Partners in Protection

Cargo Sealing Guidelines for PIP Members

Introduction

Proper sealing of cargo helps assure the security of goods being imported into or exported from Canada. This document provides direction to PIP members on the use of high-security mechanical seals on containers and trailers for imported, exported and in-transit cargo. This document should be used in conjunction with the prescribed Security Profile submitted to the PIP program as it applies to the applicable industry sector, shipment or conveyance.

Supply Chain and Business Partners’ Responsibilities

From point of origin to final destination, there is often more than one party involved in the movement of cargo. Each party in possession of a container or trailer is responsible for the security of any cargo entrusted to them, whether the cargo is at rest or in transit.

There are many circumstances in which a PIP member will not have a direct control over, or responsibility for, the cargo before taking possession. The Canada Border Services Agency (CBSA) recognizes these circumstances and endorses the application and implementation of security measures based on the assessed level of risk. To this end, PIP members must help set the standard by working with their business partners to ensure appropriate security measures are in place. Such measures include the proper use of seals throughout their respective supply chains. The practice of using seals is therefore not limited to PIP members and includes any company that participates in a PIP member’s international supply chain. Such companies include domestic and foreign suppliers, manufacturers, cargo handling and storage facilities, conveyances, warehouses or other elements.

To ensure that PIP procedures are being met, members are obligated to clearly define, document and implement their seal procedures as outlined below. PIP members are also expected to ensure that these procedures are implemented by their business partners with respect to the handling of any cargo that is affiliated with a PIP member.

PIP Seal Requirements

Seals used by PIP members must meet or exceed the current PAS/ISO 17712 standards for high security. Such seals have been manufactured with strong metal materials with the intent to delay intrusion and generally require the use of bolt or cable cutters to be removed. They can be made of one or two components and can usually be identified by an “H” (for high-security) stamped directly on the seal. High-security seals offer maximum protection and are generally in the form of bolt or cable seals. Examples include:

High-security bolt seal - A seal consisting of a metal rod, threaded or unthreaded, flexible or rigid, with a formed head and secured with a separate locking mechanism.

High-security cable seal - A seal consisting of a cable and a locking mechanism. On a one-piece seal, the locking or seizing mechanism is permanently attached to one end of the cable. A two-piece cable seal has a separate locking mechanism that slips onto the cable or prefabricated cable end.

High-security padlock - A reusable lock that can only be opened with a combination code or key. Note that high-security padlocks may only be used for multiple domestic pickups (i.e. less-than-truckload – LTL) where other cargo is added to an existing load en route. High-security padlocks cannot be used for cross-border shipments. Once final loading of a container or trailer has been completed, a high security seal must be affixed before crossing the border.

To help you confirm that you and your partners are using seals that meet the PIP standard, all high-security seals have the same basic features. In addition to the seal manufacturer's logo being easily identifiable, the seal should be:

  1. Strong and durable against weather, chemical action and undetectable tampering;
  2. Easy to apply and seal; and,
  3. Permanently and uniquely marked.

For additional information on this or other standards, please consult the ISO website or contact your seal supplier.

Seal Authentication

PIP members are responsible for acquiring seals from legitimate manufacturers. Companies purchasing seals to meet PIP requirements should acquire the seal manufacturer's test report issued by an independent testing laboratory. Members should maintain this documentation for future reference.

The CBSA does not endorse any particular seal manufacturer or product. However, there are organizations such as the International Seal Manufacturers Association that can provide guidance to PIP members who are searching for seal manufacturers offering ISO/PAS 17712 high-security seals.

Seal Application and Control

All PIP members that affix or remove seals must have written procedures in place to stipulate how seals in their possession are controlled, issued, affixed, tracked, removed and destroyed.

Control

PIP members must safeguard the use of seals and maintain a record of seal numbers they have issued and used. To ensure that the appropriate measures are followed, PIP members must have written procedures that stipulate how seals are controlled and affixed to a loaded container. PIP members are also strongly encouraged to strictly control access to seals by limiting the number designated employees who have access and by storing seals in a secure location (e.g., locked cabinet, safe) until they are needed.

