Phytosanitary Regulations Continue to Present Challenges and Opportunities

They’re back!!! That’s right the black beetles with white spots and long horns are munching on trees in the Northeast again. Asian long-horned beetles, which a couple of years ago helped raise plant health concerns in the United States, were recently discovered in New Jersey. These pests can cause major damage to hardwood trees, and they are believed to have come to this country via solid wood packaging from Asia.

            The Asian long-horned beetle helped spark the need for new regulations to govern solid wood packing used for international product transport. Pallets, dunnage and crates have all been impacted as governments around the globe are working to develop regulations. Many countries are voluntarily planning to adopt the ISPM-15 treatment standard for solid wood packaging, which was developed by the United Nations in 2002.

            Adoption of the voluntary standard has taken longer than some expected. Only New Zealand, Australia and Taiwan are currently using it as part of their official plant health/phytosanitary program. Other countries are planning on adopting the standard in the near future. Some countries, such as Mexico, are even recommending that you abide by ISPM-15 although they are yet to officially require compliance with the international standard.

            Countries changing adoption dates and policies have caused confusion in the market for many wood packaging users. “There is still a lot of uncertainty about where countries stand as far as enforcement,” said David Dixon, president of Packaging Research Laboratory (PRL), a major certification agency for treated wood packaging programs in the United States.

            Details are still being worked out as nations announce their policies. Some are even suggesting that they may require treatment practices that go beyond what is called for in the ISPM-15 standard. The European Union, which will implement the voluntary standard in March 2005, may require some wood packaging be made from debarked wood. Chile, Australia and New Zealand also are requiring that solid wood packaging be made from debarked lumber. The United States government is trying to negotiate with European authorities over this issue.

            Bill Snell of the U.S. Animal Plant and Health Inspection Service (APHIS) said, “There is no justification for debarking of wood packaging that has been treated according to the international standard.” Some countries are concerned that heat treating or fumigation does not adequately provide protection against re-infestation if wood retains a significant amount of its moisture content and bark remains on the surface.

            Both China and South Korea have voiced concerns over the use of methyl bromide fumigation to kill the pinewood nematode. Evidently, a study conducted in Asia has raised the concern that fumigation may not be as effective in killing pinewood nematodes as heat treatment. China has not set a date to implement ISPM-15 although it has indicated its intention to implement the standard with one major twist. It will not allow fumigation treatment for coniferous wood packaging. South Korea will likely follow a similar procedure.

            Australia has had fairly stringent plant health standards compared to other nations. It has begun to accept the ISPM-15 standard in addition to its existing requirements. Australia has dropped the need for a treatment certificate and its higher heat temperature for wood packaging that is ISPM-15 compliant. Additionally, Australia will no longer require that ISPM-15 compliant packaging be treated within 21 days from the shipping date although it still requires that all solid wood packaging be bark free. Shippers can either use the old procedures with the more stringent requirements or the newly adopted ISPM-15 standard.

            Mexico has indicated that it will adopt the ISPM-15 standard. Initially, Mexico planned to mirror the implementation schedules developed by the other NAFTA region countries. However, Mexico has yet to make any major announcements in a while and some experts who follow the issue doubt that Mexico will move as fast to implement ISPM-15 as the United States or Canada. Although the United States and Canada are exempting each other from the new requirements, both intend to treat Mexico just like any other country. The similarity between the United States and Canada in their forest ecosystems, pest structures and quarantine procedures has led to this exception. Non-manufactured wood packaging originating in either country will not have to be marked or treated in accordance with the IPPC standard to flow freely across the border. Shipments destined for other countries should be marked or treated. Mexico has indicated that it will require full compliance from both the U.S. and Canada when it adopts new phytosanitary measures.

            Some companies have had loads held up in Mexico because there seems to be confusion among local authorities. Although the country has yet to officially adopt the ISPM-15 standard, sporadic enforcement has caused problems for some shippers. You may want to consider treating wood packaging destined for Mexico just to be safe.

            The U.S. government is expected to publish its final rule soon. It may have even done so by the time this article reaches you. The U.S. government will adopt the ISPM-15 standard without any changes or additional requirements according to an official source. The new measures will be adopted one year after the final rule is published. Look for strict enforcement to take place gradually as the U.S. authorities provide a grace period for imports. The U.S. government doesn’t want to be too lax and thereby encourage shippers to delay compliance. On the other hand, the government does not want plant health issues to disrupt international trade.

            Michael Hicks of the U.S. Department of Agriculture Foreign Agriculture Service (FAS) said, “Everybody recognizes that the phytosanitary issue has a significant possibility to disrupt trade.”

