On August 28, 2015, the Canada Border Services Agency (“CBSA”) posted Customs Notice 15-032 “Contingency Plan for System Outages”. It is a short customs notice that primarily contains a link to the CBSA’s “System Outage Contingency Plan“. The System Outage Contingency Plan details requirements and procedures for Trade Chain Partners and all impacted parties during 15 types of CBSA system outages (defined as a temporary suspension of operation to the electronic system) that impede normal reporting procedures to the CBSA. The System Outage Contingency Plan is an alternative to the general procedures for the reporting of goods, in bond movements, release of goods and final accounting. This contingency plan is applicable only in circumstances where CBSA system outages have occurred.
Some examples of when the System Outage Contingency Plan applies are:
- Full CBSA system outage (when all CBSA systems; EDI, eManifest portal and CBSA internal systems are not functioning);
- Delays in processing;
- Full EDI outage;
- EDI inbound system outage (the CBSA is not able to receive any new inbound EDI messages from clients);
- EDI outbound system outage (the CBSA is not able to receive any new outbound EDI messages from clients);
- Full eManifest portal outage;
- eManifest portal inbound system outage (the CBSA is not receiving information submitted through the eManifest portal);
- eManifst portal outbound system outage (the CBSA is not able to post responses in the eManifest portal);
- Direct Connect (DC) or VAN outage (affects those clients that utilize the impacted Direct Connect or VAN as their electronic communication method);
- Customs Internet Gateway (CIG) outage ( affects those clients that utilizes the CIG as their electronic communication method);
- When the CBSA is upgrading computer systems;
- Blackouts (an infrastructure problem e.g. flood, earthquake, windstorm, terrorist attack that is affecting the entire country);
- Brownouts (an infrastructure problem e.g. hydro, communication lines etc. that is affecting one or multiple locations within Canada);
- Client planned outage (A client or service provider’s system outage that has been pre-scheduled for maintenance purposes that will prevent the transmission of customs information to and receipt of customs information from the CBSA); and
- Client unplanned outage (A client or service provider’s system outage that is preventing the transmission of customs information to and/or receipt of customs information from the CBSA).
What surprises me is that the CBSA does not include temporary closures of a single border crossing location due to wildfires (a current scenario is Western Canada).
The System Outage Contingency Plan provides general instructions of what interested parties should do in the case of an outage.