CTPAT Breakdown: 9.15

Item 9.15

If camera systems are deployed, periodic, random reviews of the camera
footage must be conducted (by management, security, or other
designated personnel) to verify that cargo security procedures are being
properly followed in accordance with the law. Results of the reviews
must be summarized in writing to include any corrective actions taken.
The results must be maintained for a sufficient time for audit purposes.

Implementation Guidelines

If camera footage is only reviewed for cause (as part of an investigation following a security breach etc.), the full benefit of having cameras is not being realized. Cameras are not only investigative tools. If used proactively, they may help prevent a security breach from occurring in the first place.
Focus the random review of the footage on the physical chain of custody to ensure the shipment remained secure and all security protocols were followed. Some examples of processes that may be reviewed are the following:
• Cargo handling activities;
• Container inspections;
• The loading process;
• Sealing process;
• Conveyance arrival/exit; and
• Cargo departure, etc.
Purpose of the review: The review is intended to evaluate overall adherence and effectiveness of established security processes, identify gaps or perceived weaknesses, and prescribe corrective actions in support of improvement to security processes. Based on risk (previous incidents or an anonymous report on an employee failing to follow
security protocols at the loading dock, etc.), the Member may target a review periodically.
Items to include in the written summary:
• The date of the review;
• Date of the footage that was reviewed;
• Which camera/area was the recording from;
• Brief description of any findings; and
• If warranted, corrective actions.

So if a camera system is being utilized, randomly review the footage to make sure procedures are being followed.

Purely a management item.

Big brother is watching!!

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