CTPAT Training For our Employees at .ppt

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1. Customs Trade Partnership
Against Terrorism (C-TPAT)
An Introduction
September 2016

2. Confidential – For Internal Use with Internal Audiences Only
C-TPAT Training Outline
The C-TPAT Program
Mallinckrodt’s role
What is C-TPAT
Safe Port Act 2006
Supply Chain
C-TPAT Approach, Objectives, Membership, Benefits
CBP Supply Chain Security Specialist
Validation Process
Minimum Security Criteria
Security
Information Technology
Access Device Controls, Visitor Procedures, Escort Procedures
Suspicious Persons
Reporting Security Incidents/Concerns
Security website

3. Confidential – For Internal Use with Internal Audiences Only
Mallinckrodt Pharmaceuticals
Mallinckrodt joined with U.S. Customs and Border Protection
(CBP) to help secure the international supply chain.
The Customs-Trade Partnership Against Terrorism (C-TPAT) is a
voluntary initiative between CBP and private businesses to build
relationships that strengthen international supply chains and
improve U.S. border security.
On August 4, 2014, Mallinckrodt qualified for Tier II benefits under
the C-TPAT Program.

4. Confidential – For Internal Use with Internal Audiences Only
Mallinckrodt Pharmaceuticals
►As a member of the C-TPAT program, Mallinckrodt has committed
itself to new and improved security procedures throughout our
operations.
►These new procedures are designed to enhance the security of our
facilities, people, cargo shipping, cargo receiving and cargo tracking
processes.
►Our goal is to prevent cargo loss and cargo tampering including the
introduction of illegal merchandise such as drugs and weapons of
mass destruction into our cargo boxes and containers.
►As a part of our commitment to supply chain security, we now require
all of our employees to be aware of and seriously consider supply
chain security as a significant risk to our business.

5. Confidential – For Internal Use with Internal Audiences Only
What is C-TPAT
U.S. Customs and Border Patrol (CBP) and Industry working together
to enhance international supply chain security and facilitate legitimate
compliant trade.
C TPAT seeks to safeguard the world's trade industry from terrorists,
‐
drug dealers and human traffickers while maintaining the economic
health of the United States and its neighbors.
The partnership develops and adopts measures that facilitate security
without sacrificing an expedient trade process, a difficult balancing act.
Today, more than 11,400 certified partners have been accepted into
the program and account for over 52 percent of the value of imports to
the United States.

6. Confidential – For Internal Use with Internal Audiences Only
Safe Port ACT 2006 (Excerpt)
►CBP initiated C-TPAT in November 2001, to complement other
maritime security programs as part of the agency’s layered security
strategy.
►In October 2006, the SAFE Port Act formalized C-TPAT into law.
►C-TPAT is a voluntary program that enables CBP officials to work in
partnership with private companies to review the security of their
international supply chains and improve the security of their
shipments to the United States.
►In return for committing to improve the security of their shipments by
joining the program, C-TPAT members receive benefits that result in
the likelihood of reduced scrutiny of their shipments, e.g., a reduced
number of inspections or shorter wait times for their shipments.

7. Confidential – For Internal Use with Internal Audiences Only
Supply Chain Management: Refers to the flow of material and
the relationships among intermediaries from origin to consumer.
Description of Supply Chain
Unknown Business Partners
No Visits/ Audits Conducted
Security a non-factor
No participation in International
security programs
Supply Chain Security
Note: A supply chain that has no security procedures in place
will eventually have a weak link and be vulnerable to an attack.

8. Confidential – For Internal Use with Internal Audiences Only
End-to-End Supply Chain Security Solution
Securing the entire supply chain from end-to-end – C-TPAT type measures.
Description of Supply Chain
Supply Chain Security
Note: A supply chain that has good security procedures in place will have a more
secure supply chain. The idea for a secure supply chain is to implement good
security practices throughout the chain (point of packaging to point of receipt).
There is no one thing (silver bullet) that can prevent an attack. In many
cases, multiple defenses have to be in place in order to prevent an attack.

