Dear Member,
As a follow up to our CL 11496, and CL 11521, the Federation organized an information session on CFIAs new shipborne dunnage program for members and the wider marine industry. The virtual information session held on Friday, May 12th, was well attended by over 70 participants from all sectors of the industry including members, terminals, stevedores and other service providers.
Hugo Fréchette, a Forestry Programs Specialist with CFIA gave a comprehensive overview on the shipborne dunnage program and you can click here for his presentation. It is important to note here that the presentation was oriented toward those who may be interested in applying for the import permit in order to provide dunnage services to vessel owners and operators.
He clarified that any Canadian individual or corporation willing to take care or control of dunnage to be discharged at any Canadian port terminal can apply for an Import Permit under the shipborne dunnage program The Import Permit Holder must have a CFIA approved and audited PCP (Preventive Control Plan) outlining procedures to safely monitor the discharge of marine dunnage.
Aside from dunnage definition in the policy, the key take aways of note were:
- It is only shipborne dunnage that is targeted by the new shipborne dunnage program. Dunnage is any wood packaging material (WPM) that has been used to secure the cargo and has been disassociated from the cargo at some point after discharge. Shipborne dunnage is dunnage brought into Canada by a vessel and the disassociation of the dunnage from its cargo happens at the point of entry at the port. Thus, if the disassociation of the WPM from its cargo brought by the vessel occurs outside the port terminal such as a warehouse, the dunnage is outside the scope of this program and therefore not targeted as shipborne dunnage.
- Definition of designated Port Terminals was also clarified. A port may have one or several terminals. It is the specific port terminal that is identified in the PCP (Preventative Control Plan) that will be under the shipborne dunnage program and thus permitted to discharge dunnage. Port terminals in the wider port area that are not listed in the PCP would be prohibited from discharging dunnage.
- When a vessel unloading goods has some dunnage that is temporarily landed ashore and is reloaded on the vessel, that dunnage is not considered “discharged” and is considered outside the scope of the shipborne dunnage program. This allows for dunnage to be transferred to the quay temporarily as long as it is loaded back onto the vessel and this can occur at non-designated terminals. Thus, the shipborne dunnage program only targets dunnage that is removed from the vessel and needs to be managed.
- Unmarked pieces of dunnage will be considered non-compliant unless there is a Phytosanitary Certificate which identifies the dunnage and a clear link between the certificate and the dunnage is established. The CFIA said it is important that all cut pieces of dunnage be clearly stamped.
- Those interested in applying for the Import Permit, raised concerns of PCP requirements. The PCP is a written procedure detailing the discharge and management of dunnage. CFIA stressed that the PCP is not prescriptive and there is no template. The elements of the PCP were provided in the program and can be used as guidance to write the PCP. CFIA stated that they were not expecting “experts” in the field. Their priority is visual monitoring (live pests and signs of live pests being the most important). Information sessions could be scheduled by CFIA and they would also provide documents such as Training Aid and Key Tags. PCP applications once submitted are reviewed by CFIA and once approved, the applicant can apply for the Import Permit.
- Notification is required from Vessels to CFIA offices of shipborne dunnage to be discharged (96 hours prior to entering Canadian waters). Notice via email will suffice. Questioned if there will be a penalty if notice was not provided well in advance. CFIA advised they expect to receive such notifications within the required time frame; however, justification will be considered for late notification.
Dunnage is on the Agenda in the TC/CFIA meeting on June 1st. If you have any questions or comments or wish to have another information session scheduled before the shipborne dunnage program comes into effect July 6th, please contact the undersigned.
Sincerely,
Chad Allen,
Director, Marine Operations