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D- 98-08: Entry Requirements for Wood Packaging Material into Canada

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Effective date: July 6, 2023
9th version

Subject

This directive provides the requirements for the entry into Canada of all wood packaging material (WPM) including dunnage, pallets, or crates from all areas except the continental United States (U.S.).

Revisions

This revision includes specific import requirements for dunnage entering Canada via marine vessels. Entry of non-compliant dunnage and the presence of live pests in wood packaging material and shipborne dunnage increases risk to Canada's forest and plant resource base. A shipborne dunnage management program has been developed to address this significant risk and is described in this revision.

This directive has been revised to reflect the amendments made to the International Standards for Phytosanitary Measures (ISPM) 15 regarding approved treatments associated with wood packaging material, as well as the mark and its application (see Appendix 1). The International Plant Protection Convention (IPPC) and its Commission on Phytosanitary Measures have adopted these revisions to provide further guidance to National Plant Protection Organizations (NPPO). These changes were adopted in 2018.

This document supersedes all previous versions of directive D-98-08.

On this page

1. Legislative authority

2. Definitions, abbreviations and acronyms

Definitions for terms used in the present document can be found in the International Standard for Phytosanitary Measures 5 (ISPM 5): Glossary of phytosanitary terms or in the Canadian Food Inspection Agency (CFIA) Plant Health Glossary of Terms.

3. Introduction

The risk represented by wood packaging material and dunnage varies depending on the quality, conditioning, and degree of finishing of the wood. Many exotic plant pests have been intercepted on wood dunnage, pallets, crates, or other wood packaging material in North America. Examples of plant quarantine pests intercepted include: citrus long-horned beetle (Anoplophora chinensis), Asian long-horned beetle (Anoplophora glabripennis), European spruce bark beetle (Ips typographus), black pine bark beetle (Hylastes ater), velvet long-horned beetle (Trichoferus campestris), Monochamus sp., and others. The introduction into parts of North America of the Asian longhorned beetle (Anoplophora glabripennis), brown spruce longhorn beetle (Tetropium fuscum), emerald ash borer (Agrilus planipennis), and other exotic pests can now be linked to international shipments containing wood packaging material.

In 2009, the Commission on Phytosanitary Measures of the International Plant Protection Convention adopted a standard prescribing uniform regulatory control of wood packaging material moving in international commerce. This standard titled: "ISPM 15, Regulation of Wood Packaging Material in International Trade (PDF - 1,160 kb)" recognizes the inherent pest risks associated with the international movement of untreated wood packaging material. Although this standard does not obligate countries to establish regulatory controls, the guideline represents a mechanism by which any country may establish regulatory controls in a manner that is internationally harmonized. This Canadian import directive reflects the guidelines established in ISPM 15 as updated in 2018.

In order to mitigate the risk of pests associated with non-compliant dunnage, the CFIA has established a new shipborne dunnage program providing specific requirements for the safe discharge and disposal of shipborne dunnage in all ports of Canada.

4. Scope

4.1 Regulated pests

Numerous pests regulated by Canada could be associated with wood packaging material, including shipborne dunnage. Insects are the most commonly detected pests, but fungi and bacteria can also be associated with imported material. The list of pests regulated by Canada can be found on the CFIA website.

4.2 Regulated articles

Wood packaging material (WPM) constructed from wood of any plant species not meeting the exemptions listed in section 4.2.1.

This includes, but is not limited to, dunnage, pallets, spacers, bearers, crates, and wood bracing not permanently attached to freight vehicles or containers (for example: flat rack and flatbed containers).

Note: WPM used for the transport of logs and lumber is also regulated by this policy.

4.2.1 Commodities that are exempt from phytosanitary import requirements

The following articles are considered to be a low risk and are exempt from the requirements of this directive:

Note: information on the implementation of ISPM No. 15 (2009) for wood packaging moving between Canada and the United States is maintained on the CFIA website.

4.3 Regulated areas

All countries excluding the continental United States (U.S.).

5. Phytosanitary entry requirements

To be admissible into Canada, including movement in-transit through Canada, all wood packaging material (WPM), including dunnage, must:

A phytosanitary certificate is not required, but may be used in lieu of the marking system prescribed below. Phytosanitary certificates must specify all applicable treatment details in the treatment section.  If heat treatment was applied, an additional declaration must confirm each piece of wood has attained a minimum temperature of 56 degrees Celsius throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

Important note: the phytosanitary certificate must provide a clear link to the WPM or dunnage being imported (or discharged). Where this linkage cannot be made, the WPM or dunnage may be considered non-compliant.

