Concerned about the spread of quarantine pests within the United States, government officials, trade associations, suppliers, and industry leaders convened informal meetings in December to explore the possibility of a national pallet treatment requirement. No specific strategy or plan was finalized. However, it seems that mandatory wood pallet treatment may be adopted in the future to mitigate risks from the emerald ash borer (EAB) and other wood pests.
According to one participant, most of the people involved appeared to agree that something has to be done. The spread of pests is both an international concern and a domestic issue as states and localities try to fight off the EAB and other pests.
Invasive species is a serious issue because of the effectiveness of certain pests in killing large amounts of standing timber. Waiting until the pest is at your door may be too late for many invasive species. Some suggest that it is very shortsighted to let the initial costs associated with treatment cause the destruction of the industry’s longstanding inventory. If you want to see what this does, just look to Canada where the mountain pine beetle has decimated forests in British Columbia.
Current treatment programs have helped the pallet industry stave off competition from alternative materials, such as plastic, composite and corrugated pallets. Consistent treating of all pallets would further eliminate a major sales point for competitors. It would also reduce compliance burdens for customers.
The meeting targeted pallets while other product types are being examined on a separate basis. There are a number of sticky issues that arose. Here’s a quick rundown:
• Is mandatory pallet treatment overkill? — While the issue was brought up, most seem to agree that action is required. There is concern that some little guys are not sophisticated enough or willing to treat. While that must be a factor, some contend that treating costs cannot be the deciding factor if the result of doing nothing would be widespread devastation of ash and other tree species. Nobody wants more regulations or added cost. But sometimes that is necessary to protect the long-term future of an industry. Managing for the next quarter has been a major problem with publicly-held companies in this country. Making tough decisions in the short-term is part of what drives future growth and opportunity.
• Just ash or other tree species? —It is clear that concerns abound for more than just the EAB, which targets ash trees. Also, the difficulty of determining tree species for most people would make a species-specific requirement difficult to enact and enforce.
• When? — A number of time frames were discussed. It seems like everyone agrees that some sort of phase-in period is necessary. But how long should that be? Suggestions range from six months to two years. A major factor in that process is the ability of the industry to respond to any new requirement.
• Phase-in implementation by region or set one national implementation date? — One proposal called for a regional implementation strategy. Some criticized this because it causes competitive concerns for those on either side of the boundary lines. This could extend beyond just pallets to even pallet users. Or at least that concern was voiced by one big pallet user during the call.
• What about methyl bromide? — Using it for international shipping is one thing. Using it for a domestic quarantine is another. It would likely require environmental studies and other extra hurdles for the government. This could mean that companies using methyl bromide might be put into a situation where switching to heat treatment is the only viable option.
• Treatment capacity? — How long will it take to ramp up treatment capacity? There are numerous factors from using HT lumber to excess capacity from hardwood lumber treaters to new capacity that can be brought on line.
• Harmonization with Canada? — Canadians are already taking measures to deal with the EAB threat. It is expected that Canada would likely comply with whatever restrictions the United States placed on incoming pallets although its producers would want a reasonable time frame to respond. Canada is planning to institute restrictions on lumber and pallets coming from EAB quarantine areas within the United States. Discovery of the beetle near Toronto has increased Canadian concern for enhanced protection measures. You can find out more information by visiting http://www.canadianwoodpackaging.ca/news.asp
Pallet companies should be aware of a number of factors. First, no national requirement has been put in place at this time. Interested parties are only discussing it. As has already been covered by the trade press, there are quarantines for various states and localities related to certain pests.
The severity of the concern over invasive species points to a widespread treatment requirement at some point in the future. This does not mean you should ignore the issue until the last minute. That’s a recipe for disaster. What if you are left scrambling and can’t deliver to your customers on time?
At the very least, you should assess your current situation and treatment options. You might not have to install a heat treatment chamber if lumber drying facilities in your area have excess capacity. It would be in your best interest to get a feel for treating capacity near your plant and develop relationships with those companies. Another option is using HT lumber. This is done now for new pallet manufacturing according to the ISPM-15 standard. The problem with repaired pallets is that current U.S. regulations require the entire pallet be treated and remarked instead of replacing damaged boards with HT lumber. Also, most of the HT lumber on the market is softwood, which may not be acceptable for all clients.
Many companies will decide to develop their own treatment capacity in order to control production. Regardless, you should consider investigating treatment options. The Pallet Enterprise Web site (http://www.palletenterprise.com/pests) has a number of resources on treating equipment that can help in your research. Plus, there is no substitute for picking up the phone and calling some suppliers. You may want to start setting aside money and working on a budget for treatment equipment if it is needed in the future.
There will be more information in the near future about how you can provide feedback on the issue. The federal government is looking to get information from a wide variety of sources to make the best possible decision.
