Following our reports in the October issue regarding the slow pace of implementation of ISPM-15 (the international regulation governing wood packaging material [WPM] such as pallets, crates and dunnage) questions continue to be raised. If a company ships material or finished products on or in wood, or has solid wood dunnage in its packaging material makeup, this regulation applies.
The legislation from the Interim Commission on Phytosanitary Measures of the International Plant Protection Convention (IPPC), came about because the invasions of various insects were traced back to wooden pallets and containers. The problem is global. Eradication efforts have become local at the ports of entry.
The U.S. Department of Agriculture, in concert with 113 countries, adopted the international standard for WPM approved by the commission, March 15, 2002. Compliance with the regulation has frequently changed. Most recently it was slated for September 16, 2005. Since that date, however, the Customs and Border Patrol (CBP), along with its counterparts in Canada and Mexico, has enacted a phased-in schedule for the WPM rule. Note: This schedule applies to WPM being imported. WPM being exported must still comply with ISPM-15 and the regulations of the countries to which the WPM is being sent. Here is an outline of CBP’s program:
- September 16-January 31, 2006 will be a period of informed compliance.
- February 1-July 4, the WPM requirement will be in place for pallets and crates.
- July 5 forward, WPM requirements will be enforced for all WPM, including dunnage.
The final ruling allows only two options to treat wood that will be used in overseas shipping: heat treatment or fumigation with methyl bromide.
For heat treatment, WPM must be heated to a minimum wood core temperature of 56 C for a minimum of 30 minutes. Fumigation must be with methyl bromide in an enclosed area for at least 16 hours at the regulated dosage. Wood must then be aerated to reduce the concentration of fumigant below hazardous exposure levels. You should be aware that the U.S. Environmental Protection Agency is working to eliminate the use of methyl bromide in this country.
After either of these treatments, the WPM must be marked in a visible location on each article (pallet, container, etc.), preferably on at least two opposite sides, with a legible and permanent mark approved by the IPPC, to certify that wood packaging material has been subjected to an approved treatment.
The mark must include the IPPC trademarked graphic symbol, the ISO two-letter country code for the country that produced the WPM, a unique number assigned by the national plant protection agency of that country to the producer of the wood packaging material, and an abbreviation disclosing the type of treatment.
If the border patrol spots an incoming pallet or container that is not marked, it will assume the article is untreated and non-compliant. The regulation stipulates re-export of non-compliant WPM. (See the CBP’s modification to this import rule cited above.) Exportation of non-compliant WPM will be the responsibility of the importer of the merchandise.
If the material handling article (i.e. pallet or crate) being used is made of wood, it’s a fair assumption that it falls under this ruling. Most wood packaging materials are covered, including wooden pallets, crates, boxes and pieces of wood used to support or brace cargo. Solid wood packing material is defined as ‘’wood packing materials other than loose wood packing materials, used or for use with cargo to prevent damage, including, but not limited to, dunnage, crating, pallets, packing blocks, drums, cases, and skids.”
And since there are exceptions to every rule, here are a few that apply to this one:
- Manufactured or engineered wood material such as fiber board, plywood, whisky and wine barrels, polywood, strandboard and veneer.
- Sawdust, wood wool and wood shavings, produced as a result of sawing or shaving wood into small, slender and curved pieces less than 6 mm in any dimension.
- WPM used by the U.S. Department of Defense (DoD) to package non-regulated articles, including commercial shipments pursuant to a DoD contract.
In addition, by reciprocal regulations in the U.S. and Canada, WPM made entirely from Canadian origin wood or U.S. origin wood are exempt from the treatment and marking requirements in trade between the two countries.
If a company regularly produces articles of wood to transport a specific nonregulated commodity (for example, fuel gauges, armaments and ammo boxes), this material is not considered WPM.
Where to go for help
A listing of international plant protection agencies outside the U.S. is maintained at the IPPO Web site (www.ippc.int/IPP/En/nppo.jsp). This site has a wealth of information. USDA has designated two entities to manage the treatment programs in the U.S. The National Wooden Pallet & Container Association (NWPCA, www.nwpca.com/ ExportTreatment/ProgramOverview.htm) manages the fumigation program, and the American Lumber Standards Committee (ALSC, (www.alsc.org/WPM_ facsimile_mod.htm), manages the heat treatment program.
The Implementation Plan is posted on the Customs and Border Patrol Web site, www.cbp.gov. USDA has a toll-free phone line to answer questions about the regulation, (866) 738-8197.
There are alternatives available for overseas shipping. Many plastic pallet manufacturers offer low-cost pallets (still not as inexpensive as wood) for overseas shipping. Corrugated material, properly treated and constructed, makes a viable shipping platform. There are pallets made of engineered wood, pressed wood and combinations of wood and plastic that are not regulated. Aluminum pallets are also popular for closed loop systems.CHEP, a global pallet and container pooling company,-offers a treated wood pallet for its international customers. The pallets are leased here, then moved into the company’s pallet pool when they reach their destination in Europe.