Seal in your status for C-TPAT and AEO

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Authorship

Scott Kirk, Chairman and Bob Kirby, President, International Seal Manufacturers Association (ISMA)

Publication

Proper use of cargo seals can protect shipments against theft, smuggling and terrorism. What you may not know is that proper attention to your trading partners’ seal suppliers is essential to protect your firm’s C-TPAT and AEO status.

It is a cliché to talk about layered secur ity strategies, but the ter m applies to cargo secur ity seals in a unique way: while proper use of seals provides a layer of physical security for shipments, proper attention to seals provides a layer of institutional protection for your firm’s position in important government compliance programmes. This article will help shippers, carriers, terminal operators and other third parties understand the specific actions they must take to ‘cover their flanks,’ protecting their hard-earned status in beneficial programmes, their brand’s reputation, and the integr ity of their shipments.

ISO 17712

‘ISO 17712’ is the prism that affects both the physical and institutional layers of self-protection. The formal title of the Inter national Standards Organization (ISO) document is ‘Freight containers – Mechanical seals.’ The ISO community developed 17712 quickly when, in the wake of the September 2001 terrorist attacks, industry and government leaders realised that there was no international standard for cargo security seals. There have been three versions of 17712, progressively enhancing and clarifying the document:

• Publicly Available Standard (PAS) 17712: 2003. The or iginal PAS, in effect an inter im international standard, defined the physical perfor mance expected of seals,
following benchmarks long observed by leading customs author ities, shippers and car r iers. Based on test results for tensile strength, bending, shear and impact resistance, seal classifications were Indicative (no barrier protection), Secur ity (modest bar r ier protection) and High Security (meaningful barrier protection).

• PAS 17712: 2006. The revised PAS had three major changes with one significant implication. The first change, intended to simplify the task of cargo checkers in the
field, called for seals to be marked according to their classification: ‘I’ (Indicative), ‘S’ (Secur ity), or ‘H’ (High Security). The second change, designed to reduce security
vulnerabilities, was the addition of a ‘nor mative annex’ that defines the best secur ity-related practices for seal manufacturers and distributors.

The third change, intended to mitigate counterfeiting, linked the other changes: only firms certified as compliant with the normative annex may apply grade  classification stamps. The effect of the changes is significant: every 17712-compliant seal must come from a 17712 process-compliant manufacturer. Non-compliant
manufacturers cannot provide ISO-compliant seals.

• Inter national Standard (IS) 17712: 2008. A for mal Inter national Standard will replace the PAS next year. Unanimous votes at the most recent meetings of ISO working group and its parent committee foretells the key clarifications in that document. First, laboratories must be independent third parties. Second, test procedures will be more tightly defined to reduce the risk of two labs providing different results for similar seals. Finally, the accredited scope of test laborator ies and security process reviewers must address ISO 17712.

ISO 17712 morphed into a de facto mandate even though no government formally requires the use of 17712-compliant seals. Voluntary government and international body programmes provided the catalyst for change. The three major organisations have been the US Customs and Border Protection (CBP), the World Customs Organization (WCO) and the European Commission (EC).

C-TPAT, SAFE and AEO

CBP’s Customs-Trade Partnership Against Ter ror ism (CTPAT) instigated the transfor mation of 17712 into a de facto mandate. This voluntary programme  encourages supply chain best security practices in exchange for two kinds of benefits. First, qualified members count on customs clearance preferences: fewer random inspections, less intrusive reviews and more reliable clearance processing times.  Second, qualified members enjoy a marketing advantage, enhancing
the reputation and attractiveness of their brands with trading partners; all other things being equal, it became better to do business with a C-TPAT member than a non-member. The WCO and the EC adopted many core concepts underlying C-TPAT. The WCO began with its Framework of Standards to Secure and Facilitate Trade, the SAFE Framework.

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