The minimum structural standards described below will be required for all future construction.
Existing structures shall be brought into compliance before they are approved for storage of Title
II weapons. A deficiency in a given element of the standards will not constitute grounds for
disapproval if it is compensated by an appropriate countermeasure that assures the overall
security of the facility.
A. High-Security Warehouse – High security warehouses shall have walls constructed of
masonry (reinforced concrete blocks, brick) or rein-forced concrete with concrete floors.
Roof structures and/or ceilings shall be of fire-resistant construction which will provide a
degree of security equal to or greater than the approved protection of windows and
doors. The number of doors and windows will be limited to those absolutely necessary.
1. Windows shall be protected with 9-gauge steel mesh with a 2-inch diamond grid
secured to a steel frame securely attached to the building with the fastenings
inaccessible from the building exterior. Expanded metal providing the same
degree or security as 9-gauge steel mesh may be used in lieu of that mesh. Steel
bars may be used to protect windows if vertical bars are not more than 4 inches
apart with horizontal bars welded to the vertical bars so that the interstices do not
exceed 32 square inches. The ends of the steel bars will be embedded securely
in the structure of the building or welded to a steel frame fastened securely to the
building, as mentioned above. Operators should establish procedures to assure
that all windows are locked at the close of business each day.
2. Access doors shall be constructed of materials that will render forcible entry
extremely difficult within five minutes, using tools that are readily obtainable from
retail stores. All doors, except the main entrance, shall be secured on the inside
by deadlocking bars or bolts. Deadlocking bars shall be shielded from defeat
from the exterior and drilled and pinned to their holding brackets. Door frames
shall be fastened to the building so that they cannot be separated from the
casing. The main entrance to the warehouse shall be secured by a high-security
padlock and hasp. Out swinging doors shall be mounted on fixed-pin security-type
hinges, safety stud hinges, or the equivalent.
B. Buildings Which Contain a High-Security Storage Room – the circumstances
surrounding the location of a high-security storage room within a specific building will vary
from one facility to another. Customs shall encourage operators to establish procedures
to reduce the opportunity for unobserved access to the high-security storage room within
the building. Internal procedures shall include provisions to prevent loitering near the
high-security storage room. Physical security measures for buildings in which a highsecurity
storage room is located shall, at a minimum, comply with Customs Standards for
Cargo Security (TD 72-56).
C. High-Security Storage Room
3. The roofs, walls, and flooring of high-security storage rooms shall be constructed
of the same materials as a high-security storage warehouse.
a. Windows – The number of windows shall be limited to those absolutely
necessary. All high-security storage room windows shall be protected as
described in paragraph A(l) above.
b. Doors – The entrance door to the high-security storage room shall be
constructed of solid steel or of solid wood covered on the outside with
plates of at least 12-gauge steel. Door hinges shall be of a fixed-pin
security type or of a type which provides equivalent security. Unless
safety stud hinges are used, exposed hinge pins shall be spot welded or
otherwise secured to prevent their removal. All doors except the main
entrance shall be secured on the inside by deadlocking bars or bolts.
Deadlocking bars shall be shielded from defeat from the exterior and
drilled and pinned to their holding brackets. The locking device used on
the entrance door shall be a high-security padlock and hasp.
Other doors to the high-security storage room shall be of equivalent
structural strength as adjacent walls and shall be secured so as to
preclude access to the locking device from the outside. Doors leading in
or out of adjoining rooms shall be of equal strength and construction as
the door(s) to the high-security storage room.
4. A high-security storage room shall be located as distant as is practically possible
from a receiving or delivery dock.
Physical Security Measures
A. Interior and Exterior Lighting – Interior and exterior lighting shall be provided
for all high-security storage rooms themselves. The lighting shall of sufficient
intensity to afford observers immediate recognition of illegal acts such as
breaking and entering or unauthorized removal of merchandise during
nonworking hours or reduced visibility. Areas appropriate for lighting include
entrances to buildings, corridors, entrances to merchandise rooms, and interiors
of storage rooms. Switches for exterior lights shall be installed only in the interior
of the building. Exterior lights shall be covered with wire mesh screen or similar
material which will prevent their being broken by thrown objects.
B. Guard-Protection/Surveillance
1. Operators of facilities containing a high-security warehouse or highsecurity
storage room shall avail themselves of the services of a security or
guard patrol, unless this requirement is waived by the Port director.
2. Liaison shall be established with local law enforcement agencies to
assure that periodic surveillance is conducted and that a coordinated
plan for security exists. Where electronic intrusion detection systems are
used, arrangements shall be made to provide for notification to police in
case of unauthorized entry. Customs shall be notified immediately of any
theft or attempted theft at a high-security facility.
C. Electronic Intrusion Detection System
3. Intrusion detection alarms are an essential adjunct to the physical
security system. These devices, however, are not a substitute for the basic
requirements of barrier protection and administrative control as outlined in these
4. High-security warehouses and high-security storage rooms, when
actually employed as such, shall be protected with electronic intrusion
detection systems when they are not under guard. Procedures shall be
established to assure that the alarm system is engaged properly when
the building is not under guard.
5. Intrusion detection systems shall have electronic line supervision to
assure that they are operating properly, shall be subject to periodic
routine maintenance, and shall be monitored continuously when they are
in operation. Response time to alarms shall not exceed 5 minutes.
D. Key and Lock Controls
Keys to high security warehouses shall be issued only to the facility manager and
one assistant, and to the supervising Customs officer of the facility. Both
Customs and the zone operator shall establish a key control plan that identifies
and records where keys are at all times, who has physical possession, and for
what purpose. There shall be no master key, and only one key or its duplicate
shall fit each key way. Locks shall be re keyed at least annually at a random
unannounced time. Combinations for combination licks shall be memorized, and
shall be divulged on at least as limited a basis as keys are issued. Locks, keys,
and combinations shall be changed whenever it is known or suspected that they
have been compromised.
E. Security of Tools
Tools located in the vicinity of high-security storage areas shall be secured in a
locked container and removed from the vicin4-ty of the high-security warehouse
or storage room. When a high-security warehouse or storage room is the only
secure location available, the tools shall be stored within a locked container in
that warehouse or room. When the access door to a high-security storage room
is located within an adjacent room, tools shall not be stored within that adjacent
room. Examples of such tools are hammers, bolt cutters, chisels, crowbars, and
similar items which would assist in gaining forced entry to the secure areas.
F. Personnel Security
In addition to the requirements of Section 146.7(g) CR and the recommendations of TD
72-56 concerning Personnel Screening, the facility operator shall furnish Customs with
the names and dates of birth of all officers and employees at the time the warehouse is
considered for storage of Title II firearms. The officers and employees shall be given a
background investigation consisting of at least a TECS and NCIC check before the
warehouse is approved for storage of those firearms.

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