Further to CL 11195, the Canadian Food Inspection Agency has announced a decision on Risk Management Document RMD-20-02: Shipborne Dunnage Program regarding their new break-bulk dunnage policy where compliant dunnage will be allowed to be discharged year-round. The RMD outlined four options for managing shipborne dunnage in Canada that were proposed for internal and external consultation:
- Discharge of dunnage in Canada is not permitted;
- Dunnage can be discharged based on mandatory inspection by the CFIA or CBSA;
- Dunnage discharge restricted to low-risk period; and
- Compliant dunnage can be discharged year-round.
Following consultation, the CFIA analyzed all comments and suggestions and the RMD-20-02 has been modified accordingly and provides all the relevant information. The vast majority of comments were supportive of the recommended risk management option 4 – compliant dunnage can be discharged year-round at Canadian ports where there are CFIA-approved preventative control plans. This option promotes ISPM 15, addresses industry requests to discharge and reuse dunnage, safely deals with non-compliant dunnage year-round, and permits an audit-based approach that requires less resources and is not schedule-dependent. The Federation also provided valuable suggestions for improvement:
- Ensure that penalties for cases of non-compliance are directed to the party responsible for the dunnage, which may not necessarily be the ship operator or marine agent;
- Establish a pragmatic approach to default, non-compliant labelling of chocks and blocks due to the absence of marking; and
- Extend applicants beyond terminals and stevedores, especially in smaller ports; ensure a quick approval process to allow for a company to register a PCP and obtain a permit.
The CFIA intends to begin consultation on a revised directive towards the end of 2021, with an official publication end of winter/early spring 2022. The transition period is anticipated to last several months and the program would be implemented near fall 2022.
The Federation will keep members informed with updated information. Please contact the undersigned with any further questions.