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Practice Areas

C-TPAT Partners Warned about Textile and Apparel Theft in South Africa

Wednesday, January 08, 2014
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection issued Jan. 6 a notice encouraging Customs-Trade Partnership Against Terrorism partners to take steps to address an identified security concern in South Africa. Helping C-TPAT companies assess and minimize risks such as these is one aspect of a 90-minute webinar Sandler, Travis & Rosenberg will conduct on Jan. 16.

According to the notice, CBP has confirmed several instances of containerized cargo pilferage and/or manipulation between Lesotho and the port of Durban, South Africa. CBP states that wearing apparel and textile importers have been particularly hit by thieves who steal the original cargo while in transit and then counterbalance the container with items of no value so that the weight of the container remains the same so as not to alert local customs officials. CBP adds that it is not unusual to find employees of local companies involved in cargo theft in South Africa.

CBP therefore highly recommends that importers reassess supply chain risk factors facing containerized shipments routed through the southern region of the African continent. Specifically, importers are advised to review their regional supply chains against the following C-TPAT minimum security criteria.

Risk Assessment

- provide direct outreach to vendors and service providers in the affected region regarding the importance of security measures

- communicate C-TPAT criteria regarding seal control, container tracking and monitoring, and

procedural security to local business partners

Conveyance Tracking and Monitoring Procedures

- if GPS is in place, ensure it is being utilized as a live monitoring tool, not simply as a record to be referenced at a later date

- encourage the use of geo-fencing technology to generate alerts when a conveyance strays from a predetermined route

- maintain constant communication with the driver, tractor and trailer while en route to the seaport and implement designated times/locations at which drivers are to report to dispatch

Procedural Security

- ensure that local factory managers, freight forwarding personnel and transportation providers understand procedures on reporting suspicious activities, weight discrepancies and/or other anomalies

- importers should work with foreign vendors and service providers to confirm clearly established protocols for reporting pilferage, weight discrepancies and other security breaches

- importers should ensure that reporting procedures are in place to stop a suspicious shipment from leaving Africa; failing that, they should establish procedures allowing a suspicious shipment to be reported at the earliest possible time thereafter

Security Threat and Awareness Training

- importers should request that vendors and supply chain service providers conduct refresher training on supply chain security topics

- training should be provided to employees handling cargo and especially truck drivers on topics such as detecting internal conspiracies, container seal control, reporting weight discrepancies and container tracking

Highway Carrier Environment Best Practices

C-TPAT members have developed several best practices to defeat security breaches, including the following.

- driver must report time at each specific area along the route

- minimize/eliminate unnecessary stops by drivers throughout the transportation route and require all stops to be made at approved locations

- highway carrier company has the ability to remotely shut off the truck’s engine in the event of route deviations or lost contact with driver

- use of tamper-indicative security labels bearing an actual photo of the seal and a serial number, attached to the hinges and between the two doors of the vehicle

- use of multiple ISO/PAS 17712 certified high security seals on all shipments bound to the U.S.

- for company-owned trailers, utilize spot welded bolts and other hardware (such as hinge covers) to avoid tampering

- in addition to using a bolt seal, attach a cast iron J-bar device to the locking bar that requires a specialized tool for removal

- shipping documents are held at the last checkpoint and crossing documents provided only if the shipment arrives within prescribed timeline and the original high-security seal is intact (shipments not meeting timelines are ordered back to plant for formal investigation and inspection or an alert should be sent to the appropriate government authorities)

- implement substantial internal controls and regular audits to oversee transportation providers and the conveyance monitoring processes

- the importer has an internal global supply chain security team responsible for assessing risk within the company’s international supply chains that exercises complete control and oversight of all security related matters, ensures that corporate standards are applied uniformly throughout all company facilities and verifies compliance with these security standards via onsite audits

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