CBSA, in all fairness.... Just for complete transparency, I co-chair the BCCC steering committee, which is the border commercial consultative committee; I co-chair the CBSA's public outreach committee. For total transparency, I want to put that on the record.
I think CBSA faces a number of different challenges. Probably the biggest challenge that they face from an export perspective is the fact that, quite frankly, 95% of all attention—money, staff, training, infrastructure, anything you can think of at CBSA—is focused on the import side of the house. The remaining 5% is on the export side of the house.
I'll say quite frankly that a lot of CBSA officers are sorely lacking in export training. For example, when we go through major change in export, such as sanctions with Russia—Russia went from being on GMAP and the R in BRIC to suddenly being sanctioned—it takes turnaround time. Often you have the exporters, in many cases SMEs, training customs as to what the sanction says. The officer is stopping it at the border because he just knows that Russia equals bad, and the exporter is saying that the shipment is okay for the following reasons and having to walk CBSA through it.
That sounds like a disparaging remarks against CBSA; in many ways, it's not. Those individuals work very hard. There are a lot of new and changing regulations, and they desperately need training. There needs to be a central focus on how they actually help exporters, especially when it comes to detaining goods.
The final comment I'll make is that they have a definition as to what they consider to be “detained”. I currently have an exporter whose shipment has been held by CBSA for three weeks while they consider whether or not they're going to detain it, because a “detention” is an actual defined term.