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RMD-20-02: Shipborne Dunnage Program

Preface

As described by the International Plant Protection Convention (IPPC), Pest Risk Analysis (PRA) includes 3 stages: initiation, pest risk assessment, and pest risk management. Initiating the PRA process involves identifying pests and pathways of concern and defining the PRA area. Pest risk assessment provides the scientific basis for the overall management of risk. Pest risk management is the process of identifying and evaluating potential mitigation measures which may be applied to reduce the identified pest risk to acceptable levels and selecting appropriate measures.

This Risk Management Document (RMD) includes a summary of the findings of a pest risk assessment and records the pest risk management process for the identified issue. It is consistent with the principles, terminology, and guidelines provided in the IPPC standards for pest risk analysis.

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Executive summary

Shipborne dunnage is a type of wood packaging material (WPM) used in marine vessels to stabilize or brace cargo during ocean transport. Like other types of WPM, dunnage is generally made from low quality wood that is more likely to be infested with forest pests than the wood used for other forest products (for example lumber or sawn wood). Upon arrival of a ship in the port, the cargo is discharged and the dunnage is then separated from the cargo and is often left at the port and treated as waste material. The origin of the cargo and the origin of the dunnage are not always the same, so the risk and types of potentially harmful pests that could be introduced through this pathway cannot be consistently known with any certainty.

The Canadian Food Inspection Agency (CFIA) has a directive, D-98-08 (Entry Requirements for Wood Packaging Material into Canada), that outlines the requirements for shipborne dunnage. This directive is based on the International Standard for Phytosanitary Measures (ISPM) 15: Regulation of wood packaging material in international trade. The current D-98-08 permits the discharge of dunnage that complies with ISPM 15, while dunnage that does not comply with ISPM 15 must remain on the vessel or be discharged under a CFIA-approved management plan. Dunnage is deemed to be compliant when it bears a standardized mark in accordance with ISPM 15 (also referred to as "stamped dunnage"). Even with worldwide implementation of ISPM 15, shipborne dunnage remains a major pathway for the introduction of invasive forest pests into Canada.

After Directive D-98-08 was implemented, the CFIA realized that inspection of discharged dunnage was unsafe and inefficient, that non-compliant dunnage was co-mingled with compliant dunnage and that traces of living pests were found on stamped dunnage. The shipping industry was informed in 2008 that, until a CFIA-approved process to manage compliant dunnage was established, all discharged dunnage was to be considered non-compliant and needed to be treated accordingly.

Many consultations and discussions involving the CFIA, Canada Border Services Agency (CBSA), stakeholders and partners have taken place over the years, but many challenging issues remain unresolved. Shipborne dunnage management is currently not uniform across Canada.

The risk management document (RMD) outlines 4 options for managing shipborne dunnage in Canada that were proposed for internal and external consultation.

Consultation took place from December 4, 2020 to January 11, 2021. Comments were received from National Plant Protection Organizations, national organizations, governmental partners, industry stakeholders and CFIA staff. The vast majority of comments were supportive of the recommended option, and were accompanied by valuable suggestions for improvement.

Purpose

The purpose of this document is to consult with CFIA staff as well as external stakeholders and to record the CFIA's analysis and decision in support of managing the risks and consistently applying phytosanitary requirements for shipborne dunnage coming into Canada.

Scope

This RMD pertains to CFIA's management of shipborne dunnage since the implementation of ISPM 15. It also provides the background and scientific rationale as to why the CFIA is proposing various pest risk management options as outlined in the RMD.

Definitions

Definitions of terms used in this document can be found in the Plant Health Glossary of Terms.

Dunnage is defined in ISPM 5 (Glossary of phytosanitary terms) as a type of "wood packaging material used to secure or support a commodity but which does not remain associated with the commodity". This RMD targets only "shipborne dunnage", which is dunnage used to brace, secure and support bulk cargo transported on ships and usually found in ship holds. Dunnage used within containers is monitored the same way as other forms of wood packaging material (for example pallets, crates, etc.) and is not covered by this document, even if these containers have been transported on ships.

Additionally, for the purpose of this risk management document, compliant and non-compliant dunnage are defined as follows:

Compliant dunnage – refers to dunnage that has been inspected and found compliant with ISPM 15 requirements: it has the recognizable and mandatory mark, it is made of debarked wood and it has no sign of presence of living pest (frass, larvae, pupae, etc.).

