Revised Cargo Sealing Procedures for C-TPAT and FAST Participants

February 19, 2007
By Michelle Kelley

US Customs and Border Protection (CBP) has recently updated cargo sealing requirements for C-TPAT members participating in the northern and southern border Free and Secure Trade (FAST) program. CBP’s Cargo Sealing Guide Procedures (included below) outlines requirements for affixing high security mechanical seals to cargo trailers. CBP also recommends that all manufacturers, importers, and carriers participating in C-TPAT and FAST immediately implement and adhere to these procedures in order to ensure the security and integrity of their cargo.

CARGO SEALING GUIDE – PROCEDURES
FOR C-TPAT/FAST PARTICIPANTS

1. Scope
This document establishes the recommended procedures for affixing high security mechanical seals to cargo loaded trailers for Customs-Trade Partnership Against Terrorism (C-TPAT) members who are eligible to receive trade facilitation benefits by participating in the northern and southern border Free and Secure Trade (FAST) program. To become eligible for participation in C-TPAT and FAST, manufacturers, importers and carriers must ensure security and integrity of their cargo by adhering to more stringent supply chain security guidelines, such as the sealing requirements outlined in this document.

2. Background
The sealing of trailers, to include continuous seal integrity, are crucial elements of a secure supply chain, and remains a critical supply chain security commitment to C-TPAT and FAST. U.S. Customs and Border Protection (CBP) may verify the integrity of these seals upon arrival in the United States, and during C-TPAT validations, will verify that sealing procedures are consistent with the minimum-security criteria for C-TPAT highway carriers.

3. Terms and Definitions
For C-TPAT and FAST purposes, high security seals are categorized as seals that meet or exceed the current PAS ISO 17712 standard. Seals that conform or exceed this standard are manufactured with strong metal materials with the intent to delay intrusion, and generally require removal with a bolt cutter or cable cutters.

FAST participants are responsible for acquiring seals from legitimate manufacturers. CBP does not endorse any particular seal manufacturer or product. There are organizations, however, such as the International Seal Manufacturers Association that can provide guidance for FAST participants searching for seal manufacturers offering ISO/PAS 17712 high security seals.

4. Sealing Criteria
C-TPAT approved carriers must have a high security seal affixed to all loaded trailers bound for the U.S. All seals must meet or exceed the current PAS ISO 17712 standards for high security seals. Based on risks, a high security bolt seal may be applied to the door handle and/or a cable seal must be applied to the two vertical bars on the trailer doors.

5. Seal Placement
Given the known vulnerabilities of existing trailer door hardware and in an effort to increase the security of cargo loaded trailers, all C-TPAT/FAST participants who elect to use high security bolt and cable seals, will be required to affix those seals in the manner that is outlined in this document.

HIGH SECURITY BOLT SEAL

  • Seal consisting of a metal rod, threaded or unthreaded, flexible or rigid, with a formed head, secured with a separate locking mechanism.
  • All C-TPAT/FAST participants who elect to use bolt seals will be required to place the bolt seal in the locking mechanism on the door handle with the barrel portion of the bolt seal facing downward.

HIGH SECURITY CABLE SEAL

  • Seal consisting of a cable and a locking mechanism. On a one-piece seal, the locking or seizing mechanism is permanently attached to one end of the cable. A two-piece cable seal has a separate locking mechanism, which slips onto the cable or prefabricated cable end.
  • The cable seal will be secured between the left and right door inboard locking rods, at the point where the door handle is attached. This will be accomplished by starting the cable in-between the left and right inboard locking rods and passing the cable behind the left locking rod then looping it over the door handle attaching bracket and passing the cable back behind the left locking rod.
  • The same procedure will then be performed on the right locking rod. The cable should then be locked to remove all possible slack (see photo A below).


Photo A

If needed the cable should be looped as many times as required to remove all possible slack (see photo B below).


Photo B

The cable, when affixed properly in this manner, cannot be moved up or down on the locking rod, nor can the locking rod be rotated more than a few degrees without damaging the cable.

6. Seal Control Responsibility

  • All FAST participants affixing seals to cargo loaded trailers will be responsible for initiating control, inventory, and accountability procedures to minimize the risk of compromising seal integrity and use of their seals by unauthorized entities. This must include the tracking of individual seal use.
  • Information concerning the use of every seal must be recorded and readily retrievable for possible audit or validation. The C-TPAT member placing the initial seal on a cargo-loaded trailer at the time the trailer is loaded should ensure that the seal number is documented on the manifest. This will provide CBP personnel with a method of verifying legitimate seals.

7. Seal Authentication

  • Companies purchasing high security seals should obtain evidence that the seals indeed comply with the ISO/PAS 17712 Standard for Freight Containers-Mechanical Seals from the seal manufacturer and maintain the documentation for future reference.
  • All high security seals used by a C-TPAT certified importer/carrier should be backed by the seal manufacturer’s test report issued by an independent ISO 17025 certified testing laboratory attesting that the seals comply with the strength values called for in the ISO/PAS 17712 Standard for Freight Containers – Mechanical Seals.

8. Best Practices

C-TPAT members will not be required to modify their trailers to participate in FAST. Any modification to the trailer or door hardware to further secure the trailer is considered a Best Practice that exceeds the minimum-security criteria for C-TPAT.

The following modification is categorized as a Best Practice: Trailer modification requires that a ½” hole be drilled that would allow a mechanical or electronic seal to be affixed THROUGH the inboard vertical bar on the right-hand door, and THROUGH the lower plate fastening the bar to the door of the container (see photo C below). The seal, when affixed through this hole, should cover rivet heads on the plate to prevent tampering.


Photo C

Further information is available through the Office of Field Operations, Interdiction and Security Division.

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