6.2. Container Specifications 50
6.3 Risks in Empty Containers All types of container units pose various kinds of concealment risk levels. Always remember that concealment risks are directly proportional to spaces found in different types of containers. 6.3.1 Dry Cargo Container Dry cargo containers are the most commonly used and have potential concealment spaces. Always pay particular attention to the locking equipment of the doors. 51
6.3.2 Reefer Container The 7 - Point inspection method should be applied on reefer containers - temperature controlled (25 degrees to 25 degrees Celsius) with the difference that there is a compressor and hatches on the front wall of the container which could be easily used to conceal illicit goods. The compressors must be found sealed usually by lead seals. REFEER CONTAINERS 52
6.3.3 Open Top Container Open top containers must be properly sealed at the top and doors. Also check that there are no joints in the metal wire sealing the canvas top. These types of containers are generally used for the transportation of glass, marble slabs and similar materials which are loaded or unloaded from the top. 53
6.3.4 Flat Rack Container Flat rack containers (used for the transport of heavy plant machinery) pose very potential risks in wide platform compartment at the bottom which is an optimal concealment space for smuggling of goods, e.g. cigarettes. 54
6.3.5 Tank Container Tank containers used for the transportation of gases or chemicals possess concealment risks in the tank itself and in the frame that supports the structure. Always check the number of valves. 55
7. Risk Warning Labels 7.1. Risk Labels are enlarged placards in diamond form with mini- mum size 25cm x 25cm which should be affixed to the exterior surfaces of a Cargo Transport Unit (CTU) to provide a warning that the contents of the unit are dangerous cargoes and present risks. These risk labels are technically known as International Maritime Dangerous Goods (IMDG). Square labels with an orange background are found on the product itself. These labels always indicate a potential danger and must never be ignored. 56
7.2 European Hazard Symbols Square labels with an orange background are found on the products 57
Diamond shaped risk labels are found affixed on the sides and doors of the container. 58
7.3 Radioactive Symbols There are three basic labels which are used to identify radioactive materials • Radioactive White - I • Radioactive Yellow - II • Radioactive Yellow - III All of the labels bear the distinctive tri-blade symbol which is universal for the identification of radioactivity or radiation. By looking at a package's label, one can determine the hazards associated with it without the aid of a radiation monitoring device. Radioactive White I Label - nearly no radiation. The maximum allowable radioactivity is 0.5 millirem/hr on the package service Radioactive White II Label - Low radiation levels. The maximum allowable radioactivity is 50 millirem/hr on the package surface, and one millirem/hr at three feet from the package. Radioactive White III Label - Higher levels of radiation. Maximum allowable radioactivity is 200 millirem/hr on the package surface, and 10 millierem/ hr at three feet from the package. Required for fissile Class III materials or large quantity shipments of any radiation level 59
8. Customs Approval & CSC Plate FIG. 1 FIG. 2 60
8.1 Customs Approval Plate (FIG. 1) The temporary admission facilities are granted only to containers approved by the competent authority of the country of manufacture. The purpose of the approval is to certify that the container is constructed and equipped in such a manner that: • No goods can be removed rom, or introduced into its sealed part without leaving visible traces of tampering or without breaking the customs seals; • It contains no concealed spaces where goods could be hidden; • All spaces capable of holding goods are readily accessible for customs inspection; • Customs seals can be simply and effectively affixed to it; • The beneficiary of the approval shall affix the approval plate described hereafter to the approved container before its use for transport of goods under customs seals. 61
8.2 International Convention for Save Containers Plate - CSC Safety Approval (FIG. 2) The International Convention for Safe Containers established criteria for the testing, inspection, approval, maintenance and control of containers. It is applicable to new and existing containers used in international transport, except to containers designed for air transport. The term ’international transport’ means transport between points of departure and destination situated in the territory of two countries to at least one which the CSC applies. The CSC also applies when part of a transport operation between two countries takes places in the territory of a country to which the CSC applies. The plate must be permanently affixed in a clearly visible place adjacent to any other approval plate issued for official purposes. Position of the CSC Plate 62
