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Safety Zone: Gold Paint, Pallets and International Regulations Ė A Simple Strategy for ISPM-15 Compliance
Columnist Gabriel Curry identifies some best practices for complying with ISPM 15 regulations for repaired pallets.
By Gabriel Curry
Date Posted: 8/1/2011
††††††††††† Itís a small world out there, but itís full of big time regulations. Who would have thought that your pallet plant would have so many entities looking over your shoulder and making sure you are paying enough taxes, keeping your employees safe, being a good steward of the environment, and so on.
††††††††††† One of the many agencies, principalities and powers that have something to say about the pallets you produce is the IPPC (the International Plant Protection Convention). This is the global body behind the stamp that must be on any pallet treated and certified according to ISPM 15, the international standard for pest treatment of solid wood packaging. This has become a defacto standard for wooden pallets destined for export shipments.† In the United States, the ISPM 15 ceritifcation process is managed by the American Lumber Standard Committee (ALSC) in conjunction with a number of independent certification agencies that each have their own unique stamp.
††††††††††† Blah, Blah, Blah. Already some of you may be wanting to turn the page because your facility doesnít do heat treating and your customers arenít asking for it. But before you skip to the next article, be aware that the ISPM 15 regulations should be of interest even for those outside of the program. If you repair someone elseís stamped pallet and send it back into service with the old stamp intact, you are looking for trouble.
††††††††††† Tom Searles of the ALSC said that it is illegal to repair an ISPM certified pallet and then try to pass it off as ISPM 15 compliant for export without removing the old marks, re-treating the entire pallet and applying a new mark. ALSC requires companies in the U.S. heat treatment program to remove old marks from repaired pallets. Companies outside of the U.S. program only run into legal problems if they try to pass off a repaired pallet as ISPM compliant† without going through the above mentioned process.
††††††††††† Searles added that the ALSC encourages all pallet companies to remove ISPM 15 marks when repairing or using previously certified lumber to build a new pallet. He explained that this extra step may require a little more effort, but it preserves the integrity of the ISPM 15 mark in the United States.
††††††††††† Removing marks ensures that a company doesnít get blamed for new wood added to a previously treated pallet. That would be like driving around in your car using your brother-in-lawís license tag. Heaven help you if you ever get pulled overÖ
††††††††††† Itís easy enough to remove the stamp, so this is one regulation thatís not too hard to comply with. You simply cover them over with paint.
††††††††††† When stamps first started showing up in the pallet population, recyclers most often removed them with a few bursts of black spray paint that they got at the hardware store.† As more pallets began to turn up needing stamp removal, my company responded by offering a masking product that more closely matched the color of the pallet so the stamp could be covered up in a more professional fashion. Pallets may be ugly, but they donít have to go out of your plant looking sloppy as well.
††††††††††† Called Pallet Mask, this product meets the requirements of obliterating previous marks without making the pallet look like an eye sore. Another advantage of using a product like Pallet Mask for recyclers that are heat-treating is they can apply the new stamp right over the old one in the place where inspectors are most accustomed to finding it.
††††††††††† Most of these stamps are applied with ink and a rubber stamp, but there are a few guys out there putting theirs on with a branding iron. Painting over these wonít totally obscure the embossed image, but according to Searles† of ALSC it is considered sufficiently removed if it is covered over with paint or Pallet Mask.
††††††††††† Gabriel Curry is President of Hub Industrial Supply. Hub Industrial Supply developed the Pallet Mask for covering the heat treat stamp.† He can be reached by email at Gabriel@hubindustrial.com or by phone at 800-743-9401, or visit http://www.hubindustrial.com.