Page 1 of 15

RMD 20-02 1st Version

Shipborne Dunnage Program

Consultation Risk Management Document (RMD)

Canadian Food Inspection Agency

59 Camelot Drive

Ottawa, Ontario, K1A 0Y9

CANADA

Page 2 of 15

Preface

As described by the International Plant Protection Convention (IPPC), Pest Risk Analysis

(PRA) includes three 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.

Table of contents

Executive Summary ........................................................................................................ 3

Purpose ........................................................................................................................... 3

Scope .............................................................................................................................. 4

Definitions ...................................................................................................................... 4

Background ..................................................................................................................... 4

Pest Risk Assessment Summary ...................................................................................... 5

Risk Management Considerations.................................................................................... 6

Pest Risk Management Options ....................................................................................... 7

Risk Management Option 1: Discharge of dunnage in Canada is not permitted ............ 8

Risk Management Option 2: Dunnage can be discharged based on mandatory

inspection by the CFIA or CBSA ................................................................................. 8

Risk Management Option 3: Dunnage discharge restricted to low risk period .............. 9

Risk Management Option 4: Compliant dunnage can be discharged year round. ........ 10

Risk Management Recommendation.............................................................................. 11

Appendices.................................................................................................................... 12

Page 3 of 15

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 (e.g. 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 directiveD-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 current Risk Management Document outlines four options for managing shipborne

dunnage in Canada that are being proposed for internal and external consultation.

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

Page 4 of 15

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

Terms1.

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 (i.e. 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, i.e. 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 one 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

1 https://www.inspection.gc.ca/plant-health/plant-pests-invasive-

species/directives/glossary/eng/1304730588212/1304730789969

Page 5 of 15

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:

Responsibilities between the CBSA and the CFIA regarding dunnage at ports of

Canada were unclear despite the umbrella memorandum of understanding (MOU)

and the more detailed memorandum D-19-11 signed between the two agencies;

It is not clear, even to industry, who owns the discharged dunnage and it has been

difficult to find suitable stakeholders to take charge of discharged dunnage;

Canada is a large country and ports are located in many geographical, climatic

and commercial contexts that make national uniformity challenging;

It was difficult to figure out how to manage non-compliant dunnage. If left on

board the ship it was deemed unsafe from a phytosanitary perspective. On the

other hand, if it was allowed to be discharged the same way as compliant

dunnage, then it was considered as an incentive to use non-compliant material.

Therefore, an adequate enforcement strategy was not achieved.

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 Beetle2, 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

2 Asian Longhorned Beetle (Anoplophora glabripennis) has established periodically, but has been

eradicated each time.

Page 6 of 15

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

Page 7 of 15

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 30th to March 1st for British Columbia ports,

and from September 30th to March 15th 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

dunnage3. 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 one 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

3 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.

Page 8 of 15

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:

Theoretically lowest risk of pest introduction into Canada;

Simplest option to understand and apply for both industry stakeholders and the

CFIA;

Limited inspection/monitoring activities at Canadian ports for both the CFIA

and the CBSA.

Disadvantages:

Does not promote ISPM 15;

Does not address industry requests to discharge and reuse dunnage;

Does not allow for data collection on dunnage;

Can present a risk of pest escape if dunnage is ineffectively safeguarded on

the vessel;

May be an incentive for disposal in open waters, including Canadian

waterways.

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.

Page 9 of 15

Advantages:

Promotes ISPM 15;

Address industry requests to discharge and reuse dunnage;

Data collection on dunnage is possible;

Reuse of dunnage is possible;

Dunnage inspection relies on federal inspectors.

Disadvantages:

Safe and efficient inspection requirements might be challenging to meet at

some ports;

CFIA/CBSA hours of service might not meet industry needs;

CFIA/CBSA resources might not be able to meet industry needs;

CFIA/CBSA might have difficulties covering remote ports;

Some ports might have difficulties with implementation of a preventive

control plan.

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:

Address industry requests to discharge dunnage during low risk period;

Page 10 of 15

Theoretically lowest risk of pests introduction into Canada during high risk

period;

Safely deals with non-compliant dunnage during low risk period;

Audit-based approach requiring fewer resources than option 2, as well as not

being dependent on scheduling inspections;

Current ad hoc agreements would need minimal adaptation to fit with this

program during low risk period.

Disadvantages:

Does not promote ISPM 15;

Does not address industry requests to discharge and reuse dunnage during

high risk period;

Data collection on dunnage is not possible;

Reuse of dunnage would not be possible;

May be an incentive for disposal in open waters, including Canadian

waterways, during high risk period;

Can present a risk of pest escape if dunnage is ineffectively safeguarded on

the vessel during high risk season;

Some ports might have difficulties with implementation of a preventive

control plan.