A Permit to Import is not required, except for shipborne dunnage (see section 5.2).

Note: by way of bilateral arrangement, a phytosanitary certificate is not accepted for the entry of wood packaging material originating from the People's Republic of China.

5.1 Wood packaging material certification system

The NPPO of the country from which the wood packaging material originates must have a certification system in place for the approval and monitoring of facilities producing wood packaging material to meet ISPM 15.

This certification system must ensure that the wood packaging material or wood used in the repair or remanufacture of wood packaging material is in accordance with 1 of the methods specified in Appendix 1.

Facilities must be approved by the NPPO to affix a mark to the treated wood packaging material. The system of marking must conform to the specifications laid out in Appendix 1.

Many countries have indicated that they have systems in place to meet Canada's import requirements. Click here for more information about the implementation of ISPM 15 in other countries.

The requirements for treatment and marking of wood packaging material that is reused, repaired or remanufactured are described in section 4.3 of ISPM 15. Please consult the IPPC website for up to date information.

5.2 Specific phytosanitary entry requirements for shipborne dunnage

Shipborne dunnage must meet the entry requirements as specified in section 5 above. Additionally, shipborne dunnage is only permitted to be dischargedFootnote 1 at a port terminal that is designated through registration in the shipborne dunnage program, further described in section 6. The port terminals that are designated are listed in Appendix 2.

Wood packaging material that remains associated with the imported commodity after being discharged in Canada is considered to be WPM whereas any WPM that is separated from the commodity at the port of entry is considered to be shipborne dunnage.

Note: as per section 4.2.1, shipborne dunnage made entirely of continental U.S. origin wood or Canadian origin wood coming directly from the continental U.S. is exempted from the entry requirements, including discharge under the shipborne dunnage program.

5.2.1 Notification requirements for vessels planning to discharge shipborne dunnage in Canada

The vessel owner is responsible for ensuring, where a marine vessel intends to discharge dunnage in Canada, that a notification is made to the CFIA office (as listed in Appendix 3) closest to the discharge port at least 96 hours prior to the vessel's arrival in Canadian waters.

At the time of notification, the following information must be provided to the CFIA, either directly, via the vessel's Canadian agent, or any other means:

6. Shipborne dunnage program

The shipborne dunnage program allows port terminals in Canada to accept the discharge of shipborne dunnage at their facility, as per section 5.2. A Permit to Import is required. Fees for inspection and movement authorization will be charged as per the Plant Protection Fees schedule.

6.1 Permit to Import

Any Canadian individual or corporation willing to take care or control of dunnage to be discharged at any given Canadian port terminal can apply for a Permit to Import under the shipborne dunnage program.

ApplicantsFootnote 2 must apply for and receive a Permit to Import prior to shipborne dunnage being discharged at the corresponding port terminal(s). Details on the Permit to Import application process are available on the CFIA website.

Applicants must also complete an application for the shipborne dunnage program (Appendix 4).

The shipborne dunnage program process is initiated when an application for a Permit to Import is submitted to the CFIA. The nearest local CFIA office will contact the applicant to complete the registration process.

The Permit to Import will be issued once the CFIA has approved the Preventive Control Plan (PCP) and the facility has passed an evaluation inspection, as described in section 7.2.1. The local CFIA office must authorize the application for the shipborne dunnage (Appendix 4) to confirm approval.

A list of designated port terminals approved to manage shipborne dunnage is provided in Appendix 2.

6.2 Preventive Control Plan

As part of the Permit to Import issuance process, the applicant must develop, implement, and maintain a Preventive Control Plan (PCP) as described in Appendix 5 of this directive. The PCP must be submitted to the CFIA local office (see Appendix 3) for review and approval.

The PCP is a written document that describes the system-based approach developed and implemented by the applicant to ensure that risks associated with shipborne dunnage are mitigated. The PCP must include processes for receiving, inspecting, segregating, storing, moving, and ultimately disposing or processing of shipborne dunnage. Traceability must be addressed and detailed at each step. The PCP must include details on how employees responsible for work in the shipborne dunnage program are trained, as well as how the effectiveness of training is monitored, and a record of training that is delivered.

The PCP must include a procedure for amendments that describes how and when the CFIA will be informed of changes to the manual that affect the integrity of the plan. Minor editorial changes (for example: typos) do not need to be communicated to CFIA.