9. Physical Examination 9.1. The physical examination of containers and their cargo should always be carried out in a systematic method through the following under mentioned procedure: i. Check the container number, marks and foreign seals against the Bill of Lading submitted. The local seal should be checked against the gate pass. Check the seals and ensure that these are intact. It is recommended to physically examine the seals before these are broken. ii. Note if there are any risk or fumigation labels affixed on the container and what safety procedures should be taken into consideration before opening. iii. Before opening the Releasing Office is advised to perform an external check around the container paying particular attention to the locking mechanism on the doors. iv. The apply the necessary Health & Safety measures. v at this point, the container is ready to be opened and physically examination according to the outcome of the documentation analysis. vi. During the physical control it is recommended to record all relevant details on a note book which will be helpful when responding the Risk Analysis result or drafting the feedback report on the outcome of the release. vii. In some circumstance a digital camera may also be useful to take photos of infringed consignments. 63
9.2 Reporting Techniques The notebook should contain a complete record of the examination in which the following details should be included: Date Time Place Container number Foreign & local seal numbers Description of goods Condition of container, noting visible signs of damage Trader or his representative present during release Releasing officer/s Every relevant detail that happens during the physical inspection 9.3 Final Checks i. Ensure that the container is totally empty before closing the doors (complete check) ii. Check if there are any visible signs of new paint, welding, panels or uneven floor inside the empty container that may attract your attention iii. The broken seal/s should be retrieved from their place and taken iv. Be completely satisfied with the documentary and physical control adopted during the release v. Do not leave any pending or unsettled issues related to the release of goods 64
9.4 Risk Analysis Report Following the release of goods, the Inspection Officer has to complete the inspection report relevant to the assigned declaration. Before submitting the report the Inspection Officer must input the Inspection Conclusion and Overall Remarks accordingly. When selecting A4 – Minor Discrepancies the system will automatically enable the declaration for amendments in the discrepancies tab. All data boxes may be amended except for the VAT number of the Declarant and Importer. Underneath each change, Inspection Officer can write Control remarks for every amendment. The Perform Risk button will run again the amended entry through risk analysis. The latest risk analysis is for information purposes only. 65
9.5 What details must be included in the Risk Analysis Report? During the release of a particular shipment, the number of packages has tallied with the invoices submitted but it was noted that the container was not completely loaded and had some available space near the doors. The container was not opened or unloaded at importer’s premises. Please indicate the place of unloading The foreign seal did not tally with that listed on the Bill of Lading Some new welding, panels or paint was noticed on the outer side of the container The seals or the lock mechanism on the doors of the container were found tempered with. New bolts were fixed to the hinges The container was half empty but the quantities tallied as declared Incorrect amount of the supplementary units (Box 41) on the declaration Shortages or items found in excess The container number did not tally with the Bill of Lading submitted Answer to the remarks issued by the Risk Management by stating the findings and what remedial action was taken. 66
9.6 Settlement of the Suspense Account After responding to the Risk Analysis Result, declaration is to be STRICTLY settled in the suspense account at the Cash Office Make sure that the declaration is eventually completed and status is at ‘Goods are released’ The suspense account is not applicable in the following cases: No Duty, VAT or other taxes are due Subject to relief of Duty, VAT and other taxes Warehousing regime Deferred Payment - If a declaration is covered by the deferred payment, no suspense payment receipt is issued and the declaration should be at status ‘Goods are released’. 67
9.7 Settlement of Post Entries and Feedback Reports Post-entries, Risk Information Sheets (RIS) and Feedback Reports must be settled at the earliest possible but not later than within three (3) working days and forwarded to the officer in charge of the Containers and Groupage Unit. If an infringement is detected, always refer to the Officer in Charge in order to report the case and follow the instructions given. The Economic Operator must also be informed of any discrepancy or infringement found during the physical inspection. Any person shall have the right to appeal against any decision taken by the customs authorities relating to the application of the customs legislation which concerns him or her directly and individually. Samples collected for classification purposes or for any other reason together with the relevant documentation must be submitted to the BTIU as immediate as possible by the releasing officer. 68
10. Sampling of Agricultural Products 10.1 Legislation Customs Code - EU Regulation 2913/92 Customs Code Implementing Provisions - EU Regulation 2454/93 The sampling procedure is basically divided into seven stages: 1. The right to sample 2. The right of the trader to be present during the sampling procedure 3. Drawing and dividing the samples 4. Additional information for the laboratory 5. Completion of application for analysis and station records 6. Packing, security and transport 7. Receiving the sampling results 8. Security and disposal of samples in storage Sample/s should be drawn for analysis when: • It is mandatory • Sampling is justifiable because of the potential revenue loss or licensing implications • You are unable, after fully completing the examination, to determine the classification of the goods 69
