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Multi-Regional Internal Audit of Firearms Importations
Corporate Audit and Evaluation Branch
December 2004
- EXECUTIVE SUMMARY
- INTRODUCTION
- FOCUS OF THE AUDIT
- FINDINGS, RECOMMENDATIONS AND ACTION PLANS
- CONCLUSION
- AUDIT TEAM
This audit was started, with the fieldwork and review completed, before the announcement of the division of the Canada Customs and Revenue Agency into the Canada Revenue Agency (CRA) and the Canada Border Services Agency (CBSA). CRA agreed to complete the audit and prepare the report for clearance by the CBSA.
EXECUTIVE SUMMARY
Customs is responsible for protecting the health of Canadians, their safety, economic prosperity and sovereignty. In fulfilling its responsibilities to Canadians, Customs endeavours to strike a balance between enforcement activities and facilitating the movement of goods and people across Canada's international boundaries. Changes to the Criminal Code and the Firearms Act, introduced in May 2003, have increased Canada Customs' role in managing the importation of firearms.
Objective: The objective of the audit was to provide assurance to senior management in the regions audited that the processing of firearms importations into Canada complied with legislative and regulatory provisions. The audit was conducted from July to September 2003 in the Pacific, Prairie and Southern Ontario regions.
Conclusion: Firearms importations were generally processed in accordance with laws and regulations. However, implementation of new or revised procedures was not always timely, indicating a need for more effective communication. There were also indications of a need for additional or refresher training on the safe handling and storage of firearms. Although there was some monitoring of firearms procedures, there was little evidence of a regular, formal, documented monitoring process.
Action Plan: Corrective measures have been taken to improve communication between the Firearms Coordinators and the operational staff. Refresher training on the safe handling and storage of firearms has either been provided or will be provided as soon as possible. The Headquarters Firearms Project Team will work with regional management to put in place a monitoring process to ensure accurate information is collected. In addition, the Project Team will undertake a review to monitor program changes once legislation is implemented.
INTRODUCTION
Customs is responsible for protecting the health, safety, economic prosperity and sovereignty of Canadians. In fulfilling its responsibilities to Canadians, Customs endeavours to strike a balance between enforcement activities and facilitating the movement of goods and people across Canada's international boundaries.
Changes to the Criminal Code and the Firearms Act, introduced in May 2003, have increased Canada Customs' role in managing the importation of firearms. Management in the Pacific, Prairie, and Southern Ontario regions wanted to assess the effectiveness of the firearms importation process in their regions, in light of the legislative changes.
FOCUS OF THE AUDIT
The objective of the audit was to provide assurance to senior management in the regions audited that the processing of firearms importations into Canada complied with legislative and regulatory provisions.
The audit focused on the degree of compliance with legislation and the supporting processes in place. It included the importation of restricted and non-restricted firearms and the current measures to prevent the importation of prohibited firearms.
The audit was conducted in the Pacific, Prairie, and Southern Ontario regions from July to September 2003. The scope of the audit did not cover Customs Headquarters' responsibilities for firearms importations.
FINDINGS, RECOMMENDATIONS AND ACTION PLANS
Compliance with Policy, Procedures, Laws and Regulations
Firearms Coordinators were in place in each of the regions that participated in the audit. They were responsible for communicating information associated with firearms importations, from branch and regional levels, to field operations. In addition, the coordinator acted as a liaison between field operations and Customs at Headquarters for dealing with procedural and legislative issues that surfaced at the operational level. Each Firearms Coordinator was also responsible for duties other than firearms; thus firearms were sometimes not their sole priority.
In all regions visited, firearms importations were usually processed in accordance with laws and regulations. However, the level of knowledge on firearms procedures varied among the staff in the regional work sites. The widespread lack of timely implementation of the New Procedures for Processing Non-Resident Firearm Declarations As of November 1, 2002, was of notable concern.
The failure or delay in implementing the new procedures, which were intended to clarify the non-resident firearms importation process and reduce processing times, created the risk that resource savings would not be realized. It showed a need for more effective communication of procedures from the Firearms Coordinators to the staff at the operational level.
Recommendation
The roles and responsibilities of the Firearms Coordinators should be reviewed in each of the regions audited to ensure that communication and implementation of procedures on the importation, detention and release of firearms are efficient and effective, and that the Regional Coordinator position successfully supports operations.
Action Plan
The Pacific Regional Firearms Coordinator will work with the Headquarters Firearms Project Officers to ensure that information forwarded to the districts is useable and referenced to existing policies.
District management in the Prairie Region is responsible for day-to-day management of operations, including ensuring all documentation is current and staff are aware of procedural changes. Local management will ensure that procedural information remains current and is available to all officers.
