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Public Comments Identify Key Concerns for National Wood Packaging Rule
Overview of public testimony given in various hearings about the development of a national treatment and certification rule for wood packaging material.

By Chaille Brindley
Date Posted: 12/1/2009

            Seeking to obtain input from a wide variety of voices around the country, the U.S. Animal Plant & Health Inspection Service (APHIS) recently conducted a number of meetings on its plan to implement a national treatment and certification rule for solid wood packaging material. APHIS has yet to finalize its rule. However, the agency has suggested that implementing ISPM-15, the international voluntary standard, on a domestic basis may be the best initial step to stop the spread of wood pests associated with the movement of wood packaging, firewood and other wood products.                                          

            The following is an excerpt of comments made at various APHIS meetings held in Grand Rapids, Mich.; Houston, Texas; and Portland, Ore. The Pallet Enterprise already covered testimony from the first hearing in an article that ran in the October 2009 issue of the magazine.


APHIS Provides Domestic Challenge Snapshot

            Paul Chaloux, the national program manager for emergency and domestic programs for APHIS, spoke about some of the reasons for the domestic concerns. He said, “Border stations run by the California Department of Food and Agriculture reported intercepting pests of concern on pallets and other wood packaging materials 24 times between 2001 and 2007. Some of the pests intercepted domestically at these California agriculture inspection stations included gypsy moths, Ips bark beetles, eastern tent caterpillars that I mentioned before, and others.

            “I’d like to emphasize that these shipments were domestic shipments. They originated from 13 other states and were headed to various destinations within California. Interstate shipments are

subject to restrictions and requirements if they are a regulated article under one or more of our current pest specific quarantines and regulations. This                                                                   creates a mosaic of requirements that the wood packing material industry and its customers have to be aware of and comply with. And there’s a real opportunity for confusion as a result because the requirements can vary from one pest specific regulation and quarantine to another, and there is overlap in some cases between these quarantined areas. For instance, much of the area under quarantine for gypsy moth is also under quarantine for emerald ash borer (EAB).”


Landfill and Deforestation Concerns

        The first two speakers at the Michigan hearing voiced concern over the impact caused by the use of wood packaging. Ryan Thompson of Gladstone, Mich. said that he was a hunter and outdoorsman who is alarmed by the devastation caused by the EAB. Thompson said, “Invasive pests like this are extremely destructive and pose a huge threat to many aspects of Michigan’s economy especially our outdoors and recreation industries.” Thompson called for regulations on wood packaging and for increased exploration of packaging other than wood.

            One bone of contention voiced at the Michigan meeting was the inaccurate figures sited by some on pallets going into landfills. For example, Eric Hill of Troy, Mich. said, “The United States alone uses nearly two billion wood pallets annually, and about two-thirds of these are one-time use, and that two-thirds is sent straight to a landfill, and it makes up about five percent of the total contribution to solid waste landfills every year which ends up being six million tons of wood pallets per year. We’re tearing down valuable hardwoods to harvest the timber for wood pallets, and these same wood pallets serve as a vehicle for exotic pest invasions.”

            John Swenby of Paltech headquartered in Illinois responded, “I’m a pallet recycler here in the Midwest covering about six states…We have less than two-tenths of a percent of all the materials that go through my plants end up in landfill. Most of it is ground, reused in some way, shape or form, so very little material goes into landfill. So there’s a lot of misleading and inconsistent information that’s being thrown out that needs to be clarified in this direction.”

            Terry Rodino with Recycled New Pallet in Elkhart, Ind. agreed that pallets were not a major landfill problem in today’s market. He said, “I, too don’t know of anybody that takes any wood to the landfills. I mean, in today’s market you need to recycle everything you possibly can. So there’s the wood chips, there’s boiler fuel, there’s animal bedding.  It is not cost-effective for anybody in the pallet recycling business to pay to go to the landfill. So I think that’s kind of a false thing that we’ve heard this morning that landfills are being filled up due to the wood pallet industry.”

            Bruce Scholnick of the National Wooden Pallet & Container Association (NWPCA) said, “A decade old survey saying that about 20% of wood pallets end up in landfills was probably correct in 1995, but it isn’t true today. And as we’ve heard, new technologies and the innovative business practices have allowed the repurposing of goods that a decade ago would have ended up on landfill.”


