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Phytosanitary Regulation Update: International Standard Rolling, Concern Raised about Recycling Issues
Phytosanitary Rules: Report on the latest developments impacting phytosanitary regulations governing wood pallets and wood packaging used in export applications.

By Chaille Brindley
Date Posted: 10/1/2006

    It’s hard to believe that it’s been less than five years since the international phytosanitary standard emerged for solid wood packaging. There were some early bumps along the way as countries began instituting new policies. But things appear to have settled down as the wood packaging industries and governments around the globe have responded to new standards.

    Most major markets around the world have instituted some form of ISPM-15, the voluntary standard for solid wood packaging, including: pallets, crates and dunnage. With a few major exceptions, countries have adopted policies in line with ISPM-15.

    Even though ISPM-15 is well on the way to harmonizing international standards, there are still some issues being tweaked as scientists, government and industry discuss how the standard will change in the future. There are a number of major issues being studied and discussed including: debarking, marking and treated requirements for repaired pallets, ways to reduce the use of methyl bromide, and the different mark designs from country to country.

    The wood packaging industry has responded to the challenges presented by the new phytosanitary regulations, especially in North America and Europe, where companies have massive treatment programs under way. In many cases, this has kept customers from jumping platforms.

    When asked if wood packaging
was causing shipments not to get through, Tyrone Jones, expert specialist with the U.S. Animal & Plant Health Inspection Service (APHIS), said, “I don’t think it is a big issue.” He said, “That is more of a scare tactic to get people
to spend extra money on other types
of packaging. Some shipments are still held up from time to time, but that is because of confusion.”

    Tom Searles, the president of the American Lumber Standard Committee (ALSC), said, “We have not had any formal complaints over the last year under our program. It is definitely working.” 


Debarking Issue –
Is this really necessary?

    The above question appears to be what researchers are attempting to answer. Currently, scientists are examining the issue in a number of countries including the United States. A couple of years ago researchers identified that solid wood packaging treated according to ISPM-15 could be infested after treatment. Bob Haacht, U.S. Department of Agriculture (USDA) research entomologist, said, “Insects readily attacked the material, especially if bark was present.”

    The problem is these tests did not conform to real world settings and practices. Some raised the concern that some countries wanted to spend lots of money and effort going to steps that were not necessary to combat real world phytosanitary risks.

    The USDA is finalizing a study of real world conditions for solid wood packaging entering the country. Haacht has led the research project examining results from six major ports. Insects of quarantine significance were found at only two ports (Long Beach, Calif, and Savannah, Ga.). Much less than 1% of compliant packaging was found to be infested, according to Haacht.

    Haacht added,     “Probably less than 10% of wood packaging had any real bark on it anyway.” The bark issue does not appear to be a great concern for shipments into the United States. Reports from other countries were shared at the latest meeting of the International Forestry Quarantine Research Group, which was recently held in Rome. These reports were not available by the time this article was published. 

    The major proponents of a debarking requirement for all solid wood packaging are the Europeans. Pointing to the increase in phytosanitary risk caused by bark, the European leaders have called for bark-free pallets by 2009.

    Bruce Scholnick, president of the National Wooden Pallet & Container Association (NWPCA), stated, “The underlying purpose therefore, of a bark-free requirement, is to raise the quality of wood pallets coming into Europe in the interest of positive image branding, not phytosanitary protection.”  He added, “The issue is one of balancing technical evidence against economic evidence.”

    The debarking issue is far from over as various interests continue to work toward a solution.


Recycled Components

    One of the emerging areas of concern is what should happen when a properly treated piece of packaging is repaired. The current ISPM-15 regulations give plenty of room for individual interpretation on this issue.

    Some countries are allowing component parts to be replaced and the previous marks left on the package as long as the new material is marked and treated. Some require component parts to be replaced with treated pieces, the old marks are then removed and replaced with new ones.

    Searles of the ALSC, asked, “If you leave all those marks on there, who is responsible? From an enforcement stand point, it becomes harder to police.”

    In the U.S. markets, companies that repair even one piece of lumber on packaging must remove all old marks, retreat the entire packaging and then apply new marks. While this is the most thorough way to ensure compliance, it has caused some backlash from recyclers.

    The big problem is that some recyclers are not in any official government program and are still selling pallets as ISPM-15 compliant. This is not a concern as long as they are not repairing the pallets. But in some cases, recyclers are repairing pallets and are ignoring the proper treatment and marking procedures.

    Searles pointed out that the U.S. approach is the easiest way to ensure compliance and identify the guilty party just in case something goes wrong. He added that any recycler that sells pallets as ISPM-15 compliant when they are not is committing fraud.

    Searles said, “There is nothing we can do to make people comply and join the program.”

    While being part of an official program is voluntary, even those outside of the program are not allowed to sell marked packaging under false pretenses. Fraud is no laughing matter. It can have both civil and criminal implications. The certification agencies have vigorously defended their marks.

    According to Searles, a few cases have already been settled and there are a number of active investigations taking place right now.

    One example involved a facility in New Jersey that was improperly using a stamp bearing the Package Research Laboratories (PRL) and IPPC logos. The government ordered the company to stop infringing on the stamp. Eventually, the company entered into a cash settlement with PRL.

    The federal authorities are responsible to defend the IPPC mark in each host country. When it comes to catching bad actors, APHIS is currently going through the process to change regulations so that it will be easier to stop fraud. And the NWPCA is working on developing uniform, voluntary standards so that the industry can have best practices for repairing ISPM-15 compliant pallets. While this will not stop any company set on violating the standard, it will help educate those companies that are not in compliance due to negligence.


Bug Basics

    Many people don’t realize how many different species of bugs exist. Haacht said that there are thousands if not millions of various species of invasive pests.

    The good news is that you don’t have to be a bug expert to look for the same things that inspectors do.

    Training your staff to identify suspect packaging is one way to keep your customer from getting any problems. This is especially true for recyclers who may be selling used packaging that they did not repair and do not know where it was treated.

    Look for tunnels or bore holes. If there is any bark, you can remove it and look underneath to find any pests. Look for boring dust created when a bug chews through the wood. If you find any live pests, you should retreat the entire packaging.


Emerging TrendsMore Harmonizing Details, User Certification

    Even in places where the standards are supposed to be harmonized, there are some slight differences. For example, Canada and the USA have different practices when it comes to the use of thermocouples and treatment schedules. Jones of APHIS said that both governments are working on harmonizing some things. For example, he mentioned portable kilns.

    John Conway, president of Conway & Robison, pointed out that more packaging users are doing crating at their location. They need to certify packaging for export that is built on site. As a result, these end users are coming into the program instead of just having an outside vendor handle it.

    John also said, “Most general merchandise trade has been covered by the standard. More and more, we are seeing countries of less trade starting to adopt ISPM-15.”

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