Safety And Security Checks For Containers - Syngenta

HSES Code of PracticeSafety and Security Checks for ContainersSafety and Security Checks forContainersCode of Practice 612

HSES Code of PracticeSafety and Security Checks for ContainersContents1. Purpose . 32. Definitions . 33. Scope . 44. Accountabilities and responsibilities . 45. Mandatory principles or standards . 45.1 Legal . 45.2 Implementation requirements. 45.3 Risks and Controls . 55.3.1 “7 Point check” . 55.3.2 Sealing the container using high security seals . 9Appendix 1 . 11Classification: PUBLICPage 2 of 15HSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for Containers1. PurposeThe purpose of this Code of Practice is to define the safety and security checks that are necessary forthe safe and secure transport of Syngenta products in containers. These checks will: Ensure that containers used to transport Syngenta products are fit for purpose and can beloaded safely Ensure compliance with the IMDG code Ensure that containers used to transport Syngenta products are not used to smuggle illegalcontraband Ensure that containers carrying Syngenta products are protected against tampering. Protect Syngenta’s registrations under C-TPAT and similar Approved Economic Operatorschemes. Membership of these schemes gives Syngenta shipments preferential status whenpassing through customs which reduces the administrative burden and helps to ensure areliable supply chain. Enable intervention where the transport does not comply with these regulations or where itputs safety, security or the environment at risk.2. DefinitionsC-TPATCustoms-Trade Partnership against Terrorism. A US program thatseeks to increase security for goods that cross borders when crossingborders whilst facilitating trade. There are similar programs, calledApproved Economic Operator, in other countriesDangerous GoodsGoods that have certain hazards that are defined in the DangerousGoods regulations applicable to the mode of transport e.g. IMDG codeContainerOften known as “Dry boxes” or “Cargo Transport Units (CTUs)”, theseare steel boxes that are designed to allow goods to be transported usingdifferent modes of transport without unloading the goods. Forinternational transport, the dimensions conform to ISO 668 but othersizes are available for use within regions. The most common sizes arethe 20 foot and 40 foot container. Includes refrigerated containers(reefers) as well as containers designed for ambient temperatureHigh Security SealA seal, complying with the current edition of ISO 17712, that is intendedto indicate if the load has been tampered with during its journey.Typically these are metal wire or bolt seals which are designed so thatthey cannot be opened without damaging the seals. This ensures thatany tampering with the cargo is visible.IMDG CodeInternational Maritime Dangerous Goods Code. An internationalagreement that covers the transport of dangerous goods by seaClassification: PUBLICPage 3 of 15HSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for Containers3. Scope1The carriage of Syngenta products, raw materials etc., in containers when the transport is managedby SyngentaAll Syngenta sites, toll manufactures and suppliers who load or unload containers where the transportis managed by SyngentardAll Syngenta personnel who establish or manage contracts with 3 party logistics service providersthat involve the carriage of materials in containers.4. Accountabilities and responsibilitiesSyngenta site managersor toll manufacturersLocations who load containers must establish processes that implementthe following controls: “7 point check” Use of high security sealsLocations who unload containers must establish processes thatimplement the following control: ProcurementLogistics procurementUse of high security sealsEnsure that suppliers who load containers that will be carried under aSyngenta contract establish processes that implement the followingcontrols: “7 point check” Use of high security sealsEnsure that Logistics Service Providers know that they must report sealrelated discrepancies or anomalies to Syngenta5. Mandatory principles or standards5.1 Legal2,3Containers intended to carry Syngenta goods must be inspected before they are loaded . Containers3must be sealed with high security seals5.2 Implementation requirementsAll locations who load containers must establish documented procedures to implement the followingcontrols: 7 point check Use of high security seals1This includes products, raw materials etc. that are not classified as Dangerous Goods and those that are classified asDangerous Goods.2IMDG code section 7.3.33Security Criteria for C-TPAT Foreign Manufacturers. Similar requirements exist in other “Approved Economic Operator” (AEO)schemesClassification: PUBLICPage 4 of 15HSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for ContainersAll locations who unload containers must establish documented procedures to implement the followingcontrol: Use of high security seals5.3 Risks and ControlsTypical risks associated with the use of Containers are: Cargo is tampered with after it has been loaded into the container Inadequate security procedures results in loss of C-TPAT or AEO membership. This mayresult in increased administrative burdens (financial guarantees etc.) and potential delays toSyngenta shipments due to increased inspection when passing through customs. Floor collapses while loading the container, risking injury to the fork lift truck operator Cargo is damaged by water getting into the container Cargo is damaged by contact with the container Container is used to smuggle illegal materialsThese risks are controlled by: Carrying out a 7 point check before loading the container (see 5.3.1) Sealing the container using high