Page 1 of 15 
  
  
  
  
  
RMD 20 -02 
1st Version  
  
Shipborne D unnage 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 pes t 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 t he principles, terminology , and guidelines provided in the IPPC 
standards for pest risk analysis .  
 
 
Table of content s 
 
Executive Summary  ................................ ................................ ................................ ........  3 
Purpose  ................................ ................................ ................................ ...........................  3 
Scope  ................................ ................................ ................................ ..............................  4 
Definitions  ................................ ................................ ................................ ......................  4 
Background  ................................ ................................ ................................ .....................  4 
Pest Risk Assessment Sum mary  ................................ ................................ ......................  5 
Risk Management Considerations ................................ ................................ ....................  6 
Pest Risk Management Options  ................................ ................................ .......................  7 
Risk M anagement Option 1: Discharge of dunnage in Canada is not permitted  ............  8 
Risk Management Option 2: Dunnage can be discharged based on m andatory 
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 t he requirements 
for shipborne dunnage. This directive is  based on the International Standard for 
Phytosanitary Measure s (ISPM ) 15: Regulation of wood packaging material in 
international trade . The current directive D-98-08 permits the discharge of dunnage  that 
complies with IS PM 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 wit h 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 -appro ved 
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 unifor m 
across Canada.  
 
The current Risk Management Document outlines four options for managing shipb orne 
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 manag ing the  
 
Page 4 of 15 
 risks and consistent ly applying  phytosanitary requirements for shipborne dunnage 
coming into Canada.    
 
 
Scope  
 
This RMD pertai ns to CFIA’s management of ship borne 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 (G lossary 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 “ship borne dunnage ”, which is 
dunnage used to brace, secure and su pport 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 workpl ace safety hazard.  N on-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 ha ve been m any 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 m emorandum 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 phytosanitar y perspective . On the 
other hand , if it was a llowed to be discharged  the same way as compliant 
dunnage , then it  was considered as an incentive to use non -compliant material .  
Therefore , an adequate e nforcement strategy was not achieved . 
 
These issues, c ombined 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 As h Borer, 
Brown Spruce Longhor n Beetle, Asian Longhorn ed 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 in troduction a nd spread of 
quarantine pests.  
 
In 2020, the CFIA initiated  an updat e of the pest risk assessment, with specific questions 
on high and low risk peri ods 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 i n wood 
packaging material marked with the ISPM 15 stamp and these insects are genera lly 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 implement ing a low risk period whe n 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 revi ew of this 
concept in the coming years with a list of chosen forest pests and fungal pathogens.  
Meanwhile, th e suggested interim approach is described in the Risk Management 
Considerations.  
 
The CFIA  also consider ed 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 complianc e and non -compliant dunnage report s.  
 
Low risk periods  
Low risk periods  as describe d 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 
Bore r, Asian Gypsy Moth and Brown Spruce Longhorn Beetle in their respective 
directive s has been considered . 
 
The l ow 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 p hytosanitary 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 unsaf e 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 n on-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 
dispos al of dunnage  (see Pest Risk Assessment summary above) instead of requesting that 
it “remain s 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 enforce ment  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 
(AMP s).  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 represent ative 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 l owest  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 request s 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% inspect ion 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, d unnage 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 plan s. Segregation of comp liant 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, storag e, transport , and disposal of dunnage.  
 
The dunnage would be required to be stored  in a way that prevent s the escape of pests 
and disposed of on site or transported safely for d isposal 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 enforce ment action  accordingly.  
 
Advantages : 
 Address industry requests to discharge dunnage during low risk period ;  
 
Page 10 of 15 
  Theoretically l owest 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 plan s.  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 re quired to provide notice  prior to entry in to 
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 w ould 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:  
 Promote s ISPM 15;  
 Address industry requests to discharge and reuse dunnage;  
 Data collection on dunnage would be possible;  
 Allow s discharge of dunnage all year long;  
 Safely deals with non -compliant dunnage all year long ; 
 Audit -based approach that would requir e less resource s than option 2 as well 
as not being schedule -dependent;  
 Restricted r euse of dunnage  would be permitted  during  the low risk period ; 
 Curre nt ad hoc agreements would need minimal ada ptation 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 chang es 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 a doption of ISPM 15 and corresponding harmonization of D -98-08. 
• 2003 -2008: The CFIA authorized se gregation of non-compliant ship borne 
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 ship borne dunnage discharge and control 
with the CFIA, CBSA, T ransport Canada , Port Authorities, and shipping industry.  
• 2017: Draft ship borne dunnage program ( Import P ermit  (IP) and P reventive 
Control Plan (P CP)) 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 ship borne 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 O perational 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 in itiated 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 trad e, 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 Eme rald 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 discha rge 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 c overage of remote ports   
 Very easy  Expected to be  difficult  Easy  Easy