Informative Material 9 - CTU seals
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Informative Material 9 - CTU seals

 1 Introduction

1.1 Many CTU types all have facilities for sealing them and packers and shippers may elect to seal them to protect the cargo against theft. That decision will depend on the mode of transport, the route that it follows and the cargo carried. However, CTUs in international transport should be sealed by the shipper upon completion of the packing. Countries may require that such seals should meet the standard of ISO 17712.

1.2 In this informative material the responsibilities of parties within supply chainfootnote, the types of seal available and the methods of fixing and removal of the seals are discussed.

 2 Responsibilities along the chain of custody

2.1 Cross-cutting responsibilities

2.1.1 There are responsibilities and principles that apply throughout the life cycle of a shipment of goods. The emphasis is on the relationships among parties upon changes in the custody or possession of the CTU. That emphasis does not reduce and should not obscure the fundamental responsibility of the shipper for the safe and secure stuffing and sealing of the CTU. Each party in possession of the CTU has security responsibilities while cargo is entrusted to them, whether at rest at a terminal or while moving between terminals.

2.1.2 Those responsibilities include:

  • protecting the physical goods from tampering, theft, and damage;
  • preventing illegal entry to guard against carriage of illicit goods and migrants;

  • providing appropriate information to government authorities in a timely and accurate manner for security screening purposesfootnote; and

  • protecting the information related to the goods from tampering and unauthorized access. This responsibility applies equally to times before, during and after having custody of the goods.

2.1.3 Seals are an integral part of the chain of custody. The proper grade and application of the seal is addressed below. Where fitted, seals should be inspected by the receiving party at each change of custody for a packed CTU.

2.1.4 Inspecting a seal requires visual check for signs of tampering, comparison of the seal's identification number with the cargo documentation, and noting the inspection in the appropriate documentation. If the seal is missing, or shows signs of tampering, or shows a different identification number than the cargo documentation, then a number of actions are necessary:

2.1.4.1 The consignee should bring the discrepancy to the attention of the carrier and the shipper. The consignee should also note the discrepancy on the cargo documentation and notify Customs or law enforcement agencies, in accordance with national legislation. Where no such notification requirements exist, the consignee should refuse custody of the CTU pending communication with the carrier until such discrepancies can be resolved.

2.1.4.2 Seals may be changed on a CTU for legitimate reasons. Examples include inspections by: an exporting Customs administration to verify compliance with export regulations; by a carrier to ensure safe blocking and bracing of the shipment; by an importing Customs administration to confirm cargo declarations; and by law enforcement officials concerned with other regulatory or criminal issues.

2.1.4.3 If public or private personnel duly authorized remove a seal to inspect the shipment, they should install a replacement that is of the same or higher seal classification as defined in the standard ISO 17712 as the removed seal, and note the particulars of the action, including the new seal number, on the cargo documentation.

2.2 Packing facility

2.2.1 The shipper is responsible for packing and securing the cargo within the CTU, for the accurate and complete description of the cargo and for verifying the mass of the packed CTU. Where required, the shipper is also responsible for affixing the cargo seal immediately upon the conclusion of the packing process, and for preparing documentation for the shipment, including the seal number.

2.2.2 Where required for international transport, the seal should be compliant with the definition of high-security mechanical seals in the standard ISO 17712. The seal should be applied to the CTU in a manner that avoids the vulnerability of the CTU door handle seal location to surreptitious tampering. Among the acceptable ways to do this are alternative seal locations that prevent swivelling of an outer door locking cam or the use of equivalent tamper evident measures, such as cable seals across the door locking bars.

2.2.3 The land transport operator picks up the CTU. The transport operator receives the documentation, inspects the seal and notes the condition on the documentation, and departs with the CTU.

2.3 Intermediate terminal

If the CTU movement is via an intermediate terminal, then the land transport operator transfers custody of the CTU to the terminal operator. The terminal operator receives the documentation and should inspect the seal and note its condition on the documentation. The terminal operator may send an electronic notification of receipt (status report) to other private parties to the shipment. The terminal operator prepares or stages the CTU for its next movement, which could be by road, rail or barge. Similar verification and documentation processes take place upon pickup or departure of the CTU from the intermediate terminal. It is rare that public sector agencies are involved in or informed about intermodal transfers at intermediate terminals.

