Federal-Mogul Corporation has applied for certification in the U.S. Bureau of Customs and Border Protection’s (“CBP”) “Customs-Trade Partnership Against Terrorism” (C-TPAT). As a participant in this voluntary program, we have made a firm commitment to enhance the security of goods moving through our international supply chain and to communicate the importance of security procedures to our suppliers.
As part of our C-TPAT implementation, we are posting the guidelines on the Federal-Mogul Web site for your consideration and use in enhancing your security measures. We sincerely appreciate your cooperation and request that your company join us in our efforts to improve our supply-chain integrity by embracing the C-TPAT initiatives and complying with them to the best of your company’s ability. Please contact me if you have any questions.
Sincerely,
Wendy S. Himebaugh
International Logistics and Customs, The Americas
Phone: 248-354-7084
Fax: 248-354-8972
Facility Security Best Practices
Federal-Mogul Corporation is participating in the C-TPAT, a program created by CBP that is committed to enhancing its supply-chain security to help prevent future terrorist attacks. While the program is voluntary, Federal-Mogul hopes and expects that its suppliers will develop and implement a sound plan to enhance their security procedures as well. To assist in that effort, Federal-Mogul provides these general recommendations that should be followed on a case-by-case basis depending upon your company’s size and structure:
Physical Security: All buildings should be constructed of materials that resist unlawful entry.
Physical security should include:
- Adequate locking devices for external and internal doors, windows, gates and fences;
- Walls or fences six feet or higher around the facility or other adequate security measures;
- Adequate lighting inside and outside the facility, including parking areas;
- Parking area for private vehicles that is separate from the shipping, loading dock and cargo areas;
- Segregation and marking of international, domestic, high-value and dangerous-goods cargo within the warehouse by a safe, caged or otherwise fenced-in area;
- Having internal/external communications systems in place to contact internal security personnel or local law enforcement police as necessary.
Access Controls: Unauthorized access to the shipping, loading dock and cargo areas should be prohibited. Controls should include:
- Positive identification of all employees, visitors and vendors;
- Limited issuance of keys or access cards and recovery of those keys or cards when an employee resigns or is terminated;
- Visitor screening before being allowed entry to the plant;
- Procedures for challenging unauthorized/unidentified persons.
Procedural Security: Measures for the handling of incoming and outgoing goods should include protection against the introduction, exchange or loss of any legal or illegal material. Security controls should include:
- A designated security individual to supervise the introduction/removal of cargo;
- Ensuring properly marked, weighed, counted and documented products;
- Procedures for verifying seals on containers, trailers and railcars;
- Procedures for detecting and reporting shortages and overages;
- Procedures for tracking the timely movement of incoming and outgoing goods;
- Proper storage of empty and full containers to prevent unauthorized access;
- Procedures to notify CBP and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the company.
Personnel Security: Companies should conduct employment screening, and interviewing of prospective employees should include periodic background checks and application verifications.
Education and Training Awareness: A security awareness program should be provided to employees including recognizing internal conspiracies, maintaining product integrity and determining and addressing unauthorized access.
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