Section 5: Procedural Security Summ

Section 5: Procedural Security
Summary :
C-TPAT program: Procedural Security Requirements
________________________________________
Audience: Merchandise Vendors

Overview
This section lists requirements to meet Target’s C-TPAT program at the facility level, specifically regarding procedural security such as security of written procedures, data transmissions, movement tracking, and identifying and reporting cargo anomalies. The content in this section is organized by question number from the C-TPAT Security Checklist for ease of use.

Question 5.01.00: Are there written procedures in place to ensure that all documentation regarding merchandise/cargo is legible, complete, and accurate?

Requirements:
• Written procedures must be in place describing how the facility will ensure all documents used in customs clearing of United States cargo is legible, complete, accurate, and protected against exchange, loss, or introduction of wrong information. At a minimum, the procedure must include:
o Appropriate document storage
o Review process
o Systems access procedures
• A Standard Operating Procedure (SOP) must be used to document this process, and to train all employees.
• Document employee training in a log.
Validation Criteria:
• Written procedures
• SOP for training
• Training log
Question 5.02.00: Are there written procedures to restrict access to, and the processing of, shipping and receiving documentation to authorized persons only?

Requirements:
• Written procedures must be in place describing how the factory will restrict access to and the processing of shipping and receiving documentation to authorized personnel only. At a minimum, the procedure must include:
o Restricted systems access
o Password protected applications
Validation Criteria:
• Written procedures
Question 5.03.00: Are there written procedures to ensure that information and data transmissions are transmitted to business partners accurately and timely?

Requirements:
• Written procedures must be in place describing how the factory will ensure the information provided to the overseas consolidator is transmitted accurately and timely. At a minimum, the procedure must include:
o Requirements for ISF/advanced manifest data
o Security controls
o Transmission logs used to track transmissions
o Periodic audits that validate data
o Timeliness of transmissions
Validation Criteria:
• Written procedures
Question 5.04.00: Are there electronic data transmissions (EDI or otherwise) of advance shipping information between the facility, the forwarder/consolidator, and/or the importer?

Requirements:
• If a facility utilizes data transmissions, written procedures must be in place describing how the factory will verify electronic data transmissions of advance shipping information between the facility, the forwarder/consolidator, and/or the importer.
Validation Criteria:
• Written procedures
Questions 5.05.00 – 5.05.01: Does the facility verify the accuracy of data that is transferred to the freight forwarder? If yes, are there details how accuracy and accountability is reviewed, including consequences of non-compliance?

Requirements:
• Written procedures must be in place describing how the facility verifies that data transferred to the freight forwarder is accurate, and what action is taken if data isn’t accurate.
Validation Criteria:
• Written procedures
Question 5.06.00: Are finished products properly marked, counted, weighed (if necessary), documented, and reported on the manifest and bills of lading?

Requirements:
• Written procedures must be in place describing how the facility ensures cartons are properly marked, counted, weighed, documented, and reported on the manifest and bills of lading.
• A Standard Operating Procedure (SOP) must be used to document this process, and to train all employees.
• A Purchase order/packing list must be used to verify the correct carton count by item prior to the cargo being loaded into the container/trailer.
• The loading manager/supervisor must sign and date the purchase order/packing list to validate the load was complete and correct once the cargo has been loaded into the container/trailer.
Validation Criteria:
• Written procedures
• SOP for training
• Training log

Questions 5.07.00 – 5.07.01: Are there written procedures in place to verify driver identity prior to accepting inbound or releasing outbound cargo? Is a driver log maintained to identify details of the shipments’ arrival and departure?

Requirements:
• Written procedures must be in place describing how the facility manages check ins/outs for inbound and outbound containers. At a minimum, the procedure must include:
o Validating the driver’s identification & shipping documentation with the facility’s documents upon arrival/departure of container/trailer.
• A Standard Operating Procedure (SOP) must be used to document this process, and to train all employees.
o A log must be utilized to track the inbound and outbound containers. At a minimum, the log must record:
o Date
o Time of arrival and departure
o Individual’s full name/phone number
o Seal number
o Purpose of visit
o Guard’s signature
Validation Criteria
• Written procedures
• SOP for training
• Training log
• Inbound/outbound log
Questions 5.08.00 – 5.08.01: Are outbound shipments tracked for timely movement? Are inbound shipments tracked for timely movement?

Requirements:
• Written procedures must be in place describing how the facility tracks both inbound shipments from port/vendors to the factory, and outbound shipments from the factory to final destination (CFS, port, etc.). This must include specific routes and time parameters.
• If GPS is utilized:
o Maintain records showing how predetermined routes and time parameters are followed.
• If GPS is not utilized:
o Appropriate documentation must be kept demonstrating how predetermined routes and time parameters are followed.
Validation Criteria
• Written procedure
• Records of cargo movement
Question 5.09.00: Are there written security procedures covering the introduction of unauthorized or un-manifested material during the packing, stuffing, receiving and shipping process?

Requirements:
• Written procedure and/or SOP must be in place to ensure that security procedures are in place to eliminate the introduction of unauthorized or un-manifested material during the packing, stuffing, receiving and shipping process.
• Training must be provided to employees and training logs must be available.
• Shipping and receiving records must be complete, legible and accurate. All piece counts must be verified and anomalies reported to the appropriate personnel.
• Only authorized personnel are allowed to sign shipping documents and make changes to piece counts.
Validation Criteria
• Written procedure
• Training materials and logs
• Complete, legible and accurate shipping and receiving records
Question 5.10.00: Are there written procedure in place to detect or resolve all shortages, overages, and other significant discrepancies or anomalies?

Requirements:
• Written procedures must be in place describing how the facility detects and resolves all shortages, overages, and other signification discrepancies/anomalies. At a minimum, the procedures must include:
o Investigation practices
o Reporting issues to consolidator
• A Standard Operating Procedure (SOP) must be used to document this process, and to train all employees.


Validation Criteria:
• Written procedures
• SOP for training
• Training log
Question 5.11.00: Are there written procedures in place to notify the Importer and/or law enforcement agencies if significant anomalies, illegal, or suspicious activities are detected?

Requirements:
• Written procedures must be in place describing how the facility notifies the importer/overseas consolidator and/or law enforcement agencies if significant anomalies, illegal, or suspicious activities are detected. At a minimum, the procedure must include:
o Who reported the incident
o Where and when the incident was discovered
o Who reported the incident to Target’s overseas consolidator
o How the situation was resolved
• Target’s incident reporting process and procedures for business partners must be included in the facility’s procedure. This can be found on POL here:
Consolidator Incident Reporting
Validation Criteria:
• Written procedure