In Southern Ontario, the responsible Firearms Coordinator will communicate regularly with management site contacts. Information will flow from the Firearms Coordinator through the site contact, to the relevant staff members. The Firearms Coordinator will conduct follow-up communication with the site contact to ascertain the level of comprehension and compliance.
Headquarters will forward the role statement for the Regional Firearms Coordinators to each coordinator as a reminder of the importance of their role in the delivery of the Canadian Firearms Program.
Corrective measures have been taken to improve the communication process from the Firearms Coordinators to the operational level.
Safeguarding Assets and Safety of Employees
With respect to the safeguarding of assets, procedures were in place to ensure firearms and public monies were safeguarded and controlled at each work site, although formal documented monitoring mechanisms had not always been established.
With respect to the safety of employees, Customs had been proactive in ensuring that customs officers received and passed a course on the safe handling and storage of firearms. Generally, this was done through the Canadian Firearms Safety Course. Each customs office had a complement of seasoned officers available to provide assistance and guidance to less experienced personnel. Staff who had not received training were not authorized to handle firearms.
During site visits, we were made aware of, or identified, issues pertaining to the safety of employees when handling or storing firearms. The most prevalent concern, applicable in all regions, was a need for additional or refresher firearms training.
Recommendation
Management should solicit information from Customs Inspectors regarding the aspects of firearms training they need, and provide refresher courses to satisfy those needs.
Action Plan
The issue of refresher firearms training has been referred to district management and the regional training coordinator in the Pacific Region. The Prairie Region has already provided an existing firearms safety refresher course to all districts. The Southern Ontario Region has started to provide refresher training, and will continue to monitor and address the need for firearms training.
Management from each region has made a commitment to implement the recommended improvements to safety or to monitor the firearms safe-handling processes, to ensure employee safety.
Systems were in place for dealing with client complaints at each customs office. The first step in the complaint resolution process, known to staff at all levels, was to refer the client to the responsible superintendent. There were few documented client complaints. In most cases, the issue was resolved in person with the client. Senior management in each region had been proactive in addressing the client service issues associated with firearms importations.
Monitoring, which encompasses supervising, observing and testing activities, and reporting progress to responsible individuals, is a key component of the quality management process. The audit found that superintendents were conducting monitoring through observation, review of bank deposits, cash audits and review of JUS 909 (Non-resident declaration) forms. There was, however, little evidence of a regular, formal, documented monitoring process pertaining specifically to firearms importations.
In view of the changes made to firearms legislation and the potential negative ramifications associated with unauthorized importations, management would benefit from greater assurance that firearms importations complied with the legislation and supporting regulations. Increasing formal monitoring would be effective in obtaining that assurance.
Recommendation
Senior regional management should determine roles and responsibilities specific to monitoring the Firearms Program and establish a mechanism to address operational deficiencies.
Action Plan
The Pacific Region has made a commitment to work with the Firearms Project Team and other groups at Headquarters to develop a monitoring program.
According to the Prairie Region, firearms under Customs control are already subject to regular monitoring. Firearms importation statistics are maintained, the Firearms Project Team in Headquarters conducts periodic audits of JUS 909 Non-resident declaration forms, and Headquarters compares the number of forms with the deposited payments.
In the Southern Ontario Region, the Firearms Coordinator and/or the site contacts will conduct periodic reviews of firearms storage, safeguarding and documentation.
The Headquarters Firearms Project Team will work with regional management to put a monitoring process in place to ensure the collection of accurate information. In addition, the Project Team will undertake a review to monitor program changes once legislation expanding the program to include Canadian residents and commercial firearms businesses is implemented.
CONCLUSION
There were no major issues pertaining to processing the importation of firearms in the Pacific, Prairie, and Southern Ontario Regions. Firearms importations were generally processed in accordance with laws and regulations. However, the level of knowledge on firearms procedures varied among the staff in the regional work sites. The implementation of new or revised procedures for firearms processing was not always timely, indicating a need for more effective communication. Also, there were indications of a need for additional or refresher training on safe handling and storage of firearms.
Although some firearms procedures were monitored through observation, review of bank deposits, cash audits, and review of forms, there was little evidence of a regular, formal, documented monitoring process.
AUDIT TEAM
Dianne Readman, Regional Internal Audit Manager
Stacy Allison, Project Leader
Rob Maier, Internal Auditor (Pacific Region)
Thelma Weisser, Internal Auditor (Pacific Region)
Rachel Raymond, Internal Auditor (Prairie Region)
Mark Costello, Internal Auditor (Southern Ontario Region)
Donna Lockyer, Internal Auditor (Southern Ontario Region)