2.4 Marine terminal

2.4.1 Upon arrival at the loading ocean terminal, the land transport operator transfers custody of the CTU to the terminal operator. The terminal operator receives the documentation and may send an electronic notification of receipt (status report) to other private parties to the shipment. The terminal operator prepares or stages the CTU for loading upon the ocean vessel.

2.4.2 The carrier or the marine terminal as agent for the carrier should inspect the condition of the seal, and note it accordingly; this may be done at the ocean terminal gate or after entry to the terminal but before the CTU is loaded on the ship. Public agencies in the exporting nation review export documentation and undertake necessary export control and provide safety certifications. The Customs administrations that require advance information receive that information, review it, and either approve the CTU for loading (explicitly or tacitly) or issue "do not load" messages for CTUs that cannot be loaded pending further screening, including possible inspection.

2.4.3 For those countries that have export declaration and screening requirements, the carrier should require from the shipper documentation that the shipper has complied with the relevant requirements before loading the cargo for export (the shipper is, however, responsible for compliance with all prevailing documentation and other pertinent export requirements). Where applicable, the ocean carrier should file its manifest information to those importing Customs agencies that require such information. Shipments for which "do-not-load" messages have been issued should not be loaded on board the vessel pending further screening.

2.5 Transhipment terminal

The transhipment terminal operator should inspect the seal between the off–loading and reloading of the CTUs. This requirement may be waived for transhipment terminals which have security plans that conform to the International Ship and Port Facility Security Code (ISPS Code).

2.6 Off-loading marine terminal

2.6.1 The consignee usually arranges for a Customs broker to facilitate clearance of the shipment in the off-loading ocean terminal. Generally, this requires that the cargo owner provide documentation to the broker in advance of arrival.

2.6.2 The ocean carrier may provide advance electronic cargo manifest information to the terminal operator and to the importing Customs administration as required. Customs may select CTUs for different levels of inspection immediately upon off-loading or later. Customs may inspect the condition of the seal and related documentation in addition to the cargo itself. If the CTU is to travel under Customs control to another location for clearance, then Customs at the off-loading terminal should affix a Customs seal to the CTU and note the documentation accordingly.

2.6.3 The consignee or Customs broker pays any duties and taxes due to Customs and arranges the Customs release of the shipment. Upon pickup for departure from the ocean terminal, the land transport operator inspects and notes the condition of the seal, and receives documentation from the terminal operator.

2.7 Intermediate terminal

The processes in intermediate terminals in the importing country are analogous to those in intermediate terminals in exporting countries.

2.8 Unpacking facility

2.8.1 Upon receipt of the CTU, the consignee inspects the seal and notes any discrepancy on the documentation. The consignee unpacks the CTU and verifies the count and condition of the cargo against the documentation.

2.8.2 If there is a shortage, damage, or an overage discrepancy, it is noted for claims or insurance purposes, and the shipment and its documentation are subject to audit and review. If there is an anomaly related to narcotics, contraband, stowaways or suspicious materials, the consignee Customs or another law enforcement agency should be informed.

 3 Seal types

3.1 Mechanical sealsfootnote

3.1.1 Introduction

3.1.1.1 The choice of seal for a specific requirement will depend on many factors. It should be selected after full consideration of the user's performance requirements. The first decision is the appropriate seal classification (indicative, security or high security), followed by a decision on a particular type, make and model.footnote The seal purchaser should require from the seal vendor a certification of the seal's classification in accordance with the standard ISO 17712.

3.1.1.2 In general terms, a low strength indicative seal should be used where only indication of entry is desired. Where a physical barrier is a definitive requirement either a security or high-security seal should be used.

3.1.1.3 All seals should be easy to fit correctly on the item to be sealed and once in situ be easy to check for positive engagement of the locking mechanism(s). Correct handling and fitting of seals is at least equal if not greater in importance than selection of the correct seal. A poorly chosen but correctly fitted seal may provide security; however, a well\chosen but incorrectly fitted seal will provide no security.

3.1.1.4 Security and high-security seals should be sufficiently durable, strong and reliable so as to prevent accidental breakage and early deterioration (due to weather conditions, chemical action, vibration, shock, etc.) in normal use.

3.1.2 Marking

3.1.2.1 Seals should be identified by unique marks (such as a logotype) and unique numbers that are readily legible; markings intended for unique identification of the seal should be considered permanent. All seals should be uniquely numbered and identified. The name or logo of the manufacturer or private label holder should be evident on every seal.

