NWPCA Urging World Import Standard
Import Standards: Plant health regulators are on a mission to develop phytosanitary rules to prevent insects from being transported internationally in wooden packaging.
By Bob Peters
Date Posted: 12/1/2000
National and international phytosanitary requirements are created to reduce the likelihood that the shipment of plants and plant material will introduce exotic pests into an ecosystem. This has sometimes been called "bio-invasion." The word phytosanitary literally means "clean plant."
Over the past 10 years, the Uruguay Round of trade negotiations has developed an Agreement on Sanitary and Phytosanitary Measures (SPS Agreement). The chief aim, in the phytosanitary section, is to ensure that any phytosanitary measures — which act as non-tariff barriers to trade — can be technically justified. This has led individual country National Plant Protection Organizations worldwide to develop a global structure for international harmonization of phytosanitary measures and their technical justification.
(The Purdue University EXCERPT database contains the phytosanitary requirements of more than 250 countries. The database was created by the U.S. Department of Agriculture and is maintained by Purdue’s Center for Environmental and Regulatory Information at Purdue University. Full search access to the database is available to the public for an annual subscription of $150. To learn more about the database or to subscribe, visit the Web site at www.ceris.purdue.edu/main.html or e-mail firstname.lastname@example.org.)
Phytosanitary requirements are developed as a response to a perceived or real threat to the plant resources of a single country. In 1997 a new framework for phytosanitary requirements was proposed by the Food and Agriculture Organization, an arm of the United Nations that emphasizes international standards for phytosanitary measures and technical justification through the technique of Pest Risk Analysis. Additionally there are nine Regional Plant Protection Organizations worldwide that function to promote inter-regional cooperation on phytosanitary standards development. The U.S. is part of NAPPO, the National American Plant Protection Organization (U.S., Canada, Mexico).
As you can see, in the realm of phytosanitary requirements, plant health regulators are on a mission to develop
In the forefront of all of this activity has been the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS). Aside from Australia and New Zealand, the U.S. is considered the preeminent authority on plant health.
Global Import Rule
In 1998, APHIS issued an advanced notice of a proposed rulemaking to create a "global import rule" that will apply to all incoming solid wood packing material. Representatives of the National Wooden Pallet and Container Association (NWPCA) responded to the request for comments in early 1999. The NWPCA also responded later to the APHIS plan to draft an environmental impact statement for the upcoming rule.
The rule in an internal draft form calls for the primary mitigation technique to be heat treatment of all incoming solid wood packing material.
At a review meeting earlier this year, APHIS shared a timetable for the global import rule. The pest risk assessment (PRA) was open to comments during the summer. It appears that a proposed rule might be available by July 2001 and the final rule by January 2003. It would be phased in over 12 months with full implementation by January 2004. The APHIS staff acknowledged that significant external political forces are encouraging the agency to reduce the time line by 12 to 16 months.
In December 1998 the U.S. imposed restrictions on imports from China because of outbreaks of the Asian long-horned beetle; the insect came into the U.S. aboard wooden packaging. China retaliated in the fall of 1999; it issued new requirements to reduce the likelihood of the pinewood nematode being imported on solid wood packaging material made of coniferous wood. NWPCA members have gone to great lengths in some cases to help customers comply with the new Chinese requirements.
Brazil adopted new requirements in late 1999 to protect its forest resources from the Asian long-horned beetle. The new rules were not well conceived or coordinated with the exporting countries involved. The wood packaging industry suffered the consequences. NWPCA members increasingly have been asked to research options other than solid wood for shipments to Brazil. Earlier this year Brazil lifted the requirements against the U.S. for phytosanitary certificates for solid wood packaging material. This resolved, in the short run, the regulatory uncertainty posed by the initial requirements, but the damage was already done. For example, the largest multi-national U.S.-based electronics manufacturer already had begun redesigning its most common pallet in order to construct it from non-solid wood material.
Russian agriculture officials asked APHIS earlier this year to begin issuing phytosanitary certificates for shipments containing solid wood packaging material. Russia suspended the requirement following negotiations.
Finland’s Plant Protection Service issued wood treatment requirements in the spring that are designed to stop the pinewood nematode from spreading from certain countries through imported coniferous wood packaging material. The new rules were in response to 17 recent notices that solid wood packaging material entering Finland violated European Union import requirements. The new rules affected wood packaging materials from the U.S., Canada, China, Japan, Korea, Mexico and Taiwan.
