C-TPAT for Rail Carriers: Business Partner Requirements
Security Procedures
Written procedures must be in place to address specific factors or practices, the presence of which would trigger additional scrutiny by the rail carrier. The US CBP will work in partnership with the rail carriers to identify specific information regarding what factors, practices, circumstances or risks are relevant.
For business partners eligible for C-TPAT endorsement (importers, ports, terminals, brokers, consolidators, etc), the rail carrier must have documentations like C-TPAT certificate, SVI number, etc indicating whether these business partners are or are not C-TPAT certified. Non-C-TPAT business partners may be subject to additional scrutiny by the rail carrier. Rail carriers should institute appropriate security procedures for their contract service providers.
Rail carriers have a common carrier responsibility for all cargo loaded abroad their rail cars, they should communicate the importance if security to their employees as a fundamental aspect of their security policies.
Rail carriers should also strongly encourage that contract service providers and shippers commit to C-TPAT security recommendations.
Rolling Stock Security
Rail carriers shall have procedures to protect against any unauthorized personnel or materials. It is recognized that even though a carrier may not exercise control over the loading of rail cars and the contents of the cargo, rail carrier must be vigilant to guard against stowaways and the smuggling of implements of terrorism and contraband.
The rail carriers shall have procedures in place to guard against the loading of contraband while trains are in transit to the border, even in regards to unforeseen train stops. Rail carriers also must have procedures in place for reporting of unauthorized entry into rail cars and/or locomotives.
Besides, rail carriers also need to ensure inventory information are intact, movement records are up-to-date on each rail car and use the physical rail car tracking technology that is inherent to the North america rail network system.
Inspection Procedures
Rail personnel should be briefed and trained to inspect their rail cars and locomotives for anomalies. Training in conveyance searches should be adopted as part of the company's on-job-training (OJT) program. The training should also be recorded and documented in a personnel file of the employee that had attended the training.
A systematic inspection must be made prior to reaching the US border. During the on-ground required safety inspections of rolling stock entering US, conduct security inspections for any apparent signs of tampering, sabotage, attached explosives, contraband, stowaways or any other unusual prohibited items and materials.
It is understood that railroads must comply with the Federal Railroad Safety Act and the Hazardous Materials Transportation Act. CBP will work in partnership with the rail carriers to identify specific information regarding what factors, practices or risks are relevant including the use of non-intrusive gamma ray technology or other inspection methods.