Non-compliant dunnage – refers to dunnage that does not meet either 1 or all of the compliant dunnage requirements described above.

Background

In 2008, the CBSA informed the CFIA of important issues regarding shipborne dunnage inspection at ports. The sorting and segregating of compliant and non-compliant dunnage at ports was determined to be a workplace safety hazard. Non-compliant dunnage was often co-mingled and discharged with compliant dunnage and was managed as compliant dunnage.

The CFIA and CBSA developed a new approach to manage mixed shipborne dunnage. Sorting and segregating of dunnage at the port was discontinued and all discharged dunnage was considered to be non-compliant. An option needed to be developed to manage compliant dunnage as such. In March 2008, Canadian industry was informed of this decision.

There have been many consultations and discussions involving the CFIA, the CBSA, stakeholders, and partners since 2008 and with renewed efforts beginning in 2015. Despite solutions and programs that were proposed, there were many unresolved issues. For example:

These issues, combined with the continuous finding of traces of living pests on dunnage and other wood packaging material in North American ports of entry and the establishment, regulation and spread of many forest pests in Canada (Emerald Ash Borer, Brown Spruce Longhorn Beetle, Asian Longhorned BeetleFootnote 1, etc.), resulted in the management of shipborne dunnage to be elevated as an issue of high importance.

In 2019, a new group was formed in CFIA to resolve these challenging issues. In 2020, consultations were also held within the CFIA in order to gain a better understanding of the issues and propose management options. These options are outlined in this Risk Management Document.

Pest risk assessment summary

CFIA completed a PRA on wood packaging material in December 2000, concluding that untreated wood packaging and dunnage present a significant pathway for the introduction and spread of regulated pests. The CFIA supports ISPM 15 and its assessment that shipborne dunnage, in particular, presents a high risk for the introduction and spread of quarantine pests.

In 2020, the CFIA initiated an update of the pest risk assessment, with specific questions on high and low risk periods for safe discharge of dunnage and options for storage and disposal of non-compliant dunnage.

The risk assessment was updated to include recent data on pest interception in Canada and the United States. According to these data, living insects are still found in wood packaging material marked with the ISPM 15 stamp and these insects are generally of phytosanitary concern to Canada. Dunnage contains the highest proportion of insect pests found in wood accompanying shipments of goods. These studies and experience show that despite the implementation of ISPM 15 throughout the world, the risk of pests entering Canada through the wood packaging pathway is still great.

The possibility of implementing a low risk period when requirements are less stringent was also evaluated. The risk of pest establishment and spread is pest specific and varies with geographical and climatic conditions. The CFIA will do a thorough review of this concept in the coming years with a list of chosen forest pests and fungal pathogens. Meanwhile, the suggested interim approach is described in the risk management considerations.

The CFIA also considered that it is better from a phytosanitary standpoint to discharge and quickly dispose of non-compliant dunnage instead of leaving it on board. This is applicable all year long at all ports of discharge of Canada. It is important to collect the non-compliant dunnage while unloading, and move it immediately to sealed storage. The goal is to limit potential pest exposure while the cargo is being discharged and the dunnage is left in the hold.

Risk management considerations

Promoting ISPM 15

The CFIA considers ISPM 15 to be an effective standard and prefers requirements that promote the use of ISPM 15 compliant dunnage.

Reuse of discharged dunnage

Although ISPM 15 is effective, it is often not implemented properly and live pests are still detected on stamped dunnage (see pest risk assessment summary above). Therefore, restrictions on reuse may need to be imposed. The CFIA would consider reuse of dunnage to be a safe practice only under strict conditions, such as if the dunnage has been thoroughly inspected by CFIA or CBSA inspectors as in option 2 below. However, in order to permit reuse of dunnage without restrictions, the CFIA will need to gather data on audit-based program compliance and non-compliant dunnage reports.

Low risk periods

Low risk periods as described in this document are subject to change in the future, since the CFIA will be reviewing them in the context of dunnage for ports of Canada. As an interim solution, the combination of the low risk periods already in use for Emerald Ash Borer, Asian Gypsy Moth and Brown Spruce Longhorn Beetle in their respective directives has been considered.