In addition to controlling access to unused seals, PIP members should keep records of seal usage in case of an audit or investigation. Where possible, used or broken seals should also be retained or discarded in a safe and secure manner in order to prevent misuse or duplication. PIP members and applicants who are unsure how to properly dispose used seals should raise their questions during their next site validation, or contact the PIP inbox at pip-pep@cbsa-asfc.gc.ca.

Application

PIP members must ensure that seals are appropriately applied to the container or conveyance in their custody to help prevent and detect unauthorized access and signs of tampering. Seals are to be affixed by authorized individuals. Before assigning a person the responsibility of affixing seals, this individual should receive the appropriate instruction and training. When used properly, a high quality seal should be applied to the container in a manner that prevents tampering or unauthorized access. Among the acceptable ways to prevent tampering are:

  1. Using alternative seal locations that prevent the swiveling of an outer door locking cam; or,
  2. Using equivalent tamper-evident measures such as high-security cable seals across the door-locking bars.

Inspecting and tracking

Seals on cargo-laden containers or trailers should be inspected by the receiving party at each transfer of custody. Inspecting a seal requires visual and physical checks for signs of tampering, comparing the seal's identification number with the cargo documentation, and noting the inspection in the appropriate documentation.

Written procedures must be established to record any seal changes or replacements, and stipulate how discrepancies are documented and reported.

Discrepancies

If the seal is missing, shows signs of tampering, or has a different identification number than the cargo documentation, the receiving party (or the party in possession) must report and note the discrepancy on the cargo documentation.

Reporting

Any anomalies or suspected illegal activity should be reported immediately to a CBSA Border Services Officer (BSO) at the point of entry into Canada, or to another appropriate law enforcement agency.

PIP members can also contact their regional program representative or call the CBSA toll-free Border Watch phone line at 1-888-502-9060. PIP members should notify the appropriate foreign authority for incidents occurring outside of Canada.

Replacing seals

If a seal is removed prior to arriving at the border by law enforcement or government officials, it is the responsibility of the carrier to replace the seal and document the particulars, including the new seal number, on all pertinent cargo documentation. The carrier will not be required to re-seal loads examined by the CBSA if a BSO has applied a CBSA high-security seal after examination.

Securing ‘non- sealable’ cargo

PIP members must ensure that a high-security seal is affixed to all their containers crossing the border into Canada. However not all types of commercial loads and/or conveyances are suitable for high-security seals or padlocks. Examples include tank trailers, bulk or open top loads, dump trailers, tractors, open van trailers, step decks, flatbeds, livestock trailers, and other types of open trailers or oversize loads where a seal will not detect access. In these situations, PIP members must demonstrate other effective methods to ensure the integrity of their cargo while in transit. For example, using tamper-evident tape or undertaking more frequent or thorough inspections.

PIP Member Roles and Responsibilities

Point of Origin

Cargo integrity begins at the point of origin, defined as the first place where the cargo is loaded into the shipping container. In the event that there are multiple shipments loaded at various locations, cargo integrity needs to be maintained throughout the chain and at all stops.

It is the fundamental responsibility of the shipper or exporter to ensure the safe and secure loading and sealing of the container or trailer, and to provide an accurate and complete description of the cargo. The point of origin is responsible for sealing the container or trailer until such time as the carrier assumes control. The point of origin must also ensure that the seal number is documented on the manifest, thereby providing a method of verifying legitimate seals.

Highway Carriers

When picking up cargo, the highway carrier is responsible for checking all documentation, including manifests and bills of lading. PIP members must also verify that any written seal numbers match the seals that have been affixed to the trailer or container. This inspection process must be documented.

If a carrier takes possession of a container or trailer that has not been sealed, it is the responsibility of the PIP carrier to seal the container or trailer and record the seal number on the cargo documentation.

In the event that a seal has been broken or removed, the highway carrier is responsible for notifying their dispatch immediately, and providing pertinent details. A replacement seal must then be affixed to the load and the new seal number recorded.

