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Seaports – First Line of Defense for Phytosanitary Risk
Seaports – First Line of Defense: This is the second part of a two-article series on seaports and global shipping; it covers the role and procedures used in U.S. seaports for monitoring wood packaging regulation compliance.

By Matthew Harrison
Date Posted: 2/1/2007

   Over the last few years increased phytosanitary concern and oversight of wood packaging material (WPM) has irrevocably changed the face of international shipping. While obtaining properly treated and marked packaging is keeping shippers busy, domestic seaports are reporting being relatively unaffected by the overall process.

   Created by the International Plant Protection Convention, the ISPM-15 guidelines strive to secure global trade and economic stability by preventing harmful biological agents and invasive species from spreading around the globe. January’s issue of Pallet Enterprise explained the recent havoc caused in the Midwest by the Emerald Ash Borer (EAB) as just one example of how detrimental foreign pests can be to the normal flow of business.

   Seaports have become the first line of defense for keeping the homeland secure against foreign pests. The two federal agencies most involved with the international shipping process are the U.S. Department of Agriculture (USDA) and the Customs and Border Patrol (CBP).



   The USDA’s role in international shipping deals primarily with the outbound goods. “We help give you the regulations for the commodity you’re trying to ship,” said USDA expert certification specialist Joy Brown. “We tell you the foreign country’s requirements.”

   Brown also noted that not every country has accepted the ISPM-15 guidelines yet, and that it’s up to the company that actually ships the goods as to whether or not they should comply. Once an exporting company’s non-compliance is verified, it is highly unlikely that the importing company will pursue further contracts.

   “The new guidelines are the responsibility of the shipper offering the cargo for transport,” said Linda Ford of the Virginia Port Authority. “The terminal has no responsibility for inspecting pre-palletized cargo for compliance.”

   Ford added that ports are responsible for inspecting wood packaging material used for dunnage, such as crates to protect unusually large or inconveniently shaped objects.

   USDA Animal and Plant Health Inspection Service (APHIS) Public Affairs Specialist Melissa O’Dell said that dunnage is currently receiving the most attention. Since dunnage is rarely uniform in size or shape, ports pay special attention to verify that it satisfies ISPM-15 standards.

   As for outbound shipments, “we have not had any issues with non-compliance because we have no dog in the fight other than export dunnage,” she remarked candidly.

   “If [the exporting company] has pallets that aren’t properly marked that gets into a country, and they see that it’s not properly marked, then it’s the country’s choice,” Brown said. “They can either hold the shipment or receive its entry, it’s up to them.”

   Even though the USDA ensures compliance for international shipping regulations, the American Lumber Standards Committee (ALSC) and their partner accrediting agencies send agents in the field to physically inspect pallets and verify that ISPM treatment markings are used properly.

   The stateside implementation of the ISPM-15s have been “pretty seamless,” according to ALSC President Tom Searles. He explained that there were anxieties about initializing the program. Searles thought the transition phase would move faster than pallet companies, or even the ALSC, for that matter. The fast pace of business proved him wrong, though. Currently, seventeen accrediting agencies are permitted to license the ISPM treatment markings on pallets and other wood packaging materials for 3600 companies nationwide.

   “We have a standard checklist done on each inspection,” said Bob Browder, Director of the Southern Pine Inspection Bureau accrediting agency. “Each inspection includes a documentation review to verify that the heat treatment records are available and contain the required information and that they are maintaining their documentation for at least one year.”

   Occasionally, pallet companies improperly mark their pallets for international trade. If an unmarked or improperly marked unit load arrives at the destination country, the receiving country has the right to hold the goods for further inspection or immediately export them back to the U.S. So far, few such occurrences have taken place.

   According to APHIS, there have been documented instances of WPMs failing to meet ISPM-15 standards in the EU and South America. All of those instances were resolved in-country without requiring a return shipment to the U.S.

   On the other hand, some legitimately treated and marked pallets have been held in foreign ports accidentally. “This situation has happened when a specific country first starts participating in the program,” O’Dell noted, but the instances decrease quickly as the ports become more familiar with the regulations. “All participating countries are doing well at regulating imports,” she said.



   Inbound shipments are screened by U.S. CBP with field agents making the final decision of what goods can come into the country at a port of entry. The CBP has successfully intercepted serious threats to the agricultural industry, such as the citrus canker that has the potential to devastate the entire U.S. citrus crop. The agency completes nearly five million cargo inspections per year.

   Port of Houston’s Trade and Development Manager Ricardo Arias admitted that the CBP screening process can be cumbersome, but it’s all in the name of security.

   Non-intrusive inspections (NII) techniques are used to verify that a container’s contents match the vessel’s manifest. CBP agents use radiation detectors, radiation isotope identifiers, large scale X-ray machines, and gamma-ray imaging systems.

   Gamma-ray imaging systems are most commonly employed to view the contents of a container without having to physically breech the seal. They look like an irregularly shaped little truck with a cab mounted atop the rear end. From there, a CBP officer examines an image based on objects gamma rays can penetrate as containers are driven underneath.

   Once CBP officers are satisfied with what they see, the container is released and it’s cleared for pick-up. According to Arias, CBP only handles pallets when the results of a gamma-ray scan are unsatisfactory. Due to law enforcement security, data concerning the number of pallets gamma ray-scanned versus those that are physically inspected is not available.

   In some cases, CBP officers might see something highly suspicious, however most inspections result from misiden­tification of goods on a ship’s manifest. In other cases, customs officials have found pallets reinforced with untreated lumber, which still requires the withholding or exportation of the goods.

   The enforcement of WPM requirements is a separate process from the normal course of pest interdiction duties conducted by CBP Agriculture Specialists.

   Countries and shippers seem to be serious about ISPM conformance. “The phased in enforcement process combined with education and outreach by both CBP and the trade has encouraged compliance with this USDA regulation,” said Byrd.


Nobody Likes a Faker

   So by now you’re thinking that it might be pretty easy to throw one over on border patrol agents around the world. But any company that does this takes a great risk. The pallet company may lose customers and even worse could be the subject of a civil and/or criminal investigation. Obviously, any shipper sending mis-marked packaging faces delays, treatment, deportation or even the destruction of a load. This is especially true if a shipment is found to be infested with a quarantine pest.

   Searles of the ALSC added that a pallet company accused of forging the approved ISPM label will be charged both civilly by the accrediting agency and criminally by the USDA. “Their whole business is based on the integrity of that mark.”

   Accrediting companies and the federal government are cracking down on label fraud. Searles said that all of the companies caught doing this have been either prosecuted or terminated.

   International trade is keeping people more honest than not. “People are very compliant,” Arias concluded optimistically. For the most part, these are very professional people. If you’re selling goods in another country, you’re not interested in making money off one batch; you want to do that on a regular basis.”

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