10.2 Declarant or his representative It is important that the trader or his representative is present during the sampling procedure. The trader or his representative must also sign the SAMPLES TAKEN (CAP01) form in which the trader declared that the samples taken are truly representative of the whole consignment. The Samples Taken Form must be correctly filled by Customs officers and by the trader or representative. A copy of this form is given to the trader while the original is sent together with the sample to the Customs Analyst. 10.3 Drawing and Dividing Sample It is your responsibility t take a representative sample of the whole product. How you physically take a sample depends on the kind of products being examined. What is vitally important is that the sample is representative of the whole consignment. In practice, this means: • Taking samples from boxes/cartons you have already selected for examination • When divided, all parts of the sample must be representative of the product and of each other • Ensuring the sample is sufficient for analysis • Your procedure must not alter the sample in any way that might affect the analysis • Storage and transport must not alter the sample in any significant way such as contamination, loss or deterioration Samples which are near the container walls may be exposed to a higher temperature than samples from the inner parts of the consignments. Samples should always be taken from the inner bulk of the consignment where the conditions are more constant. 70
Samples must be sufficient for analysis. Before any sampling is carried out, the best thing to do is to speak directly to our Customs Analyst in order to get some advice on the sampling procedure and amounts to be taken. 10.4 Dividing the Sample 1. The first sample (A) is to be referred to the lab for analysis 2. The second sample (B) should be retained at Customs as a reserve sample 3. The third sample (C) should be kept at importer’s premises 10.5 Laboratory Requirements It is helpful if any available technical information (certificate of analysis sheets, product descriptions, safety data sheets, etc.) is also forwarded along with the sample and test note. Completion of application for analysis It is important that this form indicates precisely what the sample is, why it has been taken and what analysis and/or advice is required. 71
10.6 Packaging It is important that samples are adequately packaged/packed (air-tight/ double wrapped were appropriate), sealed etc. accompanied with the relevant paperwork, correctly labelled to ensure that they are delivered in perfect condition and without risk of damage. Labelling Clearly label all packages on the top of each parcel. This allows for faster identification and minimal handling. Rejected Samples/Procedures If samples arriving at the laboratory are not in a satisfactory condition, the are rejected and returned back to the sampling officer. 10.7 Receiving the results After analysis, the relevant Customs Section is informed and the result is to be recorded. Disputed results If the importer or his representative wished to challenge the results of the analysis, the trader will need to write directly to the Comptroller of Customs. Customs will then send the duplicate sample (the ‘B’ sample) for analysis, preferably to a laboratory which is accredited to perform the required test. If the trader is still not satisfied with the results, he may send the sample which he has in his possession (the ‘C’ sample) to another lab for analysis. However, all this process must be performed under Customs supervision and the laboratory chosen must be acceptable to Customs. The cost of analysis of the ‘B’ and ‘C’ sample must be borne by the trader. For export refunds, if a request is received contesting the results of any analysis, these are under the discretion of MRRA and any queries must be directed to them. 72
10.8 Security and disposal of samples in storage at Customs Offices Security • Maintain a record of samples going in and out of storage • Retain the station sample in secure storage facilities • The storage facilities must be subject to close monitoring to ensure samples are not tampered with Storage • Samples must not be disposed of until the results of the analysis are confirmed • Failed samples must remain in ling-term storage until offence or recovery action has been completed. Normally, samples are returned to the trader; however, if trader does not want them back, the samples are to be destroyed • The goods should be rendered to a state where they are clearly inedible and dumped in accordance with local arrangements • Paint or dye should be applied to contaminate the goods - this is especially useful for meat • Disposal should be fully documented and witnessed to protect the officers and Department from allegations of impropriety • Details of the disposal, whether on site or returned to the declarant should be noted in the Sample Register. 73
11. Security & Safety (1) Container Inspection 7-Point Inspection Check on an Empty Container 74
INTERNAL INSPECTIONN11.1 Outside and Undercarriage • Inspect the undercarriage and the outside of container. Use a mirror to access hard-to-see areas • Undercarriage support beams should be visible; solid plates should not cover the beams 11.2 Left and Right Side • Inspect the internal and external surfaces, including structural beams • Use a small hammer to tap side walls listen and feel for hollow, metal sound • All walls, ceiling, and doors should be made of metal. Any repairs on the inside must be also visible on the outside • Blocks and vents (9 holes) inside the container must be visible and appropriately spaced 75