The specific import conditions will be outlined on the Permit to Import as per Appendix 6.

6.3 Discharge and monitoring

6.3.1 Visual monitoring and reporting

Shipborne dunnage must be visually monitored by designated terminal staff to identify materials that do not meet the entry requirements as described in section 5. Dunnage that

The PCP must describe how the dunnage will be visually monitored by trained staff during the discharge process. If shipborne dunnage not meeting entry requirements is found, the designated terminal must notify the CFIA local office. The CFIA will determine if a commodity inspection is required. If an inspection is required, the shipborne dunnage not meeting entry requirements must be:

Shipborne dunnage not meeting entry requirements will be disposed of according to the designated terminal's PCP, or as otherwise specified by the CFIA inspector.

6.3.2 Live pests or signs of live pests detected

Where live pests or signs of live pests are found in association with shipborne dunnage, notification must be made immediately to the CFIA local office (see Appendix 3). The PCP must specify the control measures that will be immediately taken to avoid the escape or movement of injurious pests from the dunnage already discharged and from any dunnage still remaining on the vessel. Infested dunnage, including dunnage and associated goods still in the holds, may be ordered to be treated prior to movement or disposal. The PCP must specify how the designated terminal will respond to the detection of a live pest.

Note: a vessel may be ordered to be removed from Canada or refused entry in Canada if it is infested or suspected to be infested with live pests.

6.4 High and low risk periods

For the revision of this directive, the CFIA examined an expansive list of insects and pathogens relevant to Canada to address the risks associated with shipborne dunnage and to determine risk periods and other factors that may impact risk. Although opportunities to establish and spread exist year-round for most pests, the winter months are the lowest-risk period in all regions of Canada. Cold temperatures minimize the spread and growth of most insects, vectors, or pathogens associated with dunnage. During the warmer months, the risk of establishment and spread of pests is much higher and that risk increases with time of exposure. Combined with practical and operational considerations, this analysis has resulted in the introduction of high and low risk periods to all ports of Canada.

The high risk periods are as below:

The low risk period occurs outside the dates specified above. Storage (section 6.5), movement (section 6.6), and disposal / processing requirements (section 6.7) are dependant on the time of the year and location of the designated terminal. Appendix 7 summarizes the impact of high and low risk periods on the shipborne dunnage program.

6.5 Storage requirements

6.5.1 General requirements

The PCP must describe where and how discharged dunnage will be stored. All discharged dunnage must be identified and segregated from any other kind of wood material. Any wood material with unknown identity or that has been co-mingled with dunnage is considered to be dunnage and must be handled as such.

6.5.2 Specific requirements for high risk period

During the high risk period, the PCP must describe how dunnage will be secured to prevent the escape of pests during and after the discharge process. If the storage container is to be opened or accessed at any time at the designated terminal, the PCP must describe the mitigation measures that will be taken to prevent the escape of pests.

Shipborne dunnage must be transported to a disposal or processing facility within 72 hours of completion of discharge.

6.5.3 Specific requirements for low risk period

During the low risk period and unless otherwise ordered by a CFIA inspector, discharged dunnage does not need to be secured and can be stored with no limitation of time, provided it is completely disposed of or processed prior to the end of the low risk period. It is permitted to store dunnage in another place than the designated terminal, as long as this is described in the PCP (see section 6.6.3).

6.5.4 Specific requirements for temporary storage facility

During the low risk period, it is possible to store shipborne dunnage in a temporary location. The PCP must specify the temporary location and how the facility will ensure the care and control of the dunnage during storage.  Shipborne dunnage must be identified and kept segregated from any other kind of wood material and must be stored so as to avoid any loss of material. The facility must retain records of stored dunnage and the dunnage must be entirely disposed of before the end of the low risk period.

During the high risk period, storage of shipborne dunnage in a temporary location is not permitted.

6.6 Movement requirements

6.6.1 General movement requirements

The movement of shipborne dunnage is not permitted without prior written approval of the CFIA local office (see Appendix 3 for a list of CFIA offices). The dunnage may only be transported following the issuance of a movement certificate (or other document as determined by the CFIA) and under the specified conditions.

The PCP must describe how the dunnage will be transported during low and high risk periods. All shipborne dunnage must be identified and kept segregated from any other wood material at all times. Any other kind of wood material that is unidentified or has been co-mingled with shipborne dunnage must be disposed of or processed in the same manner as the shipborne dunnage.

