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CUSTOMS TRADE PARTNERSHIP AGAINST TERRORISM TRAINING PLAN Container and Seal Inspection Process

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CUSTOMS TRADE PARTNERSHIP AGAINST TERRORISMTRAINING PLAN

Container and Seal Inspection Process

©2019 W. L. Gore & Associates, Inc.

Objectives

8-point container inspection procedures/process review, tools and training

Sealing criteria and procedures/processes – review and training

Cargo Log

IIT Loading Procedure

©2019 W. L. Gore & Associates, Inc.

8 Point Container Inspection Procedures/Process

Using the checklist, document the results and include with the shipping records.

Conduct an 8 point interior and exterior inspection to verify the physical integrity prior to loading.

©2019 W. L. Gore & Associates, Inc.

U.S. Importers – Point of Receipt 1 of 2

Ensure the seals envelope the rectangular hardware base of the vertical bars in order to eliminate any upward or downward movement.

Remove the slack from both sides of the cable

Use the VVTT method to ensure the cables are taut.

Tug and pull the cable to see if there is any cable slippage within the locking body mechanism.

Use CBP’s VVTT method (view, verify, twist and tug) when affixing a seal to a container.

V – view seal and container locking mechanisms

V – verify seal number for accuracy

T – tug on seal to make sure it is affixed properly

T – twist and turn seal to make sure it does not unscrew

©2019 W. L. Gore & Associates, Inc.

U.S. Importers – Point of Receipt 2 of 2

Cut seals may be held on site but must be kept in a locked container until they are sent to Left Bank for proper destruction who will dispose of them based on current recycling practices.

Compromised seals and/or containers must be:

Reported to the W.L Gore CTPAT Team members via email at [email protected], or via phone, Gary Cooke @ (410) 506- 2839 or Tom Stearns (410) 506-4210.

Held at the plant until released by the CTPAT team upon which the seal would be sent to Left Bank for destruction.

Reported to US Customs and Border Patrol and or the appropriate foreign authority by the CTPAT team immediately if a security risk is identified.

After offloading the container, it is recommended to do a visual inspection.

©2019 W. L. Gore & Associates, Inc.

8 Point Inspection @ Manufacturers - Point of Sealing slide 1 of 8

Tools required to perform inspection are as follows:

Probing Stick - can be a broom handle which is used to tap on floors, walls and ceiling. Sound should be hollow, seeking to identify density or a thud.

Mirror on a stick - used to look at the under carriage, roof or other hard to see areas. Seeking to find compartment/stowage locations.

Tape measure, rope, range finder or laser pointer - used to measure inner and outer measurements which are confirmed against the trailer size noted on the booking forms.

High Security Seal Log Book

©2019 W. L. Gore & Associates, Inc.

Outside and Undercarriage Inspection slide 2 of 8

Before allowing the container to back up to the dock:

Inspect undercarriage and outside of container

Use a mirror to access hard to see areas

Note: The undercarriage of the container should be ribbed with support bars approximately every 18”–36”.

If the bottom appears to be sealed (solid plates should NOT cover the beams) or the support bars are missing, there may be a false floor.

©2019 W. L. Gore & Associates, Inc.

Front Wall Inspection slide 3 of 8 Inspect front wall, making sure vents and blocks are visible and appropriately spaced.

Measure the interior and exterior, container should be exact to specifications.

Look for color variations in the walls.

Tap the front wall to confirm hearing a hollow metal sound.

Ensure that interior corner blocks are visible and not false.

Verify that the front wall is made of corrugated steel.

Inspect the front panels, the corners posts, and markings.

©2019 W. L. Gore & Associates, Inc.

Left and Right Sides Inspection slide 4 of 8

Inspect internal and external surfaces, including structural beams and use a tool to tap the front wall, you should hear a hollow metal sound. All walls, ceilings and doors should be metal. Any repairs on the inside must also be visible on the outside.

Inspect side panels, top and bottom rails, and forklift pocket entrances.

Inspect corner posts and markings.

Verify that ventilation holes are visible and uncovered. Covered or missing ventilation holes could indicate a false wall.

©2019 W. L. Gore & Associates, Inc.

Interior For Inspection slide 5 of 8

Inspect floor for unusual repairs. Floor should be flat and one height.

Measure floor to ceiling as the container should be exact to specifications. You should NOT need to step up from edge of container to get inside, there should be no steps or raised platforms inside container.

©2019 W. L. Gore & Associates, Inc.

Ceiling / Roof slide 6 of 8

Inspect external roof and internal ceiling, including structural beams.

Use tool to tap ceiling (you should hear a metal, hollow sound.) If unable to see roof of container, use a ladder or a mirror attached to a pole to inspect. Any repairs such as welded areas should be visible on inside and outside of container.