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

Page 11 of 15

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 period4.

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:

Promotes ISPM 15;

Address industry requests to discharge and reuse dunnage;

Data collection on dunnage would be possible;

Allows discharge of dunnage all year long;

Safely deals with non-compliant dunnage all year long;

Audit-based approach that would require less resources than option 2 as well

as not being schedule-dependent;

Restricted reuse of dunnage would be permitted during the low risk period;

Current ad hoc agreements would need minimal adaptation to fit with this

option.

Disadvantages:

Reuse of dunnage would not be permitted during the high risk period;

Reuse of dunnage during the low risk period could lead to a slight risk of pest

escape;

Might be difficult to meet CFIA requirements in some ports.

Risk Management Recommendation

The CFIA recommends the use of option 4, because it is an effective and applicable

option that offers the best mitigation of risks in order to protect our forest resources. It

is also an option that meets most industry needs. We believe this option can be applied

in ports across Canada.

The current consultation process will allow the CFIA to gather inputs from partners and

stakeholders. The CFIA will analyse these inputs and make a decision. Directive D-98-

08 will be amended to include the proposed changes outlined in this document. Internal

and external stakeholders will be consulted before amendments to the D-98-08 are

accepted.

4 This option only allows discharged dunnage to be reused on a vessel and is not designed to create or

certify new dunnage.

Page 12 of 15

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):

Page 13 of 15

Appendix 2 : Chronology

• 1995: Canadian authorities became aware of the dunnage issues related to the

separation / treatment / transport / disposal of non-compliant dunnage.

• 1998: the CFIA established import requirements for wood packaging materials

and shipborne dunnage in directive D-98-08: Entry requirements for wood

packaging material into Canada.

• 2000: The CFIA completed a Pest Risk Assessment on wood packaging and

dunnage

• 1995-2002: Compliance arrangements at some Canadian ports.

• 2002: First adoption of ISPM 15 and corresponding harmonization of D-98-08.

• 2003-2008: The CFIA authorized segregation of non-compliant shipborne

dunnage.

• 2005: inspection of WPM and dunnage at all ports of entry were transferred to the

newly created Canada Border Services Agency (CBSA), as reflected in the

Memorandum D19-1-1 .

• 2008: Letter sent to the industry informing all dunnage is from now on considered

non-compliant and has to be managed accordingly.

• Since 2008: Various regional arrangements for the discharge and inspection of

ship-borne dunnage.

• 2015: Industry requested recognition of their efforts in using ISPM 15 compliant

ship-borne dunnage and a consistent national approach to compliance verification

and enforcement.

• 2015: The CFIA formed an internal working group to explore options for the

discharge of ship-borne dunnage to reduce pest risk.

• January 2016: Initial meeting to discuss shipborne dunnage discharge and control

with the CFIA, CBSA, Transport Canada, Port Authorities, and shipping industry.

• 2017: Draft shipborne dunnage program (Import Permit (IP) and Preventive

Control Plan (PCP)) presented to the shipping industry.

• 2017: Ongoing discussions with key stakeholders to advance the new permit and

PCP approach.

• 2018: The CFIA presentation to the Shipping Federation of Canada of an update

of the shipborne dunnage discharge program. (Three options were discussed: no

approved treatment method at port/approved treatment method at port and

approved treatment method at port with no segregation.

• 2018: Draft of the revised D-98-08 completed.

• 2019: The CFIA formed an internal national working group to comment on the

draft D-98-08 and on the Operational Guidance document: The scope of the

directive (how to handle non- compliant ISPM 15 ship-born dunnage) needs to be

clarified. Creation of a new working group.

• 2020: Internal CFIA consultation initiated to find solutions to issues, and RMD

issued for consultation.

Page 14 of 15

Appendix 3: references

ISPM No. 05: 2020 revised – Glossary of phytosanitary terms, Rome, FAO

ISPM No. 15: 2019 revised - Regulation of wood packaging material in

international trade, Rome, FAO

D-98-08 (8th edition): Entry Requirements for Wood Packaging Material into

Canada

D-03-08: Phytosanitary Requirements to Prevent the Introduction into and Spread

within Canada of the Emerald Ash Borer, Agrilus planipennis (Fairmaire)

D-95-03: Plant Protection Policy for Marine Vessels Arriving in Canada from

Areas Regulated for Asian Gypsy Moth (Lymantria Dispar, Lymantria Albescens,

Lymantria Postalba, Lymantria Umbrosa

BSLB Risk Mitigation Program

CBSA-CFIA Umbrella Memorandum of Understanding (MOU)

Memorandum D19-1-1 with CBSA

Appendix 4 (next page): Table of management options with

comparative characteristics

Page 15 of 15

(Appendix 4 : table of options) 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