A designated terminal may include a third party contractor for the transport of dunnage in their PCP. The contractor will be subject to evaluation and inspection by the CFIA as part of the designated terminal PCP assessment.

6.6.2 Designated transport company

A third party contractor can be recognized as a "designated transport company" by submitting an application form as per Appendix 4 to the CFIA local office with all required information. A PCP covering transport requirements must also be submitted to the CFIA local office for review and approval. Designated transport companies will be inspected as per section 7.2.1.

Designated terminals must refer to the designated transport company's PCP to cover movements in their own PCP.

6.6.3 Requirements for movement to a disposal or processing facility

The dunnage must be transported directly to the site where disposal or processing is going to occur.

During the high risk period, shipborne dunnage must be transported in such a manner so as to avoid any pest escape during transport. During the low risk period, shipborne dunnage must be covered so as to prevent the loss of material during transport.

The PCP must describe how the transporter will prevent the escape of pests in the event of an accident or other extraordinary incident during the transport of the container from the designated terminal to the disposal or processing destination.

6.6.4 Requirements for movement to another designated terminal

Shipborne dunnage discharged in a designated terminal may be moved to another designated terminal to be further managed under the provision of the shipborne dunnage program. Dunnage must be identified and its location known and recorded.

During the high risk period, shipborne dunnage to be transported must be secured in a manner to prevent pest escape at all times. During the low risk period, shipborne dunnage must be covered so as to avoid any loss of material during transport.

Shipborne dunnage that has had live pests or signs of live pests detected must not be moved until mitigation measures have been taken.

The PCP of both designated terminals must describe how the dunnage will be stored at the destination terminal prior to disposal or processing (within 72 hours after completion of discharge).

6.7 Disposal or processing of shipborne dunnage

6.7.1 General requirements for disposal or processing

Discharged dunnage must be disposed of or processed in a manner as described in Appendix 8.

The disposal or processing facility must be capable of disposal or processing shipborne dunnage in a manner that prevents the introduction and spread of pests into Canada.

All shipborne dunnage must be identified and kept segregated from any other wood material at all times. Any other kind of wood material that is unidentified or has been co-mingled with shipborne dunnage must be disposed of or processed in the same manner as the shipborne dunnage.

Designated terminals using a designated disposal or processing facility must refer to the designated disposal or processing facility's PCP to cover that section in their PCP (a list of designated disposal facilities can be found in Appendix 2). Otherwise, all required information about disposal or processing need to be included in their own PCP.

Disposal or processing facilities will be inspected as per section 7.2.1.

During the high risk period

Shipborne dunnage must be stored in such a manner as to prevent any pest escape until the time it is disposed of or processed. The time limit for storage should not exceed 2 days (48 hours) following receipt of the dunnage at the disposal or processing facility.

During the low risk period

Shipborne dunnage must be completely disposed of or processed before the end of the low risk period.

6.7.2 Designated disposal facility

Facilities that intend to dispose or process shipborne dunnage can be recognized as a "designated disposal or processing facility" by submitting an application form as per Appendix 4 to the CFIA local office. In addition, a PCP covering disposition or processing must be submitted to the CFIA local office for review and approval.

6.7.3 Requirements for dunnage reused as dunnage

During the high risk period shipborne dunnage discharged in Canada as per section 5.2 cannot be reused as dunnage.

During the low risk period reuse is possible provided:

The PCP must describe how the designated facility will ensure that the conveyance with reused dunnage onboard will leave Canada prior to the high risk period.

6.8 Records

The PCP must detail all receiving, visual monitoring, and shipping records, along with any other documents that directly pertain to the shipborne dunnage program. Records must be maintained by the designated facility for a period of 2 years, and must be provided to a CFIA inspector upon request.

7. Inspection procedures

7.1 Wood packaging material, excluding shipborne dunnage

Inspection of WPM may be done at the point of entry by the Canadian Border Services Agency (CBSA), or at other locations by the CFIA. This inspection may be done separately or in conjunction with the import of other regulated commodities.

The inspection will verify:

7.2 Shipborne dunnage inspection procedures

Shipborne dunnage may be subject to inspection by the CBSA or the CFIA. The purpose of the inspection is to verify:

7.2.1 Shipborne dunnage program

Initial evaluation

CFIA inspectors will evaluate the Preventive Control Plan (PCP) submitted by facilities applying to be a designated terminal, transporter or disposal/processing facility and will conduct an evaluation preventive control inspection (PCI) to assess that the facility can implement the steps as described in their PCP.

