June 29, 2023 | Circular No. 11544

Dear Member,

The Federation’s Annual Ship and Cargo Inspection Meeting was held on June 1st at the Port of Montreal with close to 60 participants in attendance. The objective of this meeting was to provide members with updates on Transport Canada and Canadian Food Inspection Agency’s (CFIA) various programs and allow members to discuss any service issues.  Please click here for list of participants.

Transport Canada, Marine Safety & Security (TC, MSS)

Marine Safety and Security (MSS) provided updates on their various cargo inspection programs.  In 2022, Transport Canada inspected 1,269 vessels loading over 70M tonnes of grain, concentrates and deck timber across Canada.  This is down from the 1,468 vessels and 72M tonnes loaded in 2021.  Transport Canada conducted 711 export dangerous goods container inspections, in which there was a 31% failure rate compared to a 25% failure rate observed in 2021.

MSS are focused on modernizing their overall inspection program, and some of these initiatives include; remote inspections for mandatory cargoes, develop an online database to submit service requests for cargo inspection, and explore other pilot projects aimed to bring efficiency to the overall inspection program.  MSS also provided updates on amendments to the Cargo, Fumigation and Tackle Regulations, International Maritime Solid Bulk Cargoes (IMSBC), International Maritime Dangerous Goods Code (IMDG) Codes and the International Grain Code.  This is the third and final year of the phase-in approach for the Marine Safety Fees Regulations.  In subsequent years, increases will be linked to CPI and effective in April.  Also of note, the IMDG Code Amendment 41-22 will come into force on January 1, 2024.

They also provided a recap of the Port State Control program including an overview of the 2022 results and an outlook for 2023.  In 2022, there were a total of 1,110 inspections of which 666 (60%) were found with deficiencies. Forty-eight (4%) of those deficiencies resulted in detentions.  A Concentrated Inspection Campaign (CIC) will run between September and November focusing on fire safety and the 2024 campaign will target crew wages and seafarer employment agreements under the Maritime Labour Convention (MLC).  Transport Canada also reminded participants of their obligations under the MLC with respect to the repatriation of seafarers and access to shore leave, violations of which may lead to PSC deficiency or detention.

Marine Occupational Health and Safety (MOHS)
Transport Canada (TC) is consulting stakeholders on designating cargo holds as hazardous confined spaces.  They have released a guidance document outlining the hazards, obligations and applications as per the Maritime Occupational Health and Safety Regulations.  A ship’s cargo hold could be hazardous as it can be designed, constructed, or be in a location or contain an atmosphere, materials or substances, that can present hazards to those who enter. The IMO reported 106 accidents between 1999 and December 2018, in which at least 140 people lost their lives from asphyxiation, poisoning from toxic gases, explosion, or fire on ships carrying solid bulk cargoes.  Please click here for the MOHS presentation.

Transport Canada is also raising awareness with respect to safe access to vessels which is a shared responsibility between all stakeholders.  An SSB (Ship Safety Bulletin) will soon be issued offering guidance to large vessels highlighting international and national requirements when such vessels are operating in Canadian waters.

Transportation of Dangerous Goods (TDG)
The presentation provided an overview of the Transportation of Dangerous Goods (TDG) program covering partnership with Transport Canada’s Marine Safety & Security, undeclared/mis-declared dangerous goods risk assessment, the National Oversight Program (NOP), changes to DG training requirements and the TDG proposed amendments in Bill C-33 including a new dangerous goods site registration framework.

An amendment to Bill C-33 introduces a Site Registration requirement previously known as Client Identification Database (CID) which was launched to enable Transport Canada to identify the dangerous goods regulated community.  This will require businesses who handle, offer for transport, transport or import dangerous goods, to register under this program.  One of the important proposed modifications by Transport Canada to the site registration requirement is clarifying the definition of “Site” – for eg. For marine transport, the definition of site includes locations where dangerous goods are being loaded and unloaded, but does not include an office, warehouse or a vessel.  For example, a common-use terminal will be registered as a “Site” under this program.

Transport Canada have proposed amendments to the training requirements in which employers must ensure that all employees who handle, offer for transport, transport or import dangerous goods, receive general awareness and function-specific training. New general standards were created which focus on Competency Based Training and Assessment which is similar to the methodology of the IMDG code training requirements. The proposed regulations will be published in Canada Gazette II in the Fall of 2023 and expected Royal Assent in January 2024.  There will be a 12-month transitional period and a soft implementation approach to support stakeholders.  Transport Canada confirmed that with employees trained in accordance with the IMDG Code, will be considered properly trained in accordance the new TDG Regulations.

Transport Canada conducts random inspections of import dangerous goods containers after discharge and before entering the Canadian supply chain network.  In the event of a non-compliance, the container will be detained until the deficiency is rectified.

CFIA (Canadian Food Inspection Agency)
Formerly known as Asian Gypsy Moth, CFIA applauded industry’s high compliance rate with the FSMC (Flighted Spongy Moth Complex).  In 2022, CFIA processed 1,535 vessels in which 95% were certified.  Of the 457 vessels that were randomly inspected by CFIA, 98% of the vessels were found free of FSMC, however, 2% (9 vessels) were detected with masses.  In Langley, BC, two moths (no egg mass) were detected in 2021, triggering an aerial spray program which continued through 2022.  No trap captures have been reported since, however CFIA will continue to monitor through 2023.  Please click here for FSMC presentation.

The new Shipborne Dunnage Program is detailed in D-98-08 and will come into effect on July 6th, 2023.  CFIA reported that their inspection staff were trained and prepared.  As well, CBSA have been informed of the changes and are supportive with regards to inspection and enforcement of the program.  However, no import permits have been issued to date and only a few PCPs are under review.  CFIA and the Federation will continue the outreach to industry in order to raise the awareness of the program.  When the program is in effect, members are to expect increased surveillance within Canadian port terminals including random inspections of discharged dunnage and audits of the delivery of the program.  Please click here for the presentation. The Federation will soon be finalizing a guidance document with respect to D-98-08.


No. Action Item Responsible Party
1. Marine Safety and Security to provide detailed breakdown on port state control deficiencies at the next meeting Transport Canada
2. Transport Canada to review stricter compliance/enforcement of undeclared/mis-declared dangerous goods Transport Canada
3. Federation to distribute to members the MOHS guidance document regarding cargo holds as confined spaces Shipping Federation of Canada
4. Federation to distribute to members the Ship Safety Bulleting (SSB) on safe access to vessels focusing on gangway net safety Shipping Federation of Canada
5. Marine Safety and Security to provide the details of the MOHS open house in Vancouver on June 7th and the Federation to distribute to interested members Transport Canada
6. Federation to update members to recap the recent TDG (Transportation of Dangerous Goods) developments Shipping Federation of Canada
7. Federation to monitor the application of the Site Registration as will be required by TDG as it relates to members’ registering their offices which do not directly handle dangerous goods Shipping Federation of Canada
8. CFIA to review the application of the new shipborne dunnage program to the container sector, noting the policy was developed for the wider break-bulk sector Canadian Food Inspection Agency
9. CFIA to consider Preventative Control Plan (PCP) applications which may include procedures to discharge dunnage at anchor Canadian Food Inspection Agency
10. Federation and CFIA to consider scheduling a meeting between CFIA and marine terminals regarding the new shipborne dunnage program Shipping Federation of Canada & Canadian Food Inspection Agency
11. Federation to organize a meeting with container line members to present reports from the North American Sea Container Initiative Workshop and also an international update (IPPC and NAPPO) Shipping Federation of Canada


Chad Allen,
Director, Marine Operations
Shipping Federation of Canada