Canada Issues PIP Guidelines on High-Security Mechanical Seals

According to CBSA sources, the requirements outlined in the Guidelines are not new and are simply meant to complement and clarify what is stipulated in the Security Profile¹. Sources add that a draft of the guidelines was circulated to PIP members last year for comment and that this document represents the final version, taking into account the comments submitted.

(PIP provides benefits such as lower examination rates to companies² that demonstrate a good compliance record and actively participate in the program. It is available to the entire trade community, from importers, carriers, brokers, warehouse operators to associations and is similar to U.S. Customs and Border Protection's (CBP's) Customs-Trade Partnership Against Terrorism (C-TPAT).)

PIP Requires High Security Seals that Meet/Exceed ISO/PAS 17712

Sealing trailers and containers and ensuring continuous seal integrity throughout the life cycle of a containerized shipment of goods are crucial elements of a secure supply chain and critical parts of a member's commitment to PIP. Among other things, PIP members must monitor all components of their supply chain and monitor and advise their business partners, to the best of their ability, to verify that high-security seals are being used in accordance with PIP security requirements.

(Note that use of high security ISO/PAS 17712 High Security seals is also a C-TPAT requirement. See ITT's Online Archives or 09/24/08 news, 08092410, for BP summary.)

Meeting/exceeding ISO/PAS 17712. For PIP purposes, high-security mechanical freight container seals are categorized as seals that meet or exceed the current ISO/PAS 17712 standard for freight container mechanical seals. Seals that conform or exceed this standard are manufactured with strong metal materials with the intent to delay intrusion, and the seals generally require removal with bolt or cable cutters. CBSA adds that for PIP purposes, companies must agree to use seals that:

meet the "H" (high security) level as outlined in ISO/PAS 17712;

are strong/durable against weather, chemical action and undetectable tampering;

are easy to apply and seal;

are permanently and uniquely marked;

have the seal manufacturer's logo easily identifiable.

PIP Member Responsibilities Related to Seals

Among other things, PIP members must do the following related to seals (partial list):

acquire seals from legitimate manufacturers and acquire and maintain the seal manufacturer's test report issued by an independent ISO17025-certified testing laboratory;

work with their business partners to ensure that pertinent security measures related to the proper use of seals are in place and adhered to throughout their supply chain;

ensure a high-security seal is affixed to all their containers crossing the border into Canada. (In cases where such seals are not suitable or not able to detect access (e.g. tank trailers, bulk or open top loads, livestock trailers, etc) CBSA states PIP members must demonstrate they use other effective methods (e.g., tamper-evident tape or more frequent or thorough inspections).)

if an exporter, seal the container or trailer until such time as the carrier assumes control, ensuring that the seal number is documented on the manifest;

ensure seals are appropriately applied to the container/conveyance in their custody;

have written procedures in place that stipulate how seals in their possession are to be controlled, issued, affixed, tracked, removed and destroyed, etc.

Failure to Comply May Result in Cancellation of PIP Membership

When the CBSA becomes aware that a PIP member is not maintaining his or her responsibility to seal loads, CBSA officers will investigate, consider any action taken by the member to mitigate the situation, recommend Action Plan steps, etc. Companies that do not meet the seal criteria are subject to suspension or cancellation from PIP.

(See guidelines for PIP seal requirements for importers, freight forwarders, etc.)

¹The Security Profile is divided into generic sections (which apply to all applicants) and sections specifically developed for each of the business sectors, which identify the specific minimum security criteria. (See ITT's Online Archives or 03/04/08 and 06/27/08 news, 08030410 and 08062799 3, for BP summaries.)

²To be a PIP member, applicants must own or operate facilities in Canada that are directly involved in the importation and exportation of commercial goods or the applicant must be a U.S. highway carrier company applying for a Free and Secure Trade (FAST) Canada membership.

See ITT's Online Archives or 07/02/08 news, 08070215, for BP summary of U.S. and Canada signing a PIP/C-TPAT Cargo Security Mutual Recognition Agreement.)

CBSA's "Cargo Sealing Guidelines for PIP Members" (dated 03/04/09) available at http://www.cbsa.gc.ca/security-securite/pip-pep/seals-scelles-eng.html