 Phase-In Period

            One of the practical issues debated in the hearings was the implementation schedule and any phase-in period that would be allowed before a domestic treatment requirement would be enforced. Attitudes ranged from a long phase-in period to as short a timeframe as possible. A big consideration is how much heating capacity exists in localities and the willingness of various companies to work together. Hear what various voices had to say.

             Asher Tourison of Acme Pallet in northern Michigan said, “We would hope you just heat treat everything, make the playing field level, and have a relatively short implementation time.  Everyone that I know that’s a major player in this industry already has the capacity. We have a couple heat treat chambers and we’re not using them as much as we would like.”

            Lee Jimerson with the Collins Companies, which operates sawmills across the country, said that a phase-in period would have to be much longer if enforcement were to take place at the sawmill level. He said, “Talking about a phase-in period — that gets very complicated.  In 5 to 10 years, probably as a minimum.”

            Jimerson pointed to the permitting processes, funding and other challenges that would be more difficult at the sawmill level.  Looking at pallets, he said, “The pallet industry is very competitive. So, look at the cost per thousand to heat-treat, anywhere from maybe as low as $35 per thousand board-feet, up to around $85 per thousand board-feet. With lumber costs, some dipping as low as $75 per thousand,  you’ve got about a 30% and 100% increase in the cost of that lumber going into those pallets if it all has to be heat-treated.”

            One of the consistent arguments is that there already exists plenty of capacity to treat most pallets in many areas of the country. Jimerson responded, “You say, if heat-treatment or methyl bromide was required, what proportion of the WPM producers would need to add additional kilns or heat-treating facilities?  I would say it’s close to 100% because most of the wood products industry has the capacity to dry about 60% of what they make, because they sell a lot of green lumber to the pallet industry.  So, we will have to ramp up to meet that.”

            Casey Dean, director of western operations for Timber Products Inspection, a major certification agency for ISPM-15 in the United States, said, “Once a standard is adopted, we favor a 6-month to 1-year phase-in period.”

            Eric Miller of Sawmiller, Inc. in Haydenville, Ohio, said that the pallet industry doesn’t need a long phase-in period. He said, “We did not get very much notice to implement ISPM-15 originally and yet the industry pulled it off.”

            Eric suggested that a long phase-in

period would perpetuate unnecessarily the economic disadvantage that companies in quarantine states are experiencing.  Taking on capacity concerns, Eric said, “I travel amongst a circle of friendly competitors throughout the Midwest…Most people’s opinion is that they are only using 10-15% of their heat treating capacity currently...In our case we could go from a half a million a year by multiple shifting and other methods to — we could probably easily do a million and a half to two million a year. And we do a lot of custom heat treating for many of our competitors around us.”

            LeRoi Cochran with IFCO Systems, the nation’s largest pallet recycler, said, “IFCO only uses about 43% of our current heat treat capacity. What’s interesting to note about that is even if we used 100% of our capacity that would represent less than 5% of our volume. So capacity is somewhat of a misleading indicator.” 

            Bill Blakeslee, owner of Billet Products Company in Sherwood, Ore., said, “I think one of the things that needs to be really looked at is all of the small companies — and I consider myself to be small to medium — but there are a lot of small companies that get involved in new pallet manufacturing, as well as recycling that don’t have the financial ability to comply at the level that we’re at already. And there certainly needs to be some thought given to enforcement, looking into those companies that operate, let’s say, under the radar. Because that’s a big issue, and it’s a big source of problems.”


Determining Effective Treatment Focus

            Probably the most important issue being debated is deciding what the critical components are to really combat the domestic spread of invasive pests.

            Jim Labonte, a taxonomic and surveying entomologist with the Oregon Department of Agriculture, said, “I have inspected thousands of pallets from various sources, crates, raw lumber and other green wood. I can assure you that pallets and other crating and similar wood products that are composed of green lumber are an exceedingly high-risk pathway.”

            Pointing to a specific example, Labonte said, “I think a good example of that are pallets that came in to an electronics company in Beaverton. These were so green that they were absolutely covered with fungi, in fact some of these fungi were sprouting, which tells you how green this was. There we detected an exotic Ambrosia Beetle that, to this day, has not been identified.”