security seals (see 5.3.2)Detailed requirements for each of these key controls are defined in the following sections.5.3.1 “7 Point check”Key Principle:Before a Container is loaded, carry out a systematic check to ensure that the container is fit for loadingand that there are no modifications to the container that could be used to smuggle contraband. This isknown as the “7 point check”.3. Right side6. Ceiling/Roof5. Front Wall4. Leftside1. Outside/UndercarriageClassification: PUBLICPage 5 of 157. Floor (inside)2. Inside/outsidedoorsHSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for ContainersRequirements1. Outside/undercarriage Check that support beams are undamaged Solid plates should not cover the beams2. Inside/outside doors Check that locking bars and mechanisms areintact, in good working order, are not damagedand cannot be easily removed or tampered with. Check especially for loose bolts, plates and repairsor different color bonding materials Check that doors seal completely when closed(stand inside and look for light around the door) Check that the ribs on the inside of each door arevisible: solid plates should not cover standardcontainer cavities.Classification: PUBLICPage 6 of 15HSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for Containers3. & 4. Right/Left sides Check for unusual repairs to structural beams Check that there are no holes or cracks in thewalls. Check that repairs to the inside of the containerare visible on the outside (repairs visible only onthe inside could indicate a hidden compartment) Use a tool to tap the side walls. Check for ahollow, metal sound. Check that there are no sharp edges orprotrusions that could damage the cargo5. Front wall Check that blocks and vents are visible. Check that there are no holes or cracks in the wall. Use a tool to tap the side walls. Check for ahollow, metal sound. Check that the dimensions of the container arecorrect (if dimensions are less than expected, thiscould indicate a hidden compartment). If in doubt,use a range finder, measuring tape or string tomeasure them. Check that there are no sharp edges orprotrusions that could damage the cargo.6. Ceiling/roof Check for unusual repairs to structural beams Check that there are no holes or cracks in thewalls. Check that repairs to the inside of the containerare visible on the outside (repairs visible only onthe inside could indicate a hidden compartment) Use a tool to tap the side walls. Check for ahollow, metal sound.Classification: PUBLICPage 7 of 15HSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for Containers7. Floor Check for any unusual repairs Check that floors are flat – there should be nosteps in the floor Check that the floor is not damaged. There shouldbe no protrusions, such as nails, that coulddamage the cargo Check that the height of the container is correct (ifheight is less than expected, this could indicate ahidden compartment). If in doubt, use a rangefinder, measuring tape or string to measure them.ComplianceAll containers must comply with the “InternationalConvention for Safe Containers” (CSC). Check that the next test date, marked on the CSCplate, has not been exceededOR Check that the CSC plate contains registrationinformation for “Approved Continuous ExaminationProgram (ACEP)General Check that the inside of the container is dry andfree from condensation: condensation on the wallsmay stop Ty-Gard from sticking correctly. Largeamounts of condensation may leak from thecontainer and give the impression that the cargo isleaking. Check that all labels from the previous load havebeen removed. If any are present, they must beremoved Check that the inside of the container is clean, freefrom cargo residues and has no persistent odorClassification: PUBLICPage 8 of 15HSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for ContainersRecordsRecords of the 7 point check must be kept for at least12 months (or longer if local laws require)The checklist contained in annex I of this CoP isrecommended5.3.2 Sealing the container using high security sealsKey Principle:All containers must be sealed with high security seals. Their design and individual serial numbersmeans that any attempt to remove the seal will be apparent to the receiving locationRequirements Facilities must seal all loaded containers with highsecurity seals. These seals must comply with thecurrent edition of ISO 17712 Seals must only be attached by a designatedperson Access to seals must be strictly controlled andmust be issued in random order. Do not use sealsin consecutive number order as this is asecurity weakness. People who intend totamper with our goods may observe our traffic,and if they observe a numbering pattern thismay help them to obtain a substitute seal. Seals must be stored in a secure location (lockedcabinet, safe etc.) prior to useA typical high security bolt seal A log must be maintained in order to account for allseals under the control of the loading site. Periodicinventories of seals and the seal use log must beconducted to ensure that all seals are accountedfor All Bills of Lading, dangerous goods declarationsor other transport documents (including electronicdata transmissions) must be complete and includeall seal numbers used for the container.Classification: PUBLICPage 9 of 15HSES CoP 612 v2 1/1/2014

HSES Code of PracticeSafety and Security Checks for Containers Facilities receiving loaded contains must checkthat the serial numbers of seals attached to thecontainer match the serial numbers listed on theshipping documents. Any discrepancy must be rectified before thecontainer is accepted. Logistics service providers must report anydiscrepancies or anomalies related to seal integrityto SyngentaClassification: PUBLICPage 10 of 15HSES CoP 612 v2 1/1/2014