The low risk periods are from September 30 to March 1 for British Columbia ports, and from September 30 to March 15 for other ports of Canada.

Phytosanitary certificates

The use of phytosanitary certificates for dunnage in Canada is only accepted if the certified dunnage lot it covers can be clearly identified and segregated from any other dunnageFootnote 2. Each situation will be evaluated on a case by case basis.

Inspection of discharged dunnage

Proper inspection by the CFIA or the CBSA of dunnage discharged at ports is considered near to impossible. Discharged dunnage is generally presented as unstable piles of miscellaneous lumbers of all sorts 1 on top of the other, making ISPM 15 verification very difficult as well as unsafe for the inspectors. The CFIA will not perform inspection on discharged dunnage unless it is presented in a safe way that makes visual inspection possible.

Discharging non-compliant dunnage

Discharging non-compliant dunnage in Canada is a violation of Section 7 of the Plant Protection Act. However, the phytosanitary risk can be better mitigated with the quick disposal of dunnage (see pest risk assessment summary above) instead of requesting that it "remains secured on the marine vessel in a manner that would prevent the escape of pests while in Canadian waters", as was historically required. Non-compliant dunnage will have to be discharged and disposed. The CFIA may take enforcement actions on related violations, in order to promote the use of compliant dunnage.

Enforcement

Enforcement actions on violations could lead to Administrative and Monetary Penalties (AMPs). AMPs are issued to the violator, or to the entity that represents the violator in Canada if the violator has no Canadian address. The CFIA will consider the ship vessel operator to be responsible for bringing non-compliant shipborne dunnage in Canada. AMPs would be issued to the shipping agency as the Canadian representative for the vessel.

Pest risk management options

The objective of this document is to provide management options to stakeholders for their consideration. Following consultation, the CFIA will decide on the best management option or combination thereof.

See Appendix 4 for a table showing all options with their respective advantages and disadvantages.

Risk management option 1: discharge of dunnage in Canada is not permitted

Discharge of dunnage in Canada would not be permitted. All shipborne dunnage would need to remain secured on the vessel in a manner that would prevent the escape of pests while in Canadian waters.

Advantages:

Disadvantages:

Risk management option 2: dunnage can be discharged based on mandatory inspection by the CFIA or CBSA

Dunnage would be subject to 100% inspection by CFIA or CBSA inspectors during or right after discharge. Inspection will only be performed on dunnage presented in a safe manner that makes visual inspection possible and effective.

Compliant dunnage would be released without restrictions following inspection. Non-compliant dunnage would be required to be disposed of under a mandatory and CFIA-approved preventive control plan. Further, dunnage that is found to be non-compliant would be subject to regulatory and enforcement actions.

Advantages:

Disadvantages:

Risk management option 3: dunnage discharge restricted to low risk period

Shipborne dunnage could be discharged during low risk period only at Canadian ports where there are CFIA-approved preventive control plans. Segregation of compliant and non-compliant dunnage would not be required.

Low risk period

An import permit would be required and would be issued to stevedoring facilities with a CFIA-approved preventive control plan (PCP) covering all CFIA requirements on discharge, storage, transport, and disposal of dunnage.

The dunnage would be required to be stored in a way that prevents the escape of pests and disposed of on site or transported safely for disposal at a CFIA-approved facility. Stored dunnage would need to be completely disposed of by the end of the low risk period. Reuse of dunnage would not be permitted.

High risk period

Dunnage discharge would not be permitted and all dunnage would need to remain secured on the vessel in a manner that would prevent the escape of pests while in Canadian waters. Any discharge of dunnage during high risk period would be considered a violation and would be subject to enforcement action accordingly.

Advantages:

Disadvantages:

Risk management option 4: compliant dunnage can be discharged year round.

Shipborne dunnage could be discharged all year long at Canadian ports where there are CFIA-approved preventive control plans. Segregation of compliant and non-compliant dunnage would be required.

An import permit would be required and would be issued to stevedoring facilities or transport companies with a CFIA-approved preventive control plan (PCP) covering all CFIA requirements on discharge, storage, transport and disposal of dunnage. Ships that intend to discharge dunnage would be required to provide notice prior to entry into Canadian waters.

