How to use cargo seals

Control

PIP members must safeguard the use of seals and maintain a record of seal numbers they have issued and used.

Follow these instructions to ensure that the appropriate measures are in place:

• have written procedures that stipulate how seals are controlled and attached to a loaded container
• strictly control access to seals by:
  • limiting the number designated employees who have access
  • by storing seals in a secure location (for example, locked cabinet, safe) until they are needed
• keep records of seal usage in case of an audit or investigation
• where possible, keep or discard used or broken seals in a safe and secure manner to prevent misuse or duplication

If you are unsure how to properly dispose used seals, ask the CBSA staff during your next site validation, or contact us at pip-pep@cbsa-asfc.gc.ca.

Attach seals to prevent tampering

As a PIP member, you must make sure to have a high-security seal on the container or conveyance in your custody. When used properly, a seal will help prevent and detect unauthorized access and signs of tampering.

Only individuals who have received instruction and training should attach seals. Among the acceptable ways to prevent tampering are:

1. putting a seal in a different location to prevent the swiveling of an outer door locking cam
2. using equivalent tamper-evident measures such as high-security cable seals across the door-locking bars or applying tamper evident tape
3. applying an item such a trailer door bar lock in addition to the required high-security seal
4. using GPS and RFID technology to track trailers and containers

Inspecting and tracking

The receiving party is in charge of inspecting seals on cargo-laden containers or trailers at each transfer of custody.

When inspecting seals, it is necessary to:

• check for visual and physical signs of tampering
• compare the seal's identification number with the cargo documentation
• note the inspection in the appropriate documentation

Be sure to have written procedures in place that outline the following:

• how seal changes or replacements get recorded
• how discrepancies get documented and reported

Discrepancies

The receiving party (or the party in possession) must report if:

• the seal is missing
• it shows signs of tampering
• it has a different identification number than the cargo documentation

If the receiving party notices any of these discrepancies, they must note it in the cargo documentation.

Reporting

If you come across any inconsistencies or suspected illegal activity, here's what you can do:

• immediately report the incident to a CBSA border services officer at the point of entry into Canada
• report the incident to another appropriate law enforcement agency
• PIP members can contact their regional program representative
• call the CBSA toll-free border watch line:
  • phone: 1-888-502-9060
• for incidents occurring outside of Canada, PIP members should notify the appropriate foreign authority

Point of origin

Cargo integrity begins at the point of origin. The point of origin is the first place where the cargo is loaded into the shipping container. When you have many shipments loaded at various locations, you need to make sure your cargo is protected throughout the chain and at all stops.

The shipper or exporter at the point of origin has the following responsibilities. They must:

• make sure your container or trailer gets loaded and sealed in a safe and secure way (until the carrier assumes control)
• provide an accurate and complete description of the cargo
• be sure that the seal number is documented on the manifest:
  • this provides a method of verifying legitimate seals

Highway carrier

The highway carrier has the following responsibilities. They must:

• check all documentation when picking up cargo, including manifests and bills of lading
• seal an unsealed container or trailer that they took possession of
• record the seal number on the cargo documentation
• inform their dispatch immediately if a seal has been broken or removed
• a replacement seal must then be attached to the load and the new seal number recorded

PIP members must also verify that any written seal numbers match the seals that have been attached to the trailer or container. This inspection process must be documented. PIP members must also verify that any written seal numbers match the seals that have been attached to the trailer or container. This inspection process must be documented.

Rail carrier

The rail carrier has the following responsibilities. They must:

• check the cargo documentation when picking up a load, such as manifests or bills of lading
• have procedures to prevent the loading of contraband while trains are in transit to Canada, including unforeseen train stops
• maintain inventory information and movement records on each rail car
• use the physical rail car tracking technology that is inherent to the North American rail network system

A high-security seal must be attached to all loaded rail cars and intermodal maritime containers moving by rail to Canada where the design of the rail car permits. Rail carriers crossing the border into Canada must also make sure that PIP members are meeting the seal requirements and reporting any problems with the seal.

Marine carrier

Marine carriers or their agents must inspect seals and document their condition on the manifest or bill of lading before the container is loaded onto their vessel. Any unsealed containers must have a seal attached by the marine carrier, and ensure that the seal number is recorded on all cargo documentation.

Air carrier

In situations where an air carrier does not have full control over the handling and loading of cargo, they must work with their business partners to put in place pertinent security measures. The air carrier is legally responsible for oversight of all cargo loaded on board its aircraft.

Importer or warehouse operator

The first party to open a container, such as a consignee, or de-consolidator, has the following responsibilities. They must:

• inspect the seal before removing it
• note any discrepancies between the seal and the information listed on the cargo documentation
• report any suspected illegal activity to the CBSA or appropriate authority, such as the police or local port authority

Less-than-truck-load, less-than-container-load, pickup and delivery

All containers and trailers crossing into Canada must be secured with a high-security seal.

You can consider other options instead of a seal when there are multiple stops to pick up or deliver local freight. Alternatives include high-security padlocks or similar appropriate locking devices. As a PIP member, you must develop and enforce strict measures for the safe control of keys and combination numbers for these devices.

For consolidated freight, the seal number(s) may be recorded on the consolidated lead sheet rather than the individual bills of lading. Seal numbers should be listed on the documents presented at the first point of arrival.

Failure to meet or maintain seal requirements

If your seal policies and practices appear to be insufficient, we may place your company on an action plan to correct any deficiencies. If you can't meet or maintain seal requirements, we may deny or cancel your membership.