            CHEP, the nation’s largest pallet pooler, appears to be laying the groundwork for some type of exemption for pallets that are already in distribution. Candice Herndon, director of environmental and regulatory affairs with CHEP, commented that all lumber used in the manufacture and repair of CHEP pallets is either kiln dried heat treated in accordance with ISPM-15 or voluntarily kiln dried.

            Candice said, “The kiln drying process we use exceeds the conditions mandated for heat treatment of regulated wood packaging material by ISPM-15…Based on our experience in designing what we believe are current best practices and best mitigation strategy for managed pallet pooling operations, our chief recommendation to APHIS is to set the bar high in terms of performance but provide the flexibility to encourage different sides of the industry to find the best means of compliance within their own systems. We believe APHIS is committed to this point of view.”

            Many participants voiced concern that pallets are only a small part of the real cause behind the domestic spread of exotic pests.

            Jim Storey of Storeyline Connections said, “I would commend to you a broader vision of this than just looking at pallets. I am old enough to have lived in this state (Michigan) my entire life and to remember the Dutch elm disease which decimated some very beautiful leafy streets in many, many Michigan communities. And here we are about 30 years later and we’re just now seeing the re-growth take place from the decimation from that insect that destroyed the forest then.”

             LeRoi Cochran with IFCO Systems, said, “The launch of the international program was specifically predicated upon a significant increase in pest interceptions, and at this point that same increase has not been determined or presented for domestic wood packaging.”

            IFCO Systems has not opposed a domestic requirement outright. However, its management has called for additional research to determine the exact impact of wood packaging on the domestic spread of exotic pests before enacting sweeping ISPM-15 compliance requirements.  

            Cochran suggested that APHIS should focus first on higher risk industries such as firewood, nursery stock, live plants, etc. He is concerned that focusing efforts on wood packaging will “consume valuable time and resources without materially affecting the spread of the pests.”

            Taking issue with differences voiced between white wood and private pooled pallets, Cochran said, “We contend that there are more similarities than differences between those models.” Cochran further explained that the real difference exists between new pallets and pooled/recycled pallets and wood packaging. This goes back to what Jim Labonte of the Oregon Department of Agriculture said about green wood being the major problem.

            Some pallet producers in the West favored an approach that involved sawmills not just pallet and packaging producers. Greg Vipond, vice president of Girard Wood Products in Puyallup, Wash. and the current president of the Western Pallet Association, said, “Pallet manufacturers in the West do not cut down, de-bark, or mill trees like many do back in the mid-west and back east. The product we purchase comes to us in the form of 2x4 or 2x6, et cetera, and they come from sawmills. Lumber is processed and shipped from the mills all over the country.

            “As you consider the possibility of regulating our industry, I ask that you first look at the source of the material, the sawmills, and really think what would be the most effective way to approach this.

            “If you eliminate the possible spread of insects at the start, and would also dramatically reduce the energy costs of shipping green versus dry lumber all over the country, and eliminate the huge cost of supplying each pallet company in the country with kilns.  Most sawmills already have kilns to process this lumber.”


Why Pallets?

            Patrick Sherry of NEPA Pallet and Container, in Snohomish, Wash. said, “We do not believe we are as high-risk as some other products, such as the firewood, and the root stock issue.  We feel that we are well down the list, and that we would prefer to eliminate ourselves from the list.  And that is why we are here in mass, as the pallet industry.”

            Sherry added, “Nursery stock carried the EAB into Maryland, which now has a county under federal quarantine for that pest. It is my understanding that firewood has been responsible for most of the spread. So, why should we not, as an industry, fight against quarantine regulations?  The answer is, that as an industry, we are vitally concerned with the preservation of our raw materials.”

            Representing the Western Pallet Association, Greg Vipond underscored the breath of the potential problem and the need for universal treatment. He said, “Seventy-three percent of the wood packaging companies do business in states that have wood-related non-native invasive species. There are 3,079 which we know that do business in states that have infestation that are under quarantine, either by county, state or federal regulation.”