Coniferous wood packaging material must be bark free, free from grub holes larger than 3 mm across, and have a moisture content of less than 20% achieved at the time of manufacture.
Alternatively, the wood may be heat treated to a core temperature of 133 degrees F (56 degrees C) for 30 minutes or fumigated.
Finland also insists that the treatment options be verified through the issuance of a phytosanitary certificate. Since APHIS cannot issue phytosanitary certificates for solid wood packaging material, U.S. and Finnish officials are engaged in discussions on this matter.
In finalizing the export certification process for solid wood packaging material used in shipments to China, the U.S. has insisted that the heat treatment of coniferous wood be accomplished in the U.S. because the Department of Agriculture has no enforcement authority in Canada. To facilitate the continued use of heat treated Canadian lumber, the Canadian Food Inspection Agency developed a heat treated certification form that looks very similar to the U.S. form 553. When this form is finally approved, Canadian lumber suppliers will be able to provide U.S. pallet manufacturers with a heat treatment certificate that may be used in the U.S. export certification process. The form is expected to receive final approval before Jan. 1, 2001.
Meanwhile, U.S. pallet manufacturers may continue to use lumber that is heat treated in Canada provided that the lumber supplier makes the following declaration on its corporate letterhead: All lumber or pallet components supplied in shipment invoice #______ have been subjected to a heat treatment process that raises the internal core temperature of the material to at least 133 degrees F (56 degrees C) for at least 30 minutes. An officer of the lumber company must sign the statement.
The European Commission announced in the spring its plan for an emergency rule to regulate imports of coniferous solid wood packaging material from the U.S., Canada, Japan and China. Coordinated by the NWPCA and APHIS, U.S. and Canadian officials met with representatives of the transport industry to discuss a coordinated response to the European Union’s decision. The NWPCA was represented by Jordan Piland of Atlas Pallets (Williamsburg Millwork), chairman of the association’s standards committee and its phytosanitary review team, and myself. We presented the industry’s capabilities and the association’s thoughts on the appropriate course of action to respond to the proposed European Union requirements. Representatives from the American Association of Port Authorities, the Association of Importers and Exporters and several lumber supply associations were invited to the meeting to share their opinions as the U.S. and Canada devise a response. At NWPCA’s invitation, the group also included a representative from IBM who presented information on IBM’s pallet marking system as a possible verification solution.
I met briefly with the staff person in charge of phytosanitary issues for the European Union to express the NWPCA’s concerns about the timing and the restrictions posed by the proposed requirements. The U.S. and Canada were attempting through diplomatic channels to arrange a meeting with European phytosanitary directors in early November to review options. It appears unlikely that the proposed requirements will go into effect by Jan. 1, 2001.
A working group of the International Plant Protection Convention (IPPC) under the auspices of the United Nation’s Food and Agricultural Organization met last summer in Canada to begin to fashion an international sanitary-phytosanitary measure for non-manufactured solid wood packaging material.
The NWPCA board of directors seeks to minimize market shifts to non-solid wood packaging options and to maximize the time members will have to implement new treatment techniques by creating a treatment and marking program that facilitates international commerce.
The NWPCA will:
• Research the scientific backing of the global import rule by reviewing the pest risk assessment to determine if other mitigation techniques could substitute for heat treatment.
• Encourage the rapid develop and implementation of the global import rule. This is due to the unpredictable nature of implementation of ever changing phytosanitary requirements by individual nations and the resulting damage to the solid wood pallet industry.
• Develop a seamless pallet verification and identification program using the draft mitigation requirement for the pinewood nematode (i.e., internal core temperature of 133 degrees F for 30 minutes). The NWPCA expects other countries to implement requirements similar to the U.S. global import rule. We will face a de-facto worldwide phytosanitary rule by 2004.
For up-to-date information, visit the NWPCA Web site at www.nwpca.com; changes and updates to import requirements for China and Brazil also are posted on the APHIS Web site at www.aphis.usda.gov/ppq/swp.
(Editor’s Note: Bob Peters is Technical Services Director for the NWPCA; he may be reached by calling (703) 527-7667.)
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