3.1.2.2 Seals meeting the relevant criteria should be marked or stamped in a readily legible way to identify their classification as indicative ("I"), security ("S"), or high-security ("H") seals. Any modification of markings should require obvious irreversible physical, chemical, heat or other damage to or destruction of the seal.

3.1.3 Identification marks

3.1.3.1 Regulatory authorities and private customers may require identifiers that go beyond the requirements of the International Standard, such as in the following cases:

  • seals intended for use on CTUs moving under customs laws should be approved or accepted and individually marked as determined by the relevant customs organization or competent authority;
  • if the seal is to be purchased and used by customs, the seal or fastening, as appropriate, should be marked to show that it is a customs seal by application of unique words or markings designated by the Customs organization in question and a unique identification number;

  • if the seal is to be used by private industry (i.e. a shipper, manufacturer or carrier), it should be clearly and legibly marked and uniquely numbered and identified. It may also be marked with a company name or logo.

3.1.4 Evidence of tampering

Seals may be designed and constructed so that tamper attempts create and leave evidence of that tampering. More specifically, seals may be designed and manufactured to prevent removal or undoing the seal without breaking, or tampering without leaving clear visible evidence, or undetectable reapplication of seals designed for single use. This is a requirement for high-security seals in the standard ISO 17712.

3.1.5 Testing for seal classification

3.1.5.1 There are four physical test procedures, tensile, shear, bending, and impact. The impact procedure is performed twice at different temperatures.

3.1.5.2 The lowest classification for any sample on any test should define the classification for the seal being evaluated. To achieve a given classification, all samples should meet the requirements for that classification in all five tests.footnote

Seal Classification High Security Security Indicative
Test Test Criteria Units 'H' 'S' 'I'
Tensile Load to failure   kN 10.00 2.27 <2.27
Shear Load to failure   kN 3.336 2.224 <2.224
Bending Cycles to failure Flexible Seals   501 251 <251
  Bending moment to failure Rigid Seals Nm 50 22 <22
Impact Impact load Low Temperature J 40.68 27.12 <27.12
  Impact load High Temperature J 40.68 27.12 <27.12
  Drop height Dead blow mass m 1.034 0.691 0.346

3.1.6 Types of mechanical seal

The diagram below show examples of the types of seals, however, it does not provide information regarding the classification of the seals. The seal purchaser should contact the seal vendor for information on the seal's classification in accordance with the standard ISO 17712.

Wire seal Length of wire secured in a loop by some type of seizing device

Wire seals include: crimp wire, fold wire and cup wire seals.

NOTE The seizing device can be plastic or metal and its deformation is one indication of tampering.
Padlock seal locking body with a bail attached Padlock seals include: wire shackle padlock (metal or plastic body), plastic padlock and keyless padlock seals.
NOTE The padlock itself is not an integral part of the CTU.
Strap seal Metal or plastic strap secured in a loop by inserting one end into or through a protected (covered) locking mechanism on the other end
NOTE The seizing device can be plastic or metal and its deformation is one indication of tampering.
Cable seal Cable and a locking mechanism On a one-piece seal, the locking or seizing mechanism is permanently attached to one end of the cable. A two-piece cable seal has a separate locking mechanism which slips onto the cable or prefabricated cable end.
Bolt seal Metal rod, threaded or unthreaded, flexible or rigid, with a formed head, secured with a separate locking mechanism
Cinch seal

Pull–up seal

Indicative seal consisting of a thin strip of material, serrated or non-serrated, with a locking mechanism attached to one end
NOTE The free end is pulled through a hole in the locking mechanism and drawn up to the necessary tightness. Cinch or pull-up type seals can have multiple lock positions. These seals are generally made of synthetic materials such as nylon or plastic. They can resemble, but are significantly different from, simple electrical ties.
Twist seal Steel rod or heavy-gauge wire of various diameters, which is inserted through the locking fixture and twisted around itself by use of a special tool.
Scored seal Metal strip which is scored perpendicular to the length of the strip
NOTE The strip is passed through the locking fixture and bent at the score mark. Removal of the seal requires bending at the score mark which results in breakage of the seal.
Label seal Frangible seal consisting of a paper or plastic backing with adhesive
NOTE The combination of backing and adhesive are chosen to cause the seal to tear when removal is attempted.
Barrier seal Designed to provide a significant barrier to CTU entry
NOTE 1 A barrier seal can enclose a portion of the inner locking rods on a container.
NOTE 2 Barrier seals can be designed to be reusable.
     

