The Controlled Goods Program (CGP) is a registration and compliance program that regulates access to Controlled Goods, including International Traffic in Arms Regulations (ITAR) items, in Canada. Under the authorities of the Defence Production Act (DPA) and the Controlled Goods Regulations, the CGP’s mandate is to strengthen Canada’s defense trade controls through the mandatory registration and regulation of businesses and individuals who examine, possess and/or transfer controlled goods.

Violation of the DPA may result in fines to the individual or University ranging from $25,000 to $2,000,000 per day of non-compliance, and/or 10 years imprisonment. EHS has developed Carleton’s Controlled Goods Program to assist individuals at Carleton in understanding the required regulations and procedures.

What are Controlled Goods?

Controlled goods are primarily goods that have military or national security significance; therefore, before importing certain goods into Canada, or before entering into Agreement with research partners, it is important to determine whether or not the goods are also subject to domestic controls and require registration with the CGP. Controlled goods are those that fall into one of the following groups:

Group 2

Munitions List (Wassenaar Arrangement): Automatic weapons, firearms, ammunition, components, projectors, bombs, fighter jets, tanks, missiles, chemicals, explosives, and related equipment and components, etc.

Group 5 (Item 5504)

Strategic Goods: Global navigation satellite systems, ground control stations, and nuclear weapon design and testing equipment

Group 6

Missile Technology Control Regime: Missile technology – rocket systems, unmanned air vehicle systems, propulsion components and equipment

Technology

Not only are the physical goods controlled, but also the technology that supports the goods. In other words, the technology required to develop, produce, or use a controlled good. For example, technical data, such as blueprints, formulas, engineering designs, or models, and technical assistance, such as instructions, training, and working knowledge related to controlled goods, all can be classified as Controlled Goods, and subject to the Regulations.

Registration

Carleton University is registered in good standing with the Controlled Goods Directorate (CGD), however, any individual who has the opportunity to examine, possess, or transfer controlled goods must also be registered.

Designated Officials

Research at Carleton may involve access to or development of, controlled goods. To ensure that research and educational activities that may be subject to the Controlled Goods Regulations, as part of Carleton’s research mandate, are carried out as required, Carleton has appointed two Designated Officials (DOs) to ensure the program’s effective implementation.

Security Assessments

Researchers whose projects will involve controlled goods must undergo a security assessment conducted by the Designated Official before being authorized to work with Controlled Goods, and every five years thereafter. All individuals requiring access to the controlled good (principal investigators, post-doctoral fellows, students, technicians etc…) require this assessment.

It is important to note that registration can take up to 45 days from the time the CGP receives the application. Researchers who intend to receive or produce controlled goods must notify the Designated Official well in advance of the research project.

For information on registration exclusions and exemptions, please click here.

Canadian citizens or permanent residents who normally reside in Canada will have their security assessments completed by the Designated Official. Those who are not Canadian citizens or permanent residents ordinarily resident in Canada will have their security assessments undertaken by the Controlled Goods Directorate after receiving an application submitted on their behalf by the DO.

The Security Assessment process includes the following:

The DO may at their discretion, accept an individual’s Government of Canada security clearance of Secret (Level II) or higher, or a Transport Canada Transportation Security Clearance.If you currently hold a Government of Canada security clearance or Secret (level II) or higher or a Transport Canada transportation security clearance, this clearance may be accepted. Please contact the DO for additional information.

Training

Prior to accessing controlled goods on campus, all individuals who have received a positive security clearance must complete Accessing Controlled Goods Training. For those with a general interest, the Controlled Goods Awareness Training is offered.

Maintaining Controlled Goods

Security Plans

A Security Plan must be developed for each location where controlled goods are stored, accessed or maintained. The Security Plan must outline the security measures to be implemented in order to restrict unauthorized individuals’ access to the controlled goods. The following information must be included:

  • Procedures to control examination, possession and transfer of controlled goods;
  • Identification of individuals responsible for the security of the controlled goods;
  • Procedures for reporting and investigating security breaches;
  • Contents of training programs and security briefings.

The DO will work with the employee/researcher to create and implement a security plan using the template provided. The Security Plan should be reviewed regularly and updated as needed to reflect any changes.

Visitor Briefing

Visitors who have not been exempt from registration must be informed that they will not be allowed to examine, possess, or transfer controlled goods at Carleton.

Visitors who are eligible for a registration exemption from the CGP must receive a security briefing prior to examining controlled goods. This security briefing will:

·        Be included in the site’s security plan and submitted to the visitor in writing;

·        Detail the requirements specific to the controlled goods that the visitor(s) will be examining;

·        Advise the visitor of the access requirements and limits of the visit;

All visitors will be recorded in the site’s Visitor’s Log with the following information:

  • Exemptions documents (applications and certificates)
  • Visitor’s name, contact information and signature
  • Proof of Identity
  • Name of authorized individual who conducted the visitor briefing

Controlled Goods Inventory

Designated Officials are responsible for maintaining records of all controlled goods received, transferred or disposed of. These records must include, as appropriate:

  • Description of any controlled good(s) received, date of receipt and identity of person from whom they were transferred;
  • Description of any controlled goods transferred, date of transfer and identity of the person to whom they were transferred;
  • Description of the manner and date of disposal of the controlled goods.

Breaches

Security breaches are any unauthorized access to controlled goods. All actual or suspected security breaches must be reported to the DO. Any breach of a criminal nature must also be reported to the Department of University Safety (X4444) immediately. The CGP will be notified by the DO using the Security Breach Report Form.

Links

Controlled Goods Directorate (CGD)

Controlled Goods Regulations

Amendments to the Controlled Goods Regulations (July 13, 2016)

Documents

Carleton Controlled Goods Program

Security Breach Report Form

Security Assessment Application

Notice of Security Assessment, Authorization and Acknowledgement

Security Plan Template

Visitor’s Log