9. Confidential – For Internal Use with Internal Audiences Only
Weapons of mass destruction
Biological warfare chemicals
Arms/munitions
Terrorists
Why do we protect the Supply Chain?
Any one individual, shipment, or conveyance
could be…

10. Confidential – For Internal Use with Internal Audiences Only
Voluntary Partnership - As previously stated, the C-TPAT program is a
voluntary partnership w/ jointly developed minimum security criteria.
Because of the scale and mission of C-TPAT, (supply chains, anti
terrorism and national security), this approach was deemed to be more
effective than creating mandatory requirements, that are sometimes
necessary in certain situations, but always effective.
Customized application of guidelines by members - More times than
not, positive validation results in companies not only meeting expectations
but in many cases exceeding the minimum standard.
Clear Benefits - C-TPAT certified companies are eligible for benefits to
include a reduced number of examinations.
Trust But Verify Information - This approach adopts the requirement for
conducting the supply chain security validations on C-TPAT companies by
verifying information submitted in the companies security profile.
The C-TPAT Approach

11. Confidential – For Internal Use with Internal Audiences Only
C-TPAT allows CBP to use its knowledge, long interdiction and
enforcement experience and expand upon those qualities with C-TPAT
objectives, e.g.:
Prevention: The mission and goal to help identify a “security
compromise” as early as possible (i.e., CSI, Supply Chain
Validations) vs. traditional interdiction, in which CBP is looking for
the threats after arrival, (not an ideal situation because the WMD
may be already here).
Shared Responsibility: The program invites participation of all
trade sectors and create opportunities for companies to become
proactive in their supply chain procedures (i.e., training employees
about container security, having reporting mechanisms in place at
their owned or vendor facilities for reporting anomalies).
C-TPAT Objectives

12. Confidential – For Internal Use with Internal Audiences Only
C-TPAT allows CBP to use its knowledge, long interdiction and
enforcement experience and expand upon those qualities with C-TPAT
objectives, e.g.:
Security awareness: Opportunity of having employees
understand how smuggling, theft, organized crime networks work -
they will help identify them.
Security and efficiency: Efficient supply chain is a more secure
supply chain environment, which helps overall in conveying your
legitimacy and commitment amongst the international trade
community.
C-TPAT Objectives

13. Confidential – For Internal Use with Internal Audiences Only
Trade Act/24-Hour Rule/NTC
Advanced electronic information analysis and targeting
Non-Intrusive Inspection Technology
Employing the use of advanced inspection
technologies
NIINII
Customs-Trade Partnership Against Terrorism
Engaging the private sector to increase supply
chain security
Container Security InitiativeContainer Security Initiative
Expanding our borders by pre-screening high
risk shipments prior to arrival in the U.S.

14. Confidential – For Internal Use with Internal Audiences Only
•U.S. Importers of record
•U.S./ Canada Highway Carriers
•U.S./ Mexico Highway Carriers
•Rail Carriers
•Sea Carriers
•Air Carriers
•U.S. Port Authority/ Terminal
Operator
C-TPAT Membership
•U.S Air Freight Consolidators, Ocean
Transportation Intermediaries and Non-
Vessel Operating Common Carriers
(NVOCC)
•Mexican and Canadian Manufacturers
•Certain Invited Foreign Manufacturers
•Licensed U.S. Customs Brokers
•Third Party Logistics Providers (3PL)
•Long Haul Highway Carriers in Mexico

15. Confidential – For Internal Use with Internal Audiences Only
Reduced inspection (ATS score reduction)
Front of the line treatment for exams
Assigned CBP Supply Chain Security Specialist (SCSS) (POC)
C-TPAT Internet Portal; Security alerts (e-mail)
Access to Status Verification Interface (SVI)
Eligibility for other CBP Programs (FAST) & Training Seminars
More efficient & secure supply chain; transparency
Emphasis on self-policing, not an audit; C-TPAT guides and catalogs
(best practices)
Penalty mitigation assistance
Stratified compliance benefits
Business resumption
Benefits & Incentives

