Millions of pieces of wood packaging material (WPM) are used in imports to the United Sates every year. Regulatory authorities and the WPM industry have developed a robust treatment program to stop the spread of invasive pests around the globe.
While most shipments are compliant, there are some that are not properly marked, treated or are actually infested with a quarantine pest species. There are certain steps that shippers can take to ensure compliant packaging. Ultimately, the importer of record is liable for any fines or costs associated with non-compliant WPM detected at the U.S. border.
The Pallet Enterprise sat down with representatives from U.S. Customs and Border Protection (CBP) to discuss inspection processes and ways that shippers and importers can ensure compliance. CBP identified obvious signs of non-compliance and infestation that anyone in the supply chain should monitor. The two experts who spoke with the Enterprise are Stephen Brady, and Annaliese Blecha, senior agriculture operations managers with the Agriculture Programs and Trade Liaison for CBP.
Pallet Enterprise: Please tell the readership a bit about your role at CBP?
Annaliese Blecha: I’ve been an agriculture specialist with CBP since 2005. I started my career in Nogales, Arizona, where I worked for 10 years. Now, I work in headquarters for Agriculture and Trade Liaison for Agriculture Enforcement and Engagement as part of the Process Resolution and Risk Management Team. Steve and I work together to head up the national Wood Packaging Material Program that we have at CBP.
Steve Brady: I work in the same department as Annaliese. I started with CBP in 2008, and originally, I’m from Philadelphia.
Pallet Enterprise: If a shipper is going to do a preliminary inspection of WPM before sending cargo, what are the obvious signs of non-compliance that the exporter should look for? What should a shipper do to ensure compliance?
Steve Brady: First and foremost, the shipper should buy WPM from a reputable company. Pallets have to be treated and stamped with the International Standards for Phytosantiary Measures 15 (ISPM-15) mark. The shipper should look for obvious signs that the heat treatment or methyl bromide treatment didn’t work. This includes frass, wood dust, obvious entry or exit holes or the presence of live pest. If you find signs of a possible infestation, you want to investigate further until you can determine if a live pest is still in the WPM. If the heat treatment or methyl bromide treatment worked, there can still be bugs inside the wood, they should just be dead.
Pallet Enterprise: So, if that insect is still in there, but it’s dead, is that considered non-compliant?
Steve Brady: That’s compliant. We know that there’s going to be wood boring insects in these pallets and dunnage. If the pest is in the tree when it is cut, it will still be there even after treatment. You just don’t want any live pests feeding on the wood. We find dead ones all the time, and that’s okay. You are looking to see if it moves or is squishy or responds to warmth.
Annaliese Blecha: The presence of a bore hole or something like that will require additional inspection. This further inspection can be pretty invasive. It may take the actual destruction of the pallet to get to where the insect is. If you’re an inspector that’s looking at WPM before it goes overseas or before it is transferred from the port of loading, and you see boreholes but don’t see an insect, that doesn’t necessarily mean that a pest isn’t in there.
Pallet Enterprise: If a shipment is not compliant with ISPM-15, is it transferred to compliant packaging or is the whole thing rejected and sent back to the point of origin?
Steve Brady: That depends on the situation. If we find a live quarantine pest, it’s an automatic re-export. We don’t allow anyone to manipulate the WPM if we find a living insect. If it’s non-compliant based on an improper stamp, that decision is up to the CBP authorities at the individual port to manipulate however they see fit. Most ports are starting to prohibit manipulations. It takes a lot of time on our part. It is really all based on staffing and how many allowances we have done in the past for that company.
Pallet Enterprise: If the container has several non-compliant pallet loads, is the entire container re-exported or just those problem pallets/WPM?
Steve Brady: It depends on the circumstance. If it’s all owned by the same company/importer, yeah, we’re going to re-export the whole thing. If it is a co-mingled load with different importers and they are sharing a container, then it really just depends what the U.S. Department of Agriculture (USDA) says. If the stamps are all the same, we will re-export the entire container. But if they are from different shippers, different products and different treatment marks, we will try to help them out. We have to assess the risk based on the guidance of the USDA. Whatever happens in this case, the shipper is going to have a delay.
Pallet Enterprise: What type of delay is associated with an enhanced inspection?
Steve Brady: It all depends on the logistics of the port, but we can inspect WPM, find that it’s compliant and release into commerce.
Annaliese Blecha: The delays for problems with stamps are the worst. That’s why you want to get your WPM from a reputable supplier. Sometimes we have to check to see if the stamp is fraudulent. The USDA has to deal with the National Plant Protection Organization, where the WPM originated. That can take some time. So, a lot of that is out of our hands.
Pallet Enterprise: Bark is a major issue in terms of infestation or re-infestation, how much bark is allowed?