            Dan Hilburn an administrator with the Oregon Department of Agriculture, said, “Literally, we’re playing Russian Roulette by moving green wood around the world.  And it’s not just internationally that it’s a problem, it’s also domestically. Because things are introduced to other parts of the country, and then they can come to Oregon.”

            Explaining the need for regulations, Hilburn said, “Regulations need to be across the board, they need to be national, and they need to be simple to understand and enforce.  A complicated systems approach with lots of inspections or compliance agreements just isn’t going to do it, because there’s so much softwood packing material, and so many types of green wood that are moving around; we’d better come up with a simple system that levels the playing field, and that works, and that’s enforceable.  It would be very easy to design a system that would overwhelm the resources of the regulatory agencies, and we just couldn’t monitor it.”  


Emerging Technology

            Dan Collins with Woodsave Ltd. talked about a new mobile heat treating system that he developed for both wood packaging and firewood. This new mobile system shows promise for those who need to treat pallets but don’t want to invest in a permanent facility or need spot treatments in various locations.             Niels Jorgensen of kiln-direct.com said that his company has developed a kiln for treating firewood, which has been his best product launch ever. He said the ability to heat treat pallets using biomass as fuel is improving the environmental footprint of the process.

            Jorgensen also said that the economics of heat treating are improving. He said, “Due to our work with the private industry we actually have brought to market a heat treating kiln for as little as $20,000.  That is not a re-used container that’s rebuilt. This is a brand new kiln…That might help explain how these smaller operators can actually heat treat and become competitive in their environment.”


Existing Quarantine Areas

            Areas that have experienced serious pest outbreaks appear to have a different attitude in some cases than areas without any major problems.

            Tom Barnes with the Michigan Association of Timbermen, said “We’re looking for an even playing field. We are quarantined. We have a difficulty shipping these materials out. If we can get a level playing field across the United States that helps our position in wood pallet manufacturing.”

            Bruce Scholnick of the NWPCA said, “Michigan is the only state where hearings are being held that has a federal quarantine on wood packaging in effect. Michigan pallet manufacturers and recyclers along with those in Ohio, Illinois, and Indiana are at a competitive disadvantage as a result of the quarantine.”

            Terry Grant from G&H Wood Products in N.Y. said, “What happens in our area is a lot of the mills now are cutting ash so we’re getting an overload of ash...We’re universally heat treating all our ash so every pallet at our expense is going out whether they require heat treatment or not. You know, the trees are important to us, it’s our source of raw materials.”  


Recycled Pallets

            Ryan Stearns with Atlas Products, LLC. of Nampa, Idaho, pointed out concerns shared by many in the industry about the current rules for interpreting the ISPM-15 standard in the United States. Existing U.S. rules require a pallet where a board is replaced to be completely re-treated and re-marked. Some other countries allow a minimal amount of repairs with HT dried lumber as long as certain restrictions are followed.

            Stearns said, “That rule was not created by APHIS, but rather employed by the American Lumber Standard Committee, which manages the heat treating program. That requirement exceeds ISPM-15 guidelines, and needs to be modified.  It is the biggest complaint in the recycling industry. The ISPM-15 domestic and international standard needs to allow U.S. manufacturers to comply with the same rules governing all other IPPC signatory countries.”  


Private Citizens Speak Out

            From environmental to property concerns, a number of private citizens shared their concerns about wood packaging, treatment procedures and the impact of forest products in general. While people in the pallet and lumber industries may not agree with these people, you need to know what they are saying.

            Joe Davis, a Houston area landowner and fire chief, said, “There are a lot of dangerous pests that attach themselves to wood packaging materials and severely damage precious forests and natural areas…Forest fires are completely more intense when you have damaged trees and rotten wood and things like that that have been affected by pests.”

            Kristine Lewis, a conservationist and environmental activist from Milwaukee, Ore., said, “As an invasive species enters a local ecosystem, the effects are felt by local flora, similar species that feed off of the same flora and fauna, and predators to that species, cascading all the way up the food chain. As it cascades up, the entire ecosystem is thrown off balance.”

            More excerpts of the public testimony can be viewed online at www.palletenterprise.com. Look for the extended coverage in the December issue of the Pallet Enterprise digital edition.

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