            Right now the major focus is on the EU, China and Australia according to Jason Robison, export packaging manager for Timber Products Inspection (TPI), a major certification agency for treated wood packaging programs in the United States. Both China and the EU currently require treatment of coniferous (softwood) packaging material coming from the United States.

Early Mover Lessons

            With both the heat treatment and methyl bromide fumigation certification programs in full swing, companies around the United States are getting used to the new processes. Neither major certification agency reported problems in getting most companies certified. Treatment times have varied depending on the chamber/kiln design and other factors, such as ambient temperature.

            David of PRL reported that all of the major commercial heat treatment systems work. It’s just a matter of how long they take to treat a load. Two major things to consider in the design are the volume of air and movement of air. Jason of TPI said that BTU generation and air flow are the two biggest design factors that he has seen impact drying times. He said that he has heard of loads taking anywhere from 2.5-8 hours to dry. The type of wood used and thickness can also impact drying times. Block pallets take longer to treat than standard stringer designs. The treatment time required to comply with the ISPM-15 standard is predicated on the core temperature of the thickest component in the run.

            When fumigation was first announced as an option, some shied away from it because methyl bromide raises environmental concerns and its use is fairly restricted. Since the U.S. government has decided that methyl bromide will still be available for quarantine applications, such as wood packaging, some are less hesitant now to view fumigation as a viable option. David said, “Chemicals don’t seem to be as much of an issue to people any more…Fumigation demand is starting to pick up.”

            Fraud has not really been as big of a problem as some suspected it might be. David said, “Fraud is really being taken care of because a lot of people are keeping an eye on things.” Although this could change as hardwood lumber begins to be treated, so far there have been few real problems. The ability for the industry to police itself and report possible bad actors will be the key for the future.

            Mark fraud is a serious offense. Federal copyright law protects phytosanitary marks. Companies found guilty of mark fraud could be heavily fined. ALSC and/or the NWPCA will investigate all reported cases of fraud. If you suspect fraud, call the ALSC (heat treat) at 301/972-1700 or the NWPCA (fumigation) at 703/519-6104.

Pending Market Dynamics

            Most of the wood packaging being treated now is coniferous due to the concerns about the pinewood nematode. Buying already treated cut stock is a popular way for many companies to handle the regulations for coniferous packaging material. This is especially true for those operations without a heat treating system.

            As countries move to adopt ISPM-15, hardwood will need to be treated too. This will dramatically increase the amount of lumber and pallets that must be treated in the United States. David believes that fumigation demand will pick up as hardwood material must be treated because there is not as much treated hardwood cut stock on the market as there is coniferous material. Fumigation is primarily being used for runners and odd sizes.

            Jason said, “The heat treatment program is much larger than the fumigation program, which is still in its fledgling stage.”

            Some companies are looking at fumigation as an option  for heavy skids. The extended treatment time required for these thicker pieces of wood is causing significant wood drying and in some cases downgrading product quality. Fumigation is also a good option for those without the capital resources to invest in a heat treatment system or steady demand for treated product. The certification agencies will come out and inspect individual lots even for those who are not ongoing clients. Make sure to consult with the appropriate agency first before treating something or buying treated material. Certification agencies won’t just take your word for it. They need documentation and a chain of custody to prove that loads have indeed been treated properly.

            A list of certification agencies as well as other information on this topic can be found at

the special pest section on Pallet Enterprise’s Web site (www.palletenterprise.com/pests).

            Official inspections conducted by agencies, such as PRL and TPI, are done on a regular basis. Inspectors look at documentation for incoming board footage and the amount of lumber used in packaging to make sure that the numbers work out. Charts of core temperature readings are kept and individual lots of lumber and finished packaging are inspected to make sure that markings are correctly applied. Keep in mind that the mark for the ISPM-15 program is only applied to finished packaging. Heat treatment marks are applied to each piece of lumber as it is treated.

Heat Treatment Program

            The American Lumber Standard Committee (ALSC) is overseeing the inspection agencies for the official heat treatment program in the United States. Contact the ALSC at 301/972-1700 or visit www.alsc.org.

Fumigation Program

            The National Wooden Pallet & Container Association (NWPCA) has stepped up to lead the oversight program for U.S. companies. The fumigation program is open to both NWPCA members and non-members alike. Contact the NWPCA for more information on the fumigation program. Call 703/519-6104 or visit www.palletcentral.com.

Pallet Enterprise Web Site

            Visit www.palletenterprise.com/pests for more information on treatment technologies, a list of inspection agencies, the latest on regulatory standards, and other phytosanitary related issues.