Program delivery

CFIA inspectors will conduct surveillance PCI in designated terminals to assess adherence to the PCP during discharge of shipborne dunnage at least 2 times per year, with at least 1 being performed during high risk period. The inspection frequency may be increased if deemed necessary by the inspector. Designated transport companies and designated processing/disposal facilities are subject to the same inspection frequency. At least 1 surveillance PCI will be scheduled at the beginning of the high risk period to assess the proper transition from the low risk period.

CFIA inspectors will perform an evaluation PCI once a year to assess the facility's adherence to the conditions of the Permit to Import and their PCP as written. Designated transport companies and designated processing/disposal facilities will also be inspected for the same purpose. This inspection will review the whole PCP.

When a designated terminal reports non-compliant dunnage, the dunnage will be subject to inspection by the CFIA or CBSA.

7.2.2 Commodity inspection of dunnage

As per section 5.2, shipborne dunnage is only permitted to be discharged in Canada under the authority of a Permit to Import and approval in the shipborne dunnage program and must be disposed of or processed. On an exceptional basis, the discharge of shipborne dunnage at a port terminal where the shipborne dunnage program has not been put in place may be permitted upon prior written approval, provided an inspection is delivered by a CFIA or CBSA inspector and found compliant with entry requirements (section 5).

Requirements:

The designated terminal (or other responsible party) must also:

The CFIA may approve the request if all of the above conditions are met and operational capacity allows for the inspection.

If the shipborne dunnage meets entry requirements, written authorisation will be issued. Fees for inspection and movement authorization will be charged as per the Plant Protection Fees schedule.

8. Non-compliance

The CFIA will follow the Compliance and Enforcement Policy when informing regulated parties, assessing and monitoring compliance, and responding to instances of non-compliance. Any costs incurred due to non-compliance or violation (disposition, removal, etc.) will be the responsibility of the owner, importer, or the person having possession, care, or control of the thing.

Notifications of non-compliance will be issued in accordance with D-01-06: Canadian Phytosanitary Policy for the Notification of Non-compliance and Emergency Action.

8.1 Wood packaging material, excluding shipborne dunnage

WPM that does not meet entry requirements as per section 5 is considered to be non-compliant. Where the CBSA finds non-compliant WPM at the time of entry into Canada, the guidelines as specified in sections 41-50 of D19-1-1 will be followed. Where the CFIA finds non-compliant WPM, the material may be ordered treated prior to disposal or removal from Canada.

8.2 Shipborne dunnage

8.2.1 Discharge of dunnage in Canada

Dunnage discharged into Canada that does not comply with the phytosanitary requirements as listed in section 5 , or dunnage discharged in ports, terminals, or locations that are not designated under the shipborne dunnage program are considered to be violations of section 7 of the Plant Protection Act.

Violations of the Plant Protection Act are subject to compliance and enforcement controls, including monetary penalties. Dependant on the type of violation, the owner of the vessel, the agent, or any other individual or corporation may be identified as the responsible party.

Non-compliant dunnage may be ordered treated prior to discharge, disposal or removal from Canada.

8.2.2 Shipborne dunnage program

Designated terminals found not to be in compliance with any 1 of the conditions set out in their Permit to Import or the Plant Protection Act andregulations may have their Permit to Import cancelled.

Designated terminals, transporters and disposal/processing facilities may be removed from the program if found not to be in compliance with any 1 of the conditions set out in the shipborne dunnage program or the Plant Protection Act and regulations.

Violations of the Plant Protection Act are subject to compliance and enforcement controls, including monetary penalties.

9. References

9.1 Fees

The CFIA charges fees in accordance with the Canadian Food Inspection Agency Fees Notice, including for inspections associated with the shipborne dunnage program. Fees may also be collected by the CBSA on behalf of the CFIA. For information regarding fees associated with inspection and movement of regulated articles, please contact a local CFIA office or visit the Fees Notice web page.

9.2 Supporting documents

Note: the requirements for the importation of forest products other than wood packaging material and dunnage (including lumber, decorative wood items, etc.) are provided in directive D-02-12.