16. Confidential – For Internal Use with Internal Audiences Only
C-TPAT Benefits – Trade Based
Security Efficiency
•Good Corporate Citizen
•Product and Brand
Protection
•Partnering with Other
Government Programs
•Protecting Corporate
Information
•Better Use of Resources
•Reduced Entry Costs
•Timely Product Delivery
•Increased Productivity
•Enhanced Marketing
•Competitive Advantage
•Leveraging Information
•Resiliency

17. Confidential – For Internal Use with Internal Audiences Only
Tier 1 – Importers who have submitted a security profile that has
been reviewed and accepted. No negative findings during vetting.
Tier 2 – Importers who have been validated and are meeting the
“minimum security criteria.” (Mallinckrodt is currently approved as
Tier II)
Tier 3 – Importers who have been validated and exceed the
“minimum security criteria” and have adopted C-TPAT best practices.
(Approved by C-TPAT Director. A small number of companies
approved.)
Tiered Benefits

18. Confidential – For Internal Use with Internal Audiences Only
“The C-TPAT Supply Chain Security
Specialist (SCSS) primarily conducts C-TPAT
Validations of C-TPAT member companies
and serves as the principal advisor and
primary point of contact (POC) for certified
members in the C-TPAT program.”
Supply Chain Security Specialist

19. Confidential – For Internal Use with Internal Audiences Only
The validation process involves creating a “Validation Team” that
performs a joint review of the supply chain based on the security profile
submitted and a documented risk assessment
Each validation is customized according to the partner
An open forum to discuss issues, share ideas, address vulnerabilities
and develop solutions
Understand the role of CBP and the Trading Community in the war
against terrorism
Ensure company’s C-TPAT security profile is Reliable, Accurate, and
Effective. (Trust but verify system)
Share best practices and cooperatively develop solutions to address
potential vulnerabilities.
What is a Validation?

20. Confidential – For Internal Use with Internal Audiences Only
Validation Process
C-TPAT Guidelines and Security Criteria
Conduct Pre-Validation Risk Assessment
Conduct domestic and foreign site visit (CBP visited the Petten and
St. Louis Plants in 2014)
Site tours: Facility, D/C, customers or service providers
Verify security practices with Security Criteria
Jointly identify gaps, vulnerabilities and weaknesses
Make recommendations or actions required
Close-out meeting; Prepare Report - send to C-TPAT HQ
90-days to respond to the report
Self Policing/ Continue relationship with CBP

21. Confidential – For Internal Use with Internal Audiences Only
C-TPAT
Minimum Security Criteria
►What procedures the C-TPAT member is required to have in place.
►The starting point for partners to develop and employ effective security
practices.
►It is the responsibility of the member to study their supply chain(s),
assess the risk, and develop security controls to deal with those risks.

22. Confidential – For Internal Use with Internal Audiences Only
1.Business Partner Security - includes who the company does
business with, verify security of their business partners, verify
SVI of their C-TPAT partners, conduct security assessments of
foreign business partners.
2.Container Security & Inspection (Seals) - includes container/
conveyance inspections, tracking, sealing containers with high
security seal, reporting suspicious seals/ containers to CBP,
control and access to containers and sea.
Minimum Security Criteria –
U.S. Importers

23. Confidential – For Internal Use with Internal Audiences Only
3.Physical Access Controls - includes procedures for properly
identifying, employees, visitors and vendors as well as
preventing unauthorized access to facilities and conveyances,
removing access of terminated employees.
4.Personnel Security - includes ensuring that companies conduct
adequate screening and interviewing of employees to include
background checks (reference, criminal, drug testing),
termination policy in place.
Minimum Security Criteria –
U.S. Importers