3.2 Electronic seals

3.2.1 An electronic sealfootnote is describedfootnote as a read-only, non-reusable freight container seal conforming to the high-security seal defined in ISO 17712 and conforming to ISO 18185 or revision thereof that electronically evidences tampering or intrusion through the container doors.

3.2.2 Electronic seals can communicate either passively or actively with readers and other communication devices. The passive electronic seal relies on a signal from a reader to activate a response from the electronic seal while an active electronic seal is fitted with a battery and transmits a signal that can be interrogated by a reader or a communication device.

Figure 9.1 Electronic Seal

3.3 Other devices

3.3.1 Other devices such as sensors can report on the location of the CTU, condition of the cargo, and whether the CTU has been opened. This can be done in real time, when the CTU passes a communication portal or when the device data is downloaded.

3.3.2 Such devices are usually fitted by shippers on their, or the consignee's, behalf.

3.4 Sealing CTUs

3.4.1 Introduction

3.4.1.1 Closed units used in each of the transport modes have similar securing methods. Box type CTUs with doors at the rear will have either vertically hinged swing doors, sliding, drop down door / ramp, or roller shutter doors.

Figure 9.2 Swing door (Road vehicle)

Figure 9.3 Sliding door (Rail Wagon)

Figure 9.4 Roller Shutter (Swap Body)

3.4.1.2 The different types of CTUs offer different door closing gear, swing doors can be fitted with two or one locking bars per door which can be surface mounted or enclosed in the door structure and the locking handle can be in the bottom quarter of the door or below the doors.

Figure 9.5 Surface mounted handles

Figure 9.6 Roller shutter lock

Figure 9.7 Recessed handled with protruding eyes

3.4.1.3 All the door locking devices work on two principles. A seal can either:

  • be passed through the handle and secured against a fixed item on the CTU (see figures 9.5 and 9.6); or
  • be passed through a fixed eye protruding from the CTU and projecting through the handle (see figure 9.7).

3.4.1.4 Very often the choice for fixing the seal is obvious and where there are two or more handles generally the one that operates the inner lock rod of the right hand door should be sealed. Some handles do not have apertures for seals,footnote while some CTUs will have multiple apertures suitable for seals.

Figure 9.8 Handle without aperture

Figure 9.9 Multiple apertures

3.4.1.5 In figure 9.9 the first choice should be at 'E' or 'C' (inner lock rod right hand door) and for additional security position 'B' (Inner lock rod left hand door). Where the CTU is involved in international transport, a high–security bolt seal fitted at position 'E'footnote provides the most secure solution especially for fitting and removal when a container is on a trailer.

3.4.1.6 The decision whether to seal the CTU and the choice of seal to be used will depend on the shipper, the value of the cargo, the type of CTU and the route. For CTUs that are making a number of stops to unpack one or more packages a clip may be sufficient. Single drop off trips may require an indicative seal. However, CTUs destined for international transport should be sealed with a high-security seal.

3.4.2 Dry bulk CTUs

3.4.2.1 Units designed to carry a dry bulk cargo may have a number of loading and discharge hatches. Depending on the design there may be many loading hatches in the roof and one or more discharge hatches incorporated into the rear doors or in the front wall.

3.4.2.2 Each of the arrowed locations in figure 9.10 will require sealing. Figures 9.12 and 9.13 show discharge hatch sealing points. Figure 9.11 shows an internal slide bolt to a loading hatch in the roof of the CTU that can lock the hatch closed when the CTU is not being used to transport a cargo that requires loading from above.

Figure 9.10 Dry bulk sealing points

Figure 9.11 Roof hatch internal lock

Figure 9.12 Dry bulk discharge hatch (rear)

Figure 9.13 Dry bulk discharge hatch (front)

3.4.3 Tank CTUs

3.4.3.1 Like CTUs for dry bulk cargoes, tank containers and trailers may have multiple openings for loading and discharging.

3.4.3.2 The loading hatches in tank containers are generally secured using a number of wing nuts tightening round the manway hatch. The seal is fitted through a tang fitted to the rim plate and the hatch seal fitting.

Figure 9.14 Manway hatch seal

Figure 9.15 Seal tab

3.4.3.3 Top valves in tank containers may also need to be sealed, some have wires welded to the fixing nuts, while others will be sealed in the closed position.