Appendix 1: Wood Packaging Material requirements for entry into Canada

Use of debarked wood

Irrespective of the type of treatment applied, wood packaging material, including dunnage, must be made of debarked wood. For the purpose of this directive, any number of visually separate and clearly distinct small pieces of bark may remain on debarked wood if they are:

Approved methods of treatment

Accepted treatments are those listed in annex 1 of IPSM 15. At the time of publication of this directive, accepted treatments were as below. Please refer to annex 1 of ISPM 15 for details regarding these treatments.

Treatments cannot be inspected directly, but can be assessed by verifying the IPPC mark and if no live pests or signs of live pests (such as frass) can be detected.

Marking of treated wood packaging material

Wood packaging material that has been treated by 1 of the methods specified above and in a manner that is officially endorsed by the NPPO of the country from which the wood packaging material originates may be permitted entry into Canada provided the wood packaging material is marked as per annex 2 of ISPM 15. Examples of acceptable marks are provided in figure 1.

Figure 1. Examples of acceptable variants of the required components of the mark

Appendix 2: Designated terminals and facilities under the shipborne dunnage program

Will be available when facilities will start being certified.

Appendix 3: CFIA offices and contact information

CFIA offices are maintained on our web page:

Contact a CFIA office by telephone - Canadian Food Inspection Agency (canada.ca)

Appendix 4: Application for the shipborne dunnage program

Printable PDF - 223 kb

I, __________, the owner/person in possession, care or control of the above named facility, apply to the shipborne dunnage program as detailed in D-98-08 to be recognized as a:

By submitting and signing this application form, I hereby accept the facility to be added on any publically available lists of designated facilities, including CFIA's web page.

____________________
Name of the contact person

____________________
Signature and date

(To be completed by the CFIA)

____________________
Name of the CFIA regional program officer

____________________
Signature and date

Appendix 5: Shipborne dunnage program: elements of a Preventive Control Plan

Whether a designated terminal, a designated transport facility or a designated disposal/processing facility, each facility involved in the shipborne dunnage program must include in its PCP any following elements that are applicable. Annex B of the Integrated Agency Inspection Model has been used to provide this guide and can be consulted for more details.

Element 1: Process control

Import control

The PCP must describe the control measures used by the designated facility to verify that discharged dunnage meets ISPM 15 requirements and CFIA's import requirements.

Product control

Designated terminals, transporters and disposal/processing facilities must describe how the dunnage will be processed to mitigate the risk of the spread of pests.

Element 2: Biosecurity control

Disposal or processing of shipborne dunnage

The PCP must indicate how the discharged shipborne dunnage will be disposed of or processed as per section 6.7. If procedures vary from high to low risk period, the PCP must explain the differences and how the transition is made.

Designated disposal or processing facilities must submit their own PCP describing all aspects of the disposal or processing procedure. All designated port terminals where shipborne dunnage is received from must be listed in the PCP. If procedures vary from 1 terminal of origin to another, the PCP must explain what are the differences and how these differences are operated.

Designated terminals that use another designated facility for the disposal or processing of shipborne dunnage must reference the PCP of the designated facility in the disposal section of their own PCP. How the facilities will communicate with each other must be described in both PCPs.

Element 3: Employee training

All employees who are involved in the shipborne dunnage program must be trained in the delivery of this program and the content of the PCP they must apply to fulfill their respective responsibilities.

The PCP must indicate:

Element 4: Equipment design and maintenance

The PCP must detail the type of equipment used to store, move or dispose/process the dunnage. Equipment must be maintained so as to meet requirements outlined in the shipborne dunnage program.

Element 6: Receiving, transportation, and storage

Receipt, inspection and storage of shipborne dunnage

The PCP must indicate how shipborne dunnage will be discharged and visually monitored as per section 6.3, as well as where and how it will be stored and secured as per section 6.5. The use of plans is suggested. Traceability and segregationFootnote 3 procedures must be detailed. Where procedures vary from high to low risk period, the PCP must explain the differences and how the transition is managed.

Transport of shipborne dunnage

The PCP must cover the transport of dunnage from the loading of the stored dunnage on the transport vehicle to the unloading of the shipment at destination. The PCP must indicate how this will be done as per section 6.6 and must include a contingency plan to prevent the escape of pests in the event of an accident. If procedures vary from high to low risk period, the PCP must explain the differences and how the transition is operated.

Movement to other countries, to other certified terminals or to disposal/processing facilities must be detailed in separate sections.