Steve Brady: Bark shows us that there may be an insect in this WPM. I am not a scientist. We rely on the USDA for this sort of information. But the presence of bark on WPM is a red flag to an inspector to give this WPM a closer inspection.
Pallet Enterprise: What if WPM looks like it has old and new wood? Does this suggest non-compliance if the mark is on the old wood? Will that WPM be rejected? Why or why not?
Steve Brady: We are supposed to treat one pallet as one unit. So, if that pallet was rebuilt by combining lumber from damaged pallets, it’s going to pique the ag specialist’s interest for further inspection.
Pallet Enterprise: Does each piece of dunnage need a mark or just the packaging unit?
Steve Brady: Not every piece has to be stamped. We understand that dunnage sometimes comes in 15-foot lengths and needs to be cut. It needs to be obvious that all pieces come from the same treated and stamped material. Our specialists use our training to look and see if the material appears to come from the same piece of wood.
Pallet Enterprise: What about the thickness of the wood?
Steve Brady: If a piece of wood is thicker, I would anticipate that it would invite closer inspection. But it wouldn’t be rejected unless an issue is found.
Pallet Enterprise: Is a mark viable if it doesn’t have the country of origin and/or a license number?
Steve Brady: No, it has to have the stamp correct. It needs the International Plant Protection Convention (IPPC) logo, the country code and certification number of the treatment facility.
Pallet Enterprise: I assume an importer’s past history can come into play in terms of how much leeway is received or how much scrutiny a container receives.
Steve Brady: Obviously, we do spot checks. That’s how we find the bad actors. But a history of non-compliance is going to get an ag specialist to investigate further.
Pallet Enterprise: What is the impact of non-compliance?
Steve Brady: Fines can be big because the USDA gets involved. The importer of record can actually be fined by both the USDA and the CBP. We can go all the way up to the value of the commodity. As a federal agency, we don’t have the ability to go after a shipper if they’re not a U.S. company. So, we penalize the importer, and most of the time, it’s not the importer’s fault. They were buying a commodity, and they assumed their shipper was doing everything correctly and they weren’t. But it’s kind of our only leg to stand on. And it is ultimately the importer’s responsibility.
Pallet Enterprise: Is any species or country of origin more of an issue or concern?
Steve Brady: I’m not sure about species. But our big countries of interest right now are Mexico, China and Turkey. Those are the top three when it comes to non-compliant WPM.
Pallet Enterprise: Does ISPM-15 seem to be working?
Annaliese Blecha: I think historically we did find more live quarantine pests before the treatment program. Of course, we find more non-compliant WPM now because there wasn’t a marking requirement back then. But overall, ISPM-15 appears to be decreasing the incidents of live quarantine pests in WPM.
Steve Brady: Awareness is definitely up. Some different programs that don’t have anything to do with WPM now consider it. For example, Customs-Trade Partnership against Terrorism (CTPAT), CBP’s partnership against terrorism, now incorporates ISPM-15 rules. CTPAT is a program that importers can join where CBP will work with them to make their supply chain more secure. Its focus is mostly fighting terrorism and drugs. Basically, if you want to be a part of CTPAT, you must have good WPM as well. So, we kind of added the bugs to the terrorism part.
Annaliese Blecha: We’ve been working a lot more on outreach for companies, especially when it comes to pre-shipment inspections.
Pre-Shipment Inspection Checklist
1.) Make sure to buy your Wood Packaging Material (WPM) from a reputable company that is licensed by your national plant protection oversight organization. For example, in the United States, oversight for treatment is handled by the American Lumber Standard Committee. Don’t assume compliance. Require ISPM-15 compliant packaging in your contracts and communicate those expectations to the supplier.
2.) Only buy WPM that is treated and properly marked according to ISPM-15. First, look for an ISPM-15 mark. No mark on the packaging unit, no compliance. The mark should bear the IPPC logo, the country of origin code, the treatment code and the identification code for the treatment facility. The mark should be applied to two opposite sides of the WPM, clearly visible and legible.
3.) Look for visible signs of infestation. This includes round exit holes, feeding damage, and snake-like trails. The presence of frass (insect excrement that looks like sawdust) is also an indicator of WPM infestation. If you see signs of a possible infestation, continue investigating until you decide if there is a live insect present or not.
4.) Buy WPM with debarked wood because bark increases the likelihood of infestation. And it can also increase inspection scrutiny at the port.
5.) Ask your WPM provider who certifies their operation and what the results have been.
For more information on CBP resources regarding WPM, visit www.cbp.gov/border-security/protecting-agriculture/wpm.
For more information on what to look for when inspecting WPM, visit www.aphis.usda.gov/aphis/ourfocus/planthealth/import-information/wood-packaging-material/inspecting-wpm.
