TPAT questionnaire.
Following
is Customs Questionnaire to importers:
 Supply
Chain Security Profile Questionnaire
- Provide
an executive summary outlining the process elements of the security
procedures you currently have in place. At minimum, address the
following elements:
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Security Program:
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Facilities security.
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Theft prevention.
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Shipping and receiving controls.
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Information security controls - integrity of automated systems.
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Internal controls - process established for reporting and correcting
problems.
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Personnel Security:
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Pre-employment screening & periodic background reviews.
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Employee training on security awareness and procedures.
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Internal codes of conduct.
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Internal controls - process established for reporting and
managing problems related to personnel security.
- Service
Provider Requirements - Product suppliers, Carriers, Forwarders:
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Written standards for service providers' physical plant security.
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Quality controls on production processes to ensure system
integrity.
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Financial Assessment process to determine service provider's
fiscal soundness and ability to deliver goods and services
within contract parameters.
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Internal Controls for the selection of service providers.
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Profiles of Tier 1 suppliers (i.e. those entities receiving
and packing a finished commodity, for transportation to the
final destination) maintained and available for review.
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Indicate that the specific detailed procedures noted above
are available to Customs in a verifiable format at an identified
location.
- Include
an assessment of your security processes, as well as information
on what changes you envision making to correct identified weaknesses.
*
Identifying perceived weaknesses will not necessarily prohibit
participation in C-TPAT. Customs is committed to working
with you to identify effective corrections and adjustments
to your processes that will result in a more secure supply
chain operation. We have specific programs in place that
can assist your company in meeting this objective. Our Carrier
Initiative Program Coordinators can provide expert advice
on establishing security programs throughout your supply chain.
Program information will be provided upon request.
If you have any questions on any of the issues raised in this newsletter, please contact George R. Tuttle, III at (415) 288-0428 or via email at geo@tuttlelaw.com.
George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle in San Francisco. The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.
Copyright
© 2002
by Tuttle Law Offices.
All
rights reserved. Information has been obtained from sources believed
to be reliable. However, because of the possibility of human or
mechanical error by our offices or by others, we do not guarantee
the accuracy, adequacy, or completeness of any information and are
not responsible for any errors, omissions, or for the results obtained
from the use of such information.
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Apparel 
Requirements