11.3 Doors - Outside and Inside • Ensure locking mechanisms (hasps, hinges, handles, bars, bolts, etc.) are secure and in good working order • There should be ribs on the interior sides of each door; solid plates should not cover standard interior door cavities 11.3.1 Doors - External Check • Look for different colour bonding material, loose bolts, new and worn metals on the same device • When closed the doors should seals completely • Check the types of bolts and their condition CONTAINER EXTERNAL CHECK 11.3.2 Doors - Internal Check • Check for unusual putty placed on the inside of the doors 76
11.4 Front Wall • Inspect front wall, making sure vents and blocks are visible and appropriately spaced • Measure the interior and exterior of the container with a tape measure, range finder or a string. Container should be exact to specifications • Look for different wall colours and blocks that are too close to the vents. Use a small hammer to tap front wall - you should hear a hollow, metal sound 11.5 Ceiling & Roof • Inspect external roof and internal ceiling, including structural beams. Use a small hammer to tap - you should hear a metal, hollow sound. If unable to see roof of container, use ladder or a mir- ror attached to the pole • False compartments are common in ceilings, beams, floors, doors, and the front wall • Any weld repairs on the inside must be also be visible on the outside. Watch for unusual welding or repair on support beams 77
11.6 Interior Floor • Inspect floor for unusual repairs • The floor should be flat and of one height • Measure floor to ceiling with a tape measure, range finder or piece of wood. Container should be exact to specifications • There should be no steps or raised platforms inside the container 78
11. Security & Safety (2) Seals and Door Mechanism All different types of container seals are manufactured to be secure. Some seals have more security standards than others but always remember that seals could be easily tampered with. 12.1 Some of the different types of seals: i. Bolt seals iii. Cable Seals ii. Tin seals iv. Hand-cuffs seals v. Plastic seals vi. Lead seals 79
12.2 Documentation Controls Prior to the physical inspection of the seals always check the foreign seal number against the bill of lading submitted. 80
12.3 Methods of tampering Bolt seals not properly clipped in place False seal numbers Seal numbers which are not aligned Different forms of numbering Erased seal numbers Faulty mechanism in bolt pin Screwing mechanism inside the bolt seals Deep scratches on seals Tin or plastic seals may also be glues If one of the centre bars is cut off, the hand-cuffs seal could be easily removed and put back in place 12.4 Physical check on bolt seals • Bolt seals must be checked by holding the lower part and exert strong downward forces to ensure that it is firmly locked • Then hold the metal pin and turn the lower part in the right and left directions for several times. It must move freely in both directions* • Finally hold firmly the lower part of the seal and try to turn the pin in an anti-clockwise direction (screwing mechanism) * anti-spin seals do not move freely in both directions 81
12.5 Door mechanism • If after the necessary checking, the seals are found to be intact the controls are not over yet! • The Customs Officer must check the door mechanism before opening the container and ensure that there are no signs of possible tampering 12.6 What are the main risks related to door mechanism? • The metal sheet at the centre • The middle bar at the right hand side • The locking mechanism at the right bottom • All bolts and metal accessories related to door handles • Different types of bolts • New and old bolts 82
12.7 High security bolt seals Specifications ISO/PAS 17712 “H” certificated C-TPAT compliant Galvanised low carbon steel, wrapped with ABS anti-spin construction to prevent the locked seal from being rotated out 8mm diameter steel perch, hexagon shape bottle 18mm perch head diameter compliant with ISO/DIS 17712.3 The height of male and female is 86mm and 34mm separately Special security features Company logo or name Sequential numbers Bar code Available in various colours 83
12.8 High Security Cable Seals Specifications: ISO/PAS 17712 “H” certificated, C-TPAT compliant 3.5mm diameter cable with standard cable length 35cm (14 inches). Other lengths available Lock head dimensions: 26mm x 26mm x 7.5mm Aluminium alloy, free of plastic Locking mechanisms: Zinc extrusion Braided aircraft cable construction Petroleum & sunlight resistant Pull tight locking mechanism, easy to use Special security features Company logo or name Sequential numbers Bar code Available in various colours 84
12.9 Summary There are many risks associated with the seals and door mechanism of an ISO ocean container 1. Check the seal number against the Bill of Lading or manifest document 2. The check physically the seal/s following the appropriate methods 3. Check the door mechanism cautiously 4. Pay particular attention to the middle bar at the right hand side 5. Always look for different or new paint, weld or panels on the doors 6. Old and new bolts or different types of bolts may be a relevant risk indicator 7. Scratched paint on certain parts (centre metal sheet) 8. The bolt’s end on the inner side of the doors must be properly covered with putty 85
13. Share Your Information 13.1 Discuss the outcome of a particular release with your colleagues at work because sharing of information is highly recommended An effective communication network between employees accelerates the performance levels of the Department 86
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