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International Standards For Phytosanitary
Measures
Guidelines for Regulating Wood Packaging Material in
International Trade
FREQUENTLY ASKED QUESTIONS
Updated April 16, 2002
1) When
will it become effective?
The standard is now in place (approved March 15, 2002) but
it doesn't become effective until the receiving countries enact the
appropriate regulations.
2) Do providers have a license or a
stamp?
HT "providers" must be registered with the ALSC
enforcement agencies. APHIS is still determining how to provide oversight
over the fumigation program.
3) Will there be new requirements
for proving that the material was fumigated?
There will be a program to monitor activities of
fumigators providing services under the program.
4) Which countries are likely to
ask for bark-free or debarked material?
We are guessing here, but the European Union countries are
the ones who supported the "debarking" requirement in the IPPC meeting. It
is unclear if they would adopt the debarking provision for all countries
rather than on a "technical justification" basis for particular
countries.
5) Does this rule apply to all
species of wood?
It is not a rule; it is a standard. But yes, it does apply
to all species of wood.
6) What about using peeler
cores?
Peeler cores are specifically exempted from other
treatments but wood packing material manufactured from peeler cores would
need to be marked under the program.
7) At the time of effectivity, what
about wood materials that are already enroute? (will there
be a "grace
period"?)
The standard doesn't address this but our expectation is
that there would be a phased in implementation period for each
country.
8) Is there a plan for a revision
of the standard after
implementation issues are fully surfaced?
No plan for revision as such, but standards are reviewed
every three years.
9) Exactly how do users get a copy
of the specifications for
Heat Treatment?
There is no
specification (other than the standard) at present but the ALSC
enforcement rules can be downloaded from the APHIS web site or the ALSC
web site.
10) If I comply fully with the IPPC
standard as it reads now, will the countries that currently have
regulations in place accept those shipments? (rationale, the IPPC standard
is more encompassing than many regulations).
Not until they adopt regulations that are consistent with
the IPPC standard. For instance, countries with "higher" standards (e.g..,
Australia) would keep their current requirements until the IPPC standard
is adopted in Australia. But since the IPPC standard is more stringent
than the EU standard (that is, it covers all wood types, not just
coniferous) appropriately treated and marked wood would be acceptable for
the EU.
11) Can I apply the markings as
shown even if there is no grading agency oversight process established
within my country right now?
No, since the National Plant
Protection Organization (NPPO), of the exporting country (in this case
APHIS), is responsible for oversight of the program, the use of marks must
be coordinated with the NPPO. Companies that use the marks improperly will
be investigated and possibly fined.
12) When will the wooden pallet
industry truly be ready to heat treat softwoods AND hardwoods per this
standard?
The softwood industry is already complying substantially
with the measures since the EU program has now been in effect for 6
months. The hardwood industry is now the main focus of further efforts. It
is unclear when the hardwood industry will be "truely" ready but the
National Hardwood Lumber Association (NHLA) is a member of the ALSC heat
treatment program.
13) What is the estimated cost
increase for heat treated materials compared with
untreated?
This is not a quarantine issue. Please consult the
National Wood Pallet and Container Association (NWPCA).
14) Can we still use untreated
materials on shipments between NAFTA countries (Canada, US,
Mexico)?
Canada, the US and Mexico still need to harmonize their
entry requirements and this issue is still far from settled. But even if
untreated materials are allowed for within-NAPPO movements, it is the
market for wood packing that will be control the issue. APHIS expects that
shipments between the US, Canada and Mexico will have to meet the
conditions of the international standard since many of the products are
shipped on to third countries.
15) When will countries that
currently require Govt. issued paper certifications for heat
treatment/fumigation switch to the paperless marking protocol? (priority
on China)
APHIS is discussing harmonization of wood packing
requirements with China in an upcoming bilateral meeting (scheduled for
May, 2002).
16) What will be the requirements
for shipments to/from countries that are NOT part of the
IPPC?
They will have to meet the requirements of the importing
country.
17) What is being done to review
and approve other treatment methods such as irradiation?
APHIS is not involved in the development of new technology
for wood treatment. However, the IPPC technical panel will meet
periodically to review new treatments.
18) After the IPPC standard becomes
effective, will I still be able to ship materials that were treated and
marked per EU regulations or other country regs? (example: pallets marked
"China Treated" that were fumigated before).
The presumption is that the packing materials will have to
be marked in accordance with the international standard.
19) Even though the IPPC standard
defines a paperless protocol for compliance, are there any suggested
statements that we should put on shipping documentation to assist
inspectors? Example: "All packaging within this shipment complies with
IPPC standards" (along with bug symbol).
APHIS makes no such recommendation at this time. Any such
statements will be at the request of importing countries
20) How stable is this standard?
What is the timetable for potential changes to it?
The standard will change from time to time. There is a 3
year cycle for review of existing standards and the necessary adjustments
will be made where needed.
21) Will lumber shipments being
shipped as a commodity in itself be affected?
The IPPC standard only applies to the export of non
manufactured wood packaging material used in the transport of
commodities.
22) Are there any requirements for
dunnage?
Dunnage should be marked and treated under one of the
approved measures of heat treatment or fumigation. If not treated under
one of these measures, at a minimum wood will be required to be made from
bark free wood and free of pests and signs of live pests. Dunnage includes
blocking and bracing used to secure or support the commodity.
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