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2016 OAS Guidelines

2.V.2. Building security

In order to prevent tampering with goods, but also to protect sensitive data and documents, the applicant must ensure that "the buildings to be used for the performance of AEOS-related operations offer protection against unlawful intrusion and are constructed with materials that resist unlawful entry."

The purpose of the security measures adopted to protect buildings is to prevent unlawful intrusion and, in the event of an intrusion into the perimeter fence or the building, to enable:

  • delay and deterrence of the intruder (p. e.g., by means of bars, codes, external and internal windows, doors and fences secured with locking devices);
  • rapid intrusion detection [p. e.g., with surveillance and access control measures, such as internal and external anti-theft alarm systems, or closed-circuit television (CCTV) systems;
  • the rapid reaction to intrusion (p. e.g., by using a remote transmission system to a manager or security company in the event of an alarm).

This condition must always be considered in the context of access controls and cargo security. In fact, security measures must be reflected as a whole: If applicants wish to protect their property (goods, data, buildings), they cannot sharply separate security controls and access to buildings from security measures for the goods.

Furthermore, for the purposes of risk analysis, both applicants and customs authorities will take into account the specific characteristics of each location. In some cases, the facility will consist solely of a building, which will therefore simultaneously serve as the external boundary of the company's premises; In other cases, the facility will be located in a well-protected and controlled area, such as a free port, an industrial zone, a logistics park, etc. Sometimes even the loading ramp for the entry and exit of goods will be part of the external protection line.

Also the location/configuration of the facilities (e.g. e.g., in a high-crime environment, or a newly developed area that has not been previously built up, next to or attached to other buildings, or near roads or railways) may influence the necessary measures to be taken. Such a situation may also affect the assessment of the criteria in Article 28, paragraph 1, letters a), "security of buildings", and b), "access controls", of the AE CAU. Considerations to consider when assessing this condition include, for example, whether a fence is located at the top of a slope, or on an embankment that raises it, or whether it is surrounded by a hedge or waterway that makes access to the building in question difficult.

In any case, although checking this condition is of enormous importance in order to duly take into account that each applicant must guarantee the security of its buildings and access control, the specific characteristics of SMEs must be taken into account when assessing the way in which these tasks are addressed. For example, a large manufacturer might have a perimeter wall or fence, security personnel, closed-circuit television (CCTV), etc., while a customs broker operating in a small facility might only need security locks on doors, windows, and filing cabinets.