However, some types of commercial loads and conveyances may not be suitable for high-security seals or padlocks (e.g. tank trailers, bulk or open top loads, dump trailers, tractors, open van trailers, step decks, flatbeds, livestock trailers and other types of open trailers or oversize loads where a seal will not detect access). In these situations, PIP members must demonstrate that they use other effective methods to ensure the integrity of their cargo while in-transit. Examples include: tamper-evident tape or conducting and documenting more frequent and thorough inspections.

Rail Carriers

A rail carrier picking up a load must check the cargo documentation such as manifests or bills of lading. Rail carriers should have procedures in place to guard against the loading of contraband while trains are in transit to the border into Canada, including unforeseen train stops. They must maintain inventory information and movement records on each rail car and use the physical rail car tracking technology that is inherent to the North American rail network system.

To the extent practical, a high-security seal should be affixed to all loaded rail cars and intermodal maritime containers moving by rail and destined for Canada. Rail carriers crossing the border into Canada must also fully ensure seal requirements are met and that any seal anomalies are reported.

Marine Carriers

Marine carriers or their agents must inspect seals and document their condition on the manifest or bill of lading before the container is loaded onto their vessel. Any unsealed containers must have a seal affixed by the marine carrier, and ensure that the seal number is recorded on all cargo documentation.

Air Carrier

In situations where an air carrier does not have full control over the handling and loading of cargo, they must work with their business partners to ensure that pertinent security measures are implemented. The air carrier is legally responsible for oversight of all cargo loaded on board its aircraft.

Importer, Warehouse Operator

The first party to open a container, such as a consignee, or de-consolidator, must inspect the seal before removing it and note any discrepancies between the seal and the information listed on the cargo documentation. Any anomalies where illegal activity is suspected should be reported to the CBSA or appropriate authority such as the police or local port authority.

Less-Than-Truck-Load (LTL), Less-Than-Container-Load (LCL), Pickup and Delivery (P&D)

High-security padlocks or similar appropriate locking devices may be used instead of high-security seals when there are multiple stops to pick up or deliver local freight. PIP members must develop and enforce strict measures for the safe control of keys and combination numbers for these devices.

All containers and trailers crossing the border into Canada must be secured with a high-security seal.

If a facility where several shipments from multiple companies is used to consolidate freight (such as a warehouse), the seal number(s) may be recorded on the consolidated lead sheet rather than the individual bills of lading. Seal numbers should be listed on the documents presented at the first point of arrival.

Failure to Meet or Maintain PIP Seal Requirements

PIP Applicants

Where an applicant's policies and practices with respect to seals appear to be insufficient, the company may be placed on an Action Plan by the PIP program to correct any sealing deficiencies. Failure to meet or maintain seal requirements may result in denial or cancellation of membership.

The CBSA will confirm that the seal policies and procedures described in the PIP Security Profile are in line with the program’s minimum security requirements. To ensure applicants meet all requirements, PIP Officers will ask to see the following during the PIP site validation process:

  1. A certificate of conformance/attestation that seals meet or exceed ISO PAS 17712 requirements;
  2. Evidence of company seal policies, procedures or protocols;
  3. Written company procedures to adequately control the seals;
  4. How employees are made aware of the sealing policies and procedures;
  5. Evidence that company management or security personnel investigate seal anomalies;
  6. Evidence of action taken by the company when a seal discrepancy is discovered;
  7. Where the seals are stored; and
  8. The method for discarding used seals.

PIP Members

When the CBSA becomes aware that a PIP member is not adhering to sealing responsibilities, the CBSA will investigate to determine the cause and scope of the incident. The CBSA will also consider any action(s) taken by the member to mitigate the situation.

Based on the evaluation and history of the organization, the CBSA will determine the best course of action for the company. This may include issuing an Action Plan outlining the necessary steps to address the identified gaps. If the prescribed action items are not addressed, PIP membership may be suspended pending compliance with seal requirements, or cancelled.

Questions

Should you require further information or wish to submit questions related to these sealing guidelines, please contact the PIP program at pip-pep@cbsa-asfc.gc.ca or bring them to the attention of to the PIP Officer during your site visit.

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