High risk period

During the high risk period, discharged dunnage would need to be stored for no more than 48 hours in sealed containers that prevent the escape of pests. The storage site would need to be no less than 30 meters from any forest or any pile of Canadian wood. Stored dunnage would then be disposed of at a CFIA-approved facility, as per the PCP. Reuse of dunnage would not be permitted.

Low risk period

During the low risk period, restrictions regarding storage time and location would not apply, provided all discharged compliant dunnage is disposed of as per the PCP before the end of the low risk period. If the dunnage is segregated and traceability is maintained, compliant dunnage could be reused as dunnage in another vessel, provided the vessel leaves Canadian waters prior to the end of the low risk periodFootnote 3.

Non-compliant dunnage

Non-compliant dunnage would be managed as described in the risk management considerations section (page 6) above and would have to be disposed of as if it is the high risk period. Import permit holders would need to report non-compliant dunnage to the CFIA immediately.

Advantages:

Disadvantages:

Risk management decision

Consultation

The RMD, proposing to implement option 4, was circulated in December 2020 to international, national and regional partners and stakeholders and feedback was received from all levels. All comments received were reviewed and taken into consideration. The majority of Canadian partners and stakeholders expressed support for option 4, as the most reasonable and applicable option. Option 2 was the next preferred option, although resources and scheduling are important limiting factors. A number of valuable suggestions were made to strengthen option 4 and make it even more flexible and applicable. 3 notable examples included: to hold customs clearance until responsibility regarding dunnage compliance has been established officially, so as to avoid enforcement targeting the wrong entity; to allow dunnage to be stored in sealed containers to be shipped back to port of origin; and to add surveillance inspections in addition to audits. All suggestions will be thoroughly evaluated, and considered for incorporation into the next revision of D-98-08.

Decision

Option 4, which received the majority of the support during the consultation, is the selected option. It combines robust pest mitigation measures with a flexible and easy-to-apply approach that also promotes and encourages the use of ISPM 15 compliant material. The CFIA will be implementing option 4, as proposed, but with some improvements that were received during the consultation. The implementation of option 4 will require the relevant plant health directive (D-98-08) be amended to incorporate the new shipborne dunnage program.

The effectiveness of option 4 will be assessed over the next several years. The CFIA is moving in a graduated direction that will permit ISPM 15 compliant dunnage to enter Canada without restrictions.

Endorsement

This risk management document has been approved by the Chief Plant Health Officer.

Appendices

Appendix 1: amendment record

Number of amendment: Amended by: Date of submission for approval of amendment: Summary of amendment and number of amended section(s) or page(s):

Appendix 2 : chronology

Appendix 3: references

Appendix 4: table of management options with comparative characteristics

Risk management option 1
discharge of dunnage in Canada is not permitted
Risk management option 2
Dunnage can be discharged based on mandatory inspection by the CFIA or CBSA
Risk management option 3
dunnage discharge restricted to low risk period
Risk management option 4
compliant dunnage can be discharged year round
Basis of program Surveillance Visual inspection by federal inspectors Audit-based system Audit-based system
Import permit required No No Yes Yes
Preventive control plan (PCP) required No Yes, but only to manage non-compliant dunnage

Yes for low risk period,
no for high risk period (discharge not permitted)

Yes
Level of complexity Low Medium High High
Allow for discharge of compliant dunnage No Yes

Yes during low risk period
No during high risk period

Yes
Reuse of compliant dunnage possible No Yes No Only during low risk period and under specific conditions
Non-compliant dunnage management Stays on the vessel (pest escape risk) Preventive control plan and enforcement strategy

As option 4 for low risk period
As option 1 for high risk period

Preventive control plan and enforcement strategy
Incentive for disposal in open waters Medium-high Low

Low during low risk period
Medium-high during high risk period

Low
Promote ISPM 15 No Yes No Yes
Meet industry needs No Yes Only during low risk period Yes
Ability to collect data Hard Very easy complicated during low risk period and hard during high risk period Easy
CFIA resources needed Low High Medium-low Medium-low
Ease of scheduling Non-applicable Difficult

Easy during low risk period
non-applicable during high risk period

Easy
Proper coverage of remote ports Very easy Expected to be difficult Easy Easy
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