Where not covered by a designated terminal, transport companies must submit their own PCP covering all aspects of the transport procedure. If a designated company is transporting shipborne dunnage for more than 1 port terminal, each terminal should be covered in a separate section. Terminals using a designated company for the transport of shipborne dunnage can refer to the PCP of the designated company in the transport section of their own PCP. How the facilities will communicate with each other must be described in both PCPs.

Element 7: Traceability and control

Traceability

The facility has to include how each occurrence of discharge of dunnage is traced at each step of the process in the PCP.

Control

The PCP must describe how the facility will respond to a pest detection as per section 6.3.

Verification procedures

The PCP must detail an internal verification procedure to ensure that the measures included in the PCP are followed. The PCP must identify a responsible person to conduct the verification and verification frequency.

The PCP must also describe what steps will be taken following a deviation from the PCP: correcting the situation, determining the cause, and preventing reoccurrence.

Records

Records are evidence that the facility has implemented the preventive controls and that they are effective to meet the phytosanitary requirements. The facility must make them available for review by the CFIA.

The facility will need to identify records and documents associated with each element, and retain them for a period of 2 years. Some examples may include:

Amendment procedure for the PCP

The PCP should be reviewed on an ongoing basis by the facility staff to ensure that it properly details the procedures and processes in place, and that it effectively addresses the risk associated with shipborne dunnage. Minor changes to the PCP may be done at any time, major changes to the PCP that impact the integrity of the program must be submitted to the CFIA for review and approval prior to implementation.

The PCP must have an amendment record.

Appendix 6: Permit to Import conditions for the shipborne dunnage program

Important note: this appendix is provided for informational purposes only. Conditions outlined in the permits to import may differ.

Destinations

(Permits can combine more than 1 terminal of the same port, but cannot combine terminals from different ports.)

Selected conditions

Shipborne dunnage (all species)

Additional conditions

Shipborne dunnage (all species)

Appendix 7: High and low risk periods impacts on the shipborne dunnage program

- Low risk periods High risk periods
Storage requirements (section 6.5) - -
All discharged dunnage must be identified and segregated from any other kind of wood material. X X
The shipborne dunnage not meeting entry requirements as per section 6.3 must be stored in a manner that will allow for safe and efficient inspection by the CFIA.  X X
Discharged dunnage must be stored in a manner to avoid any pest escape at all times, other than when actively discharging.  - X
Shipborne dunnage must be transported to a disposal or processing facility within 72 hours of completion of discharge. - X
Discharged dunnage does not need to be secured and can be stored with no limitation of time, but must be completely disposed of or processed prior to the end of the low risk period. X -
Dunnage may be stored at a CFIA-approved temporary location. X -
Movement requirements (section 6.6) - -
The movement of shipborne dunnage from the designated terminal is not permitted without prior written approval of the CFIA local office. X X
All shipborne dunnage must be identified and kept segregated from any other wood material at all times. X X
Any other kind of wood material that is unidentified or has been co-mingled with shipborne dunnage must be disposed of or processed in the same manner as the shipborne dunnage. X X
Shipborne dunnage must be transported in such a manner so as to avoid any pest escape during transport. - X
Shipborne dunnage must be covered so as to prevent the loss of material during transport. X -
The PCP must describe how the transporter will prevent the escape of pests in the event of an accident or other extraordinary incident during the transport. X X
Disposal or processing requirements (section 6.7) - -
Shipborne dunnage must be stored in such a manner as to prevent any pest escape until the time it is disposed of or processed. - X
The time limit for storage should not exceed 2 days (48 hours) following receipt of the dunnage at the disposal or processing facility. - X
Shipborne dunnage must be completely disposed of or processed before the end of the low risk period. X -
Shipborne dunnage reused as dunnage in vessels. X -

Appendix 8: Approved disposal methods

All wood packaging material, including shipborne dunnage

The following methods may be used to dispose or process all WPM and shipborne dunnage:

Wood chipping is not an approved method of disposal due to the risk of pathogens, bacteria, or viruses that could be present. Chipping can be included as a step in the disposal or processing procedure, but must be treated or disposed of as described above.

Other disposal methods may be accepted by the CFIA on a case-by-case basis.

Compliant shipborne dunnage only

under the written authorization of the CFIA, shipborne dunnage that has been visually monitored as per section 6.3 and found compliant with entry requirements in section 5 may be permitted to be recycled (or remanufactured) in a facility registered under D-13-01. Original certification marks must be completely obliterated and the material treated and re-marked in accordance with ISPM-15 by the facility.

Segregation and identification is required at all times.

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