Figure 9.16 Top valve seal

Figure 9.17 Discharge valve seal

3.4.3.4 The discharge valve on many tanks may have one or two valves plus a closing cap. It is possible to seal all of these, however, the best sealing position is the main butterfly type valve. There the handle is sealed to the adjacent tank.

3.4.4 Open sided units

3.4.4.1 The World Customs Organization defines all sheeted CTUs as open units.

3.4.4.2 There are two basic designs of sheeted attachment:

 "Tautliner" where there are buckles used to tension the straps and the side sheet. Each buckle will have a hole through which the TIR cord will be passed (see figure 9.18); the TIR cord may be secured with a sealing device at each end;

 the second design has eyes that are placed over rings and the TIR cord is passed through the rings (see figure 9.19); this design is most often used with open sided and open top containers.

Figure 9.18 Tautliner clip

Figure 9.19 TIR wire fitting

3.4.4.3 The tautliner buckles do not require the TIR cord to be in place to close the curtain, whereas the ring and eye design requires the cord or else the curtain or top tarpaulin/tilt may easily detach.

3.4.5 Open Top CTUs

Figure 9.20 Open Top CTU

3.4.5.1 In addition to the doors of an open top container the flexible top covering, when required and upon the completion of packing, should be sealed.

3.4.5.2 On arrival of the open top CTU, the packer should check that the top sheet appears to be in good condition with no holes or tears in the material. Patches are permitted so long as there are two visible seams attaching the patch to the sheet and there are no cut edges visible on the patch material and the sheet under the patch.

3.4.5.3 There should be removable or re-locatable roof bows fitted to all the sockets or pins to support the sheet when in place.

3.4.5.4 The TIR Convention requires that sheeted vehicles (including open top containers) be fitted with a strong canvas or plastic-covered or rubberized clothfootnote, of sufficient strength, in good condition and made up in such a way that once the closing devices has been secured, it is impossible to gain access to the load compartment without leaving obvious traces.

3.4.5.5 The sheet should be affixed to the CTU by the following system:

  • .1 metal rings fixed to the CTU;
  • .2 eyelets let into the edge of the sheet; and

  • .3 a fastening passing through the rings above the sheet and visible from the outside for its entire length.footnote

3.4.5.6 The fastening may be of the following specification:

  • .1 steel wire rope of at least 3 mm diameter;
  • .2 ropes of hemp or sisal of at least 8 mm diameter encased in a transparent sheath or un-stretchable plastic; or

  • .3 rope consisting of batches of fibre-optic lines inside a spirally wound steel housing encased in a transparent sheath of un-stretchable plastic; or

  • .4 ropes comprising a textile cord surrounded by at least four strands consisting solely of a steel wire and completely covering the core, under the condition that the ropes (without taking account the transparent sheath, if any) are not less than 3 mm in diameter.

3.4.5.7 In practice most open top containers are supplied with a steel wire rope encased in an un-stretchable plastic sheath.

3.4.5.8 Each type of fastening rope should be in one piece and should have a hard metal end-piece at each end. Each metal end-piece should allow the introduction of the thread or strap of a customs seal (see figure 9.21 below).

Figure 9.21 Fastening rope end-pieces

3.4.5.9 On completion of packing the roof bows should be refitted and the sheet placed over the container making sure that all eyelets in the sheet are placed over a ring fitted on the CTU.

3.4.5.10 The fastening rope should then be passed through every ring on the outside of the sheet starting above the fastening rope retaining bracket or brackets, often found on the right side of the container towards the rear end. The fastening rope should be long enough so that the hard metal end-piece can be brought back to the retaining bracket.

Figure 9.22 Fastening rope threading on Open Top CTU

3.4.5.11 The fastening rope should be tight to prevent edges of the sheet from being lifted.

3.4.5.12 Any additional length of the fastening rope should be restrained so that it cannot be slid out to loosen the securing of the sheet.

3.4.5.13 A seal should be inserted through both hollow rivets of the metal end-pieces. Additional closures may be used to connect the two end–pieces through the round holes.

3.4.6 Fitting seals

3.4.6.1 There have been a number of designs for the handle retainers and catches, but generally there are two generic designs in use illustrated in figures 9.23 and 9.24.

Figure 9.23 2 point seal

Figure 9.24 3 point seal

3.4.6.2 Figure 9.23 shows a design where the lock rod handle is attached to the catch which in turn is attached to the container using a rivet. As the catch has to rotate there is always a small gap between the catch and the retainer.

