Rules and Regulations for Mechanical Conveyance Sealing Devices for Rail Cars and Containers
Conveyance sealing devices or ‘seals’ are an important component in the process of securing cargo during rail transportation. Conveyance Sealing Devices (seals) are designed for simultaneous locking and sealing of rail cars and containers and must comply with the present rules and technical characteristics of seals for rail cars and containers as described in Engineering and Standards Requirements section below.
All seal devices used on shipments to and from Mexico must comply with all applicable domestic and international laws and regulations including but not limited to:
Customs-Trade Partnership Against Terrorism Program (CTPAT)
U. S. Customs and Border Protection
Nuevo Esquema de Empress Certificadas (NEEC)
Free and Secure Trade (FAST)
ISO 17712-2013 Freight Containers – Mechanical Seals
Seals that require special application or removal tools (anything other than standard cable cutters) can be used only when KCSM agrees. If a seal does not require any special tools, an agreement is not necessary. If the commercial agreement between KCS and the client requires a special or specific seal, blueprint and technical specification of this seal should be attached to the commercial agreement.
Rail cars and containers must be sealed with seal devices which are impossible to open and remove without damaging the seal and leaving clear and obvious evidence of tampering. The seal must be applied in such a way that it excludes any possibility of accessing the cargo to steal or to insert contraband without damaging the seal and leaving clear and obvious evidence of tampering.
Some applications will require more than one (1) seal to follow best practices security sealing protocols. If a rail car or container is sealed with several seals (more than one), each must have the same seal number (group of seals with one number) and be clearly stated in the accompanying conveyance documents.
Seals with characteristics or sealing applications which do not correspond with KCSM security (minimum security) regulations may not be used. KCS may request from all manufacturers of seals in use a written statement wherein the manufacturer attests that their seal meets or exceeds the present Engineering and Standards Requirements 1-5 below.
It is the sole responsibility of the shipper to apply appropriate and adequate seal security devices to protect the cargo while in rail transit. KCS and KCSM do not provide or apply seals except in the case of a breach of shipment integrity. KCS and KCSM will not be responsible for loss or shortage of any kind without proof that the shipper applied appropriate and adequate seal security devices. KCS and KCSM Rules Publications provide that as a condition to recovery for loss of or damage to goods caused by a breach of shipment integrity while in transit, the shipper is responsible for documentation of the application of seal type and identification numbers.
Engineering and Standards Requirements of Mechanical Seals for Rail Cars and Containers
1. Function and Range of Application
Seals must be designed for simultaneous locking and sealing of containers and railroad freight cars such as boxcars, tanks including tanks which transport liquefied gases and other liquid chemical products, hoppers, refrigerated cars, auto cover platforms, etc. If these conveyances are to be sealed in accordance with transportation best practices and working regulations, then the seal must restrict or eliminate access to the goods being transported. Seal must be constructed so that any tampering with will leave clear and obvious indication of tampering.
2. Engineering Requirements
Seal must be a one piece cable device.
Seal must be a one-time use device. (Seals by definition are never reusable).
Seal must be certified as an ISO PAS 17712 high security seal, by an independent laboratory with ISO/IEC 17025:2005 certification.
Seal must be inspected and certified by an independent laboratory with ISO/IEC 17025:2005 certification that components, devices, parts, and indicators, which adequately protect the seal from common methods of defeat, are present.
Common Methods of Defeat:
Ratcheting
Picking
Freezing
Changing the cable
Marking: seal must be marked with abbreviations of the seal manufacturer's name, abbreviations or identification (I.D.) of the user’s company name, a sequential seal number, and the last digit of the year of seal production.
Seal must be easy to install by hand. Locking force (with regard to inserting cable and pulling it through the locking mechanism to the seals sealed position) must not be more than 50 N (5 kilogram-force / 11 pound-force).
The force required by personnel to cut the seal cable during the removal process must be no more than 200 N (20 kilogram-force / 45 pounds-force).
All human readable information applied to seals must be easily read from a distance of 1.00 meter in full daylight.
3. Ergonomic Demands
Seals must employ convenient and safe external shapes which won’t injure employee hands while working with them. Seal design must allow comfortable locking and ease of inspection from footlights, stands, attached stairs, the ground, etc., including when in sealed/locked status during travel and check-point review.
4. Reliability/Durability Demands
All seals must preserve their working abilities and meet requirements of all Engineering and Standards Requirements for a full 12 months after their application and 24 months from the date of production, including transportation time by mixed traffic to the Far North regions involving further storage of the seals outside.
Regarding climate factors, seals must withstand a range of temperature conditions between – 60°C (-76°F) + 55°C (131°F), and relative humidity 100% at 25°C, (77°F). Extreme cold and heat can be detrimental to the seal. Seals must withstand these conditions.
Seal Inventory Management Procedures
1. Assign Owner and Responsible Person
It is essential that each shipper assign a specific person that will be responsible for ensuring the proper storage and distribution of Seal security devices. This person must maintain records of seal identification numbers and dates the devices are received and dates they are assigned for use. This person is also responsible to ensure the storage of seals in a secure area.
2. Seal Inventory and Control
Shipper assigned person must ensure that seals received into inventory are checked immediately to ensure that all seals are complete and undamaged. Any seal in suspect packaging or showing any sign of damage should be quarantined for further inspection and / or returned to the seal manufacturer.
All security seals should be stored in a locked facility once they have been received and checked. Access to the facility must be available to only authorized personnel. The assigned person should make distribution of seals as needed and record the ID numbers and dates. Transfer of seal inventory should always be conducted at a box level or greater and single seals should not be transferred from one shipping location to another. Lost or missing seals should be reported immediately.
All seals must be applied according to the specific manufacturer’s application instructions. Records of all seal applications, the transportation vehicle and the date applied must be taken and maintained by the shipper.
The use of a robust software platform for the management of seal applications is highly recommended and KCS / KCSM Security personnel are available to provide additional information or assist with any of these procedures.
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