24. Confidential – For Internal Use with Internal Audiences Only
5.Procedural Security - includes the protection of un-manifested
material into the supply chain, and includes supervision and control
of the movement of goods (some criteria consists of the proper
marking, weighing of cargo, reporting shortages and overages, and
verifications of seals on containers), ensuring that manifests are
complete and accurate.
6.Physical Security - includes building structure, perimeter fencing,
locking devices on internal and external doors, windows, etc.,
adequate lighting, CCTV capability, and security alarms.
Minimum Security Criteria –
U.S. Importers

25. Confidential – For Internal Use with Internal Audiences Only
7.Security Training & Threat Awareness - includes formal training
program for employees about cargo integrity, internal conspiracies,
container inspections, reporting any anomalies.
8.Information Technology Security (IT) - includes the protection of
companies information, protecting IT access (passwords, firewalls,
virus protection), servers in a locked room, access to shipment
information.
Minimum Security Criteria –
U.S. Importers

26. Confidential – For Internal Use with Internal Audiences Only
Information Technology Security
Passwords should be changed every 90 days
Do not share your password with anyone
Do not share access to your computer with strangers
Log-off when you leave your computer
Do not write down your password.

27. Confidential – For Internal Use with Internal Audiences Only
Information Technology Security
Use hard-to-guess passwords
Do not use the same password in more than one place
A password should have a mix of letters, numbers and symbols
I Love to be Secure iL2bs@
Always on time to work !AoT2wx
My Password is Very Secure MyP1VS#
Yo Quiero Taco Bell Yqtb!10

28. Confidential – For Internal Use with Internal Audiences Only
Electronic Mail and Telephone
Restrictions
Do not use company e-mail for private business
activities, amusement or entertainment.
Do not send e-mail containing racist, sexist,
threatening or other objectionable language.
Do not join mailing lists.
Do not open unknown or unexpected e-mail
attachments.
Do not provide personal information over the
telephone

29. Confidential – For Internal Use with Internal Audiences Only
Visitor Controls
Security personnel, the receptionist or a designated employee must
adequately control the issuance and collection of visitor badges. Follow
applicable site procedures.
Register Visitor with Reception or Security (Site procedures).
Visitor Entrance Requirements:
Ensure that your visitor has provided you a photo identification (i.e.,
driver’s license, passport), logged in and has been issued a visitor
badge.
All visitors must be escorted and visibly display their visitor badge.
Visitor Entrance
Notify
hosting
employee
Issue
Visitor
badge
Document
arrival on
Visitor Log
Check
Photo ID
Employee notifies
Reception of visitor
Visitor
arrives

30. Confidential – For Internal Use with Internal Audiences Only
Visitor Controls
Visitor Escort Requirements
You must escort your visitor(s) at ALL times
Do not leave your visitor unattended
Visitor Exit Requirements
Ensure that your visitor has logged out and has returned
the visitor badge to the guard or receptionist.

Collect
Visitor
badge
Document
departure on
Visitor Log
Visitor Exit

31. Confidential – For Internal Use with Internal Audiences Only
Employee Identification
Employee Responsibilities:
►While on company property:
Your company identification badge must be properly
displayed and worn at all times.
Properly secure and protect the following:
•ID badge
•Uniform
•Keys
•Access control devices, etc.

32. Confidential – For Internal Use with Internal Audiences Only
Suspicious Persons
LOOK FOR…..
Any person without a badge
Determine if the person is an employee or a visitor
If an employee, remind them always to display their
ID badge.
If a visitor, escort them to the reception area or to the
person with whom they are visiting.
Report the incident to your immediate supervisor and
Security.

33. Confidential – For Internal Use with Internal Audiences Only
Reporting
Security Incidents/Concerns
Report any security incident or concerns to Security.
Security will report identifiable events to law enforcement (e.g., FBI,
DHS/CBP, DEA, Local or State authorities).
View Security website @Work for latest security information.
Travel Warnings
Travel Tips
Identity Theft
Contact Information

34. Confidential – For Internal Use with Internal Audiences Only34
Security Website