Look for unusual welding or repair on support beams as false compartments are common in ceilings, beams, floors, door and the front wall.

©2019 W. L. Gore & Associates, Inc.

Doors: Outside and Inside slide 7 of 8

Inspect door panels, locking bars/rods, locking bar cams, hinge components, door gaskets and retaining strips, upper and lower corner fittings, and rain gutter.

Ensure locking mechanisms are secure and in good working order. There should be ribs on the interior sides of each door; solid plates should not be cover standard interior door cavities.

Look for different color bonding materials, loose bolts, new and worn metals on same device. Doors should seal completely when closed.

©2019 W. L. Gore & Associates, Inc.

Upon Completion of the inspection slide 8 of 8

Utilize the 8 point inspection checklist to document your findings of the inspection.

Include the 8 point inspection checklist with the shipping records in the export file.

Notify the necessary parties if needed. (i.e. container cannot be used)

Load the container

Seal container utilizing the sealing of containers procedure

Maintain a copy of the 8 point inspection checklist

Submit a copy of the 8 point inspection checklist with the shipping documents

©2019 W. L. Gore & Associates, Inc.

Sealing Procedure / Processes

https://www.gore.com/about/c-tpat

©2019 W. L. Gore & Associates, Inc.

Seals, Log and Inventory Requirements

▪ Seals must be compliant with ISO 17712:2013 standards for high security seals.

– Maintain documentation regarding the compliance standard must be on file for verification.

▪ Upon receipt of seals:

– an inventory audit must be conducted,

– Record seals in a seal log to include the unique seal number.

▪ Conduct seal inventories yearly during the internal audit process.

▪ Maintain evidence to support audit was conducted.

▪ Secure seals in a designed area with limited access.

▪ Designate specific Associates to ensure seal inventory is maintained properly.

©2019 W. L. Gore & Associates, Inc.

Seals, Log and Inventory Requirements

Upon issuance of seals, complete the seal log with the following:

Seal Number

Container Number

Bill of Lading Number

Export Reference # (sales or purchase order numbers)

Note if the seal is an original seal or a replacement seal

Name of person affixing seal to the container, dated and initialed by that person

©2019 W. L. Gore & Associates, Inc.

Manufacturers - Point of Sealing slide 1 of 2

– Ensure the seals envelope the rectangular hardware base of the vertical bars in order to eliminate any upward or downward movement.

– Remove the slack from both sides of the cable

– Use the VVTT method to ensure the cables are taut.

– Tug and pull the cable in order to determine if there is any cable slippage within the locking body mechanism.

– Use CBP’s VVTT method (view, verify, twist and tug) when affixing a seal to a container.

• V – view seal and container locking mechanisms

• V – verify seal number for accuracy

• T – tug on seal to make sure it is affixed properly

• T – twist and turn seal to make sure it does not unscrew

©2019 W. L. Gore & Associates, Inc.

Manufacturers - Point of Sealing slide 2 of 2

Placement of seals must be by a designated person who has received seal security training.

Placement of seals must be witnessed by another person who has had seal security training, to ensure it has been properly affixed using U.S. Custom’s VVTT method.

Compromised seals and/or containers, destined for W. L Gore and Associates, Gore customers or 3rd party providers, must be reported as follows when an immediate security risk is identified:

Internal at Gore: contact the W.L Gore CTPAT Team members via email at [email protected], or via phone, Gary Cooke @ +1(410) 506 - 2839 or Tom Stearns +1(410) 506 - 4210.

External parties: Contact your local security and foreign authorities. Next, provide W.L Gore CTPAT Team members an email at [email protected], or via phone, Gary Cooke @ +1(410) 506 - 2839 or Tom Stearns +1(410) 506 – 4210 advising of the situation.

©2019 W. L. Gore & Associates, Inc.

Container Storage

Empty containers that are dropped at the facility for loading at a later time must be parked either door-to-door or stored securely using other methods to prevent tampering.

Store all loaded containers with seals affixed to the doors (a must).

Store containers in a secure area to prevent unauthorized access and/or manipulation.

Ensure procedures are in place for reporting any unauthorized entry into containers or container storage areas.

Ensure the facility does not allow loaded containers to remain overnight under normal circumstances. If there is no alternative, the containers should be placed in areas where cameras can monitor them, preferably in fenced-in parking area with a security guard/watchman.

©2019 W. L. Gore & Associates, Inc.

Summary

Utilize the Gore 8 Point Inspection Checklist for Containers Processes

Log seals into the seal log

Utilize proper sealing procedures, to include having a witness

Use the checklist to document findings & Retain records (checklists and logs)

Compromised seals and/or containers, destined for W. L Gore and Associates, Gore customers or 3rd party providers, must be reported as follows when an immediate security risk is identified:

Internal at Gore: contact the W.L Gore CTPAT Team members via email at [email protected], or via phone, Gary Cooke @ +1(410) 506 - 2839 or Tom Stearns +1(410) 506 - 4210.