3.4.6.3 Figure 9.24 has the seal passing through the catch, the handle and a fixed arm on the retainer. This design means that there the seal is directly attached to the retainer and to remove the seal would require the seal or the retainer to be damaged. The type of handle, handle retainer and catch can also affect the security of the doors.

3.4.6.4 Before fitting the seal record the number of the CTU and the number(s) of the seal(s) to be fitted and where each is used (Right hand door inner cam keeper, rear hatch etc.).

3.4.6.5 Push the seal through all elements of the retainer, handle and clip and snap the two halves together.

Figure 9.25 Fitting a bolt seal

3.4.6.6 Once the seal has been fitted, give the bottom a number of sharp tugs and twist the two components to confirm that the seal is fully and properly engaged.

3.4.7 Cutting seals

3.4.7.1 The following four pictures show various seals and the tools normally associated with cutting them. Indicative and security cable seals (figure 9.26) can be generally cut with cable cutters or small bolt cutters. High security cable seals (figure 9.27) and twist seals (figure 9.29) generally require 24 in (600 mm) cable or bolt cutters.

Figure 9.26 Cable seals

Figure 9.27 High–security Cable seals

Figure 9.28 Cutters for cable seal

Figure 9.29 Cutters for twist seal

3.4.7.2 The design of cable cutters shearing edges (figure 9.28) are such that the cable seal strands are captured during the cutting process which prevents strands from becoming separated from the cable.

3.4.7.3 Cable seals use Non Preformed Cable, that frays wildly when cut. Figure 9.30 shows two examples where cable seals have been cut, both have frayed. Cable seals are supplied with the cable permanently attached to one lug, in the case of the picture they are the lower lugs in both examples. The loose end of the cable is passed through the upper lug and crimped closed.

Figure 9.30 Cut cable seals

3.4.7.4 In the top example the cable has been cut correctly, only a small length of cable remains staked (permanently attached) to the seal, whereas the bottom example has been cut too close to the bottom lug.

3.4.7.5 Bolts should be cut as close to the lock body as possible. The left hand bolt in figure 9.31 was cut close to the lock body and is unlikely to present a risk to walkers or vehicles as it is not likely to roll point upwards.

Figure 9.31 Cut bolt seal – stems

Figure 9.32 Cut bolt seals – head

3.4.8 Cutting tools

3.4.8.1 High-security bolt seals (figure 9.33) are generally the hardest to cut and will often require 36 in (900 mm) cutters. 42 in bolt cutters are considered too heavyfootnote for this operation and should not be used.

Figure 9.33 Typical bolt seal

Figure 9.34 Bolt cutters

Figure 9.35 42in bolt cutter

3.4.8.2 Figure 9.36 shows a version of the bolt seal seen previously. It satisfies all the minimum test requirements for the seal to be designated as "High Security". However, the shear strength is very high and cannot normally be cut with a bolt cutter.

Figure 9.36 Rail car bolt seal and breaking tool

3.4.8.3 Bolt cutters are assemblies of four or five linked levers which magnify the force applied at the handles via the fulcrum and into the shearing blades that cuts through the seal shaft. The fulcrum is point A in figure 9.37 with a lever length DL.

Figure 9.37 Bolt cutter schematic

3.4.8.4 The length shown as DL in the diagram below dictates the force that can be applied (Fc). Bolt cutters with 900 mm long handles would need an applied force of 46 N to cut a bolt seal with shear value of 3.336 kN. Cutters with 600 mm long handles would require a force of 70 N to cut the same bolt.

3.4.8.5 As an indication, the force that can be applied by an average fit man "squeezing" the arms inwards is approximately 70 N. Therefore, many people may find attempting to cut a high-security bolt seal with cutters with handles 600 mm or shorter will not be able to cut through solid bolts without excessive force applied at the handles which may result in injury.

3.4.8.6 Operators who open CTUs with high security seals regularly may wish to use a mechanical bolt cutter. Figures 9.38 and 9.39 show the hydraulic cutting head and pump of a high volume bolt cutter. Figure 9.40 shows a battery operated hand held cutter. Similar designs are available.

Figure 9.38 Hydraulic cutting head

Figure 9.39 Hydraulic pump and controller

Figure 9.40 Battery operated bolt cutter

3.4.8.7 When cutting seals, an operator should be standing on a level stable surface and using appropriate personal protective equipment (PPE).


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