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Facility Security & C-TPAT

(Customs-Trade Partnership against Terrorism)

      1. Policy
        1. As a certified member of C-TPAT (Customs-Trade Partnership against Terrorism), it is policy that all Rocky Brands vendors establish facility procedures to guard against the introduction of non-manifested cargo into outbound shipments. Such items would include (but not be limited to) drugs, biological agents, explosives, weapons, radioactive materials, illegal aliens, & other contraband following C-TPAT guidelines. Rocky requires a questionnaire be completed and sent to Rocky Brands prior to first business transaction as instructed, and annually thereafter.
      2. Procedure Security
        1. Procedure should be in place to protect against non-manifested material being introduced into the supply chain following C-TPAT guidelines.
        2. Security controls following C-TPAT guidelines should include (but not necessarily be limited to):
          1. The supervised introduction/removal of cargo.
          2. The proper marking, weighing, counting and documenting of cargo; verified against manifest documents.
          3. The detecting/reporting of shortages/overages.
          4. Procedures for verifying seals on containers, trailers and railcars.
          5. The movement of incoming/outgoing goods should be monitored
          6. Random, unannounced security assessments of areas in your company’s control within the supply chain should be conducted.
          7. Procedures for notifying Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected, or suspected, by the company should also be in place.
      3. Physical Security
        1. Following C-TPAT guidelines, all buildings & rail / truck yards should be constructed of materials which resist unlawful entry and protect against outside intrusion.
        2. Physical security should include:
          1. Perimeter fences
          2. Locking devices on external and internal doors, windows, gates.
          3. Fences and adequate lighting inside and outside of the facility.
          4. The segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged or otherwise fenced-in area.
      4. Access Controls
        1. FollowingC-TPAT guidelines, unauthorized access to facilities and conveyances should be prohibited.
          1. Controls should include (but not necessarily be limited to) positive identification of all employees, visitors & vendors.
          2. Procedure should also include challenging unauthorized/unidentified persons.
      5. Personal Security
        1. Companies should conduct employment screening and interviewing of prospective employees to include appropriate background checks and application verifications, Following C-TPAT guidelines.
      6. Eduction and Training Awareness
        1. FollowingC-TPAT guidelines, a security awareness program should be provided to employees including:
          1. The recognition of internal conspiracies.
          2. Maintaining cargo integrity.
          3. Determining and addressing unauthorized access.
        2. These programs should offer incentives for active employee participation in security controls.
      7. Manifest Procedure
        1. Following C-TPAT guidelines, companies should ensure that manifests are complete, legible, accurate and submitted in a timely manner to Customs.
      8. Conveyance Security
        1. Following C-TPAT guidelines, conveyance integrity should be maintained to protect against the introduction of unauthorized personnel and material.
        2. Security should include (but not necessarily be limited to):
          1. The physical search of all readily accessible areas.
          2. The securing of internal/external compartments and panels.
          3. Procedures for reporting cases in which unauthorized personnel, non-manifested materials, or signs of tampering, are discovered.

Container Security Policy

Rocky Brands Inc. provides the following guidelines in an ongoing commitment to implement security procedures recommended by C-TPAT (Customs Trade Partnership against Terrorism)

Empty Containers:

      1. Empty containers must be secured in a facility which meets Rocky Brands security criteria as follows:
        1. Perimeter fencing should enclose container yard. If yard is unfenced then empty containers should be backed into dock door when possible.
        2. Gates through which vehicles or personnel enter or exit must be monitored.
        3. Overhead lighting which illuminates all corners must be provided for the entire storage yard, as well as along the fence lines.
        4. Pin locks must be placed on each chassis when container is dropped.
        5. In all cases a 7 point inspection must be performed on the container prior to loading. Please reference the “C-TPAT 7 Point Inspection Process” document for further guidelines regarding the 7 point inspection: Front Wall, Left side, Right side, Ceiling/Roof, Inside/outside doors, Outside/Undercarriage
      2. A check on the entire facility must occur daily to include the following items:
        1. Is fencing intact and undamaged?
        2. Are seals or padlocks intact on the containers?
        3. Are any suspicious materials in or around the chassis or tires?
        4. A check on the entire facility must occur daily to include the following items:
      3. Should a breach in security in the container yard be detected, immediately notify the manager of the yard as well as local authorities (as applicable)

Loaded Containers:

  1. Warehouse staff must validate authorized trucker is picking up cargo, and verify the driver’s Company ID or driver’s license before releasing loaded container.
  2. In the circumstances where a loaded container may remain at the facility overnight you must secure it by backing it up to a solid wall, apply a lock to the doors and locking the chassis.

Seal Integrity & Verification Policy

Rocky Shoes & Boots provides the following guidelines in an ongoing commitment to implement security procedures recommended by C-TPAT (Customs Trade Partnership Against Terrorism).

  1. Obligation To Seal: The party that physically performs the stuffing of the container is responsible for sealing the container immediately upon the conclusion of a secure stuffing process. Each seal has a unique number, which must be provided to the carrier by the shipper.
  2. Seal Standards: Rocky requires that the Ocean carriers use high security bolt container seals as specified by the ISO/PAS17712 International Organization for Standardization.
  3. Seal Integrity testing: Rocky requires that seals be thoroughly inspected for loss of integrity or possible tampering. Suspected or confirmed problems with seal integrity must be immediately communicated to local customs officials and Rocky Brands. Please refer to “C-TPAT 7 Point Inspection Process” document to obtain further guidance on testing methods
  4. Recording Seal Numbers: Upon affixing the seal, the seal number must be recorded on the bill of lading.
  5. Recording Seal Changes: Rocky must be notified immediately if the exporting port authority or Carrier should need to break the seal. The carrier or terminal operator must record the new seal number on the relevant shipping documents and notify Rocky with the new seal number.
  6. Seal Anomalies: There are four different kinds of seal “anomalies” that could arise under these procedures:
    • The seal does not meet the ISO standard.
    • The seal number does not match the seal number in the shipping documents.
    • The seal has been tampered with and is not intact.
    • The seal is missing.

Immediately notify your local port authorities and Rocky Brands should any of these anomalies be discovered.