US Customs & Border Protection issues new security profile for Sea Carries

United States Customs & Border Protection reported that the Customs Trade Partnerships Against Terrorism (CTPAT) Portal’s new security profile for Sea Carries which came on line June 1, 2020, does not fully reflect the associated minimum security criteria (MSC).

Accordingly, BIMCO’s Jakob Paaske Larsen provides guidelines received by CPB to assist the industry be in line.

The guidelines state that:

• Keep the following in mind when completing the new security profile:

1. Procedural Security – Are security breaches included in a Vessel Security Plan (VSP)? 
2. Procedural Security – Are unannounced third party security audits performed on high risk routes?  What are the third party audit procedures, how often are they performed and how are security deficiencies addressed?  This is a requirement. 
3. Physical Security – Are vessels equipped with video surveillance systems that have night vision capability?  Are the system recordings stored?  How are the recordings protected? 
4. Personnel Security – Are crew members rotated on high risk routes in order to prevent internal conspiracies and crew from working the same route on consecutive trips?  Is this policy included in written procedures?  This is a requirement.

• Implement and document these three criteria which are currently not reflected in the security profile:

#1  7.36 Must – Procedural Security

To address security vulnerabilities for voyages in high-risk areas (as defined by the Member’s CTPAT risk assessment), Sea Carriers must conduct CTPAT-focused company security audits annually; following specific CBP guidance/instructions to the Sea Carrier; or following a significant security incident if the findings of the internal post-incident analysis warrant it. These audits must be documented and be made available to the SCSS upon request. Any security deficiencies identified by the audits must be addressed as soon as practicable.

#2 7.35 Must – Procedural Security 

CTPAT sea carriers must have written procedures to ensure the implementation of measures to secure all means of access to the ship, including: access ladders; access gangways; access ramps; access doors, side scuttles, windows and ports; mooring lines and anchor chains; and cranes and hoisting gear.  Refer to MTSA -33CFR 104.265 and the ISPS Code, Part B – Ship Security Plan, section 9.9, for guidance.

#3 9.18 Must – Physical Security

As required by the Maritime Security Act (MTSA – 33 CFR 104.285), Sea Carriers must have the capability to continuously monitor the ships, the restricted areas on board the ships, and the areas surrounding the ships through a combination of lighting, watch keepers, security guards, deck watches, waterborne patrols, automatic intrusion detection devices, or surveillance equipment as specified in the ship or vessel security plan.

Supporting the maritime environment the program launched the CTPAT Maritime Security Unit (MSU), which will increase uniformity across the program field offices, facilitate the timely resolution of security issues affecting our maritime Members, and further strengthening critical program knowledge on key maritime industry practices.