External parties: Contact your local security and foreign authorities. Next, provide W.L Gore CTPAT Team members an email at [email protected], or via phone, Gary Cooke @ +1(410) 506 - 2839 or Tom Stearns +1(410) 506 – 4210 advising of the situation.

©2019 W. L. Gore & Associates, Inc.

Cargo Log Requirements

Upon exporting of cargo, record the following in the cargo log:

Name of Driver Photo ID verified

Company / Employer Name ID Number

Truck # / License Plate # Date

Container # Time In

Seal Number Time Out

©2019 W. L. Gore & Associates, Inc.

Transitions from Container Sealing to the IIT Procedures

©2019 W. L. Gore & Associates, Inc.

IIT Loading Procedure slide 1- 7

Containers: use the following procedures/checklists

CTPAT Container Sealing Procedure UPDATED

Complete the High Security Seal Log UPDATED

Complete the 8 Point Inspection Checklist using the 8 Point Ocean Container Inspection Security Guide (2 sided visual aid) NEW / UPDATED

Submit the 8 Point Inspection Checklist with the shipping documents NEW

Maintain a copy of the 8 Point Inspection Checklist with plant’s daily shipping paperwork. NEW

Complete the Cargo Log for all Exports NEW

Reference the Gore CTPAT Internet (GORE.com/about/c-tpat) as needed

©2019 W. L. Gore & Associates, Inc.

Cores, Drums, Racks, Pallets, etc slide 2- 7

All Wood Packaging Materials (WPM) must be compliant with the International StandardsOf Phytosanitary Measures (ISPM) 15 and possess the International Plant ProtectionConvention Markings.

For areas of vulnerability specifically look for:Support Arms of Racks (prior to capping)Interior of cardboard tubes (of the product)Beds of the racksHollow metal bars at the bottom of rackBottom of rack Between rolls after being put onto the rack (top/bottom, sides)

All freight will go to the 3PL properly marked and labeled.

©2019 W. L. Gore & Associates, Inc.

Gore Warehouse Locations slide 3- 7

Color dot/ sticker on product to help identify destination location

Yellow = Putzbrunn 5 (APE)

Green= Germany (ITG- Putzbrunn 3/ Putzbrunn 1)

Blue = Germany (Putzbrunn 4)

Pink = China (Shenzhen)

Purple = Japan (Nihon Gore)

Preliminary check of security vulnerability areas

Move product to the staging area for shipment

Ensure the product is loaded on interplant truck to move to the 3PL

©2019 W. L. Gore & Associates, Inc.

Gore Shipping & Receiving Associates slide 4- 7

Confirms ship to location in the system

Creates International Shipping Documents

Creates Customs Invoice, Packing List and Export letter

Sends all documents to the freight forwarder (Expeditors) and 3PL to include the 8 point inspection container checklist if applicable

Sends the packing list to the consolidator, one will be used by 3PL for verification to include the 8 point inspection container checklist if applicable

Note: Products can be shipped as manufactured, but must be confirmed before shipping.

©2019 W. L. Gore & Associates, Inc.

Consolidator slide 5- 7

Receives product and creates receiving report

Contacts the Gore Consolidation Team when discrepancies are found

Generates one bill of lading (dock receipt) for each consolidated shipment

Conducts a visual inspection of any instruments of international traffic (Cores, Racks, Pallets, etc.) and materials prior to loading the container. Shipper is looking for any non-manifested materials, products or contraband of any sort. Areas of vulnerability have been highlighted in the OTB rack awareness and procedure.

Conducts and documents the 8 point container inspection and sealing process and includes with the shipping papers.

Sends the signed bill of lading and the 8 point container inspection checklist to Expeditors and Gore once the container is loaded.

©2019 W. L. Gore & Associates, Inc.

Freight Forwarder (Expeditors) slide 6- 7

Makes the container booking based on a request from consolidation team

Sets the load date with dray carrier

Creates the master ocean bill of lading

Informs both 3PL and Gore of any changes

©2019 W. L. Gore & Associates, Inc.

Notification Process for all slide 7- 7

Compromised instruments of international traffic, such as OTB racks, the materials on these racks must be reported to the W.L Gore CTPAT Team members via email at [email protected], or via phone, Gary Cooke @ (410) 506 - 2839 or Tom Stearns (410) 506 - 4210. US Customs and Border Patrol and or the appropriate foreign authority shall be notified immediately if a security risk is identified.

If discovered in a foreign location customer, supplier or provider may have to notify their local Customs authority.

QUESTIONS?

THANK YOU