On Aug. 27, the U.S. Animal and Plant Health Inspection Service (APHIS), part of the U.S. Department of Agriculture (USDA), released a notice of proposed rulemaking and requested public comments regarding options for controlling the spread of plant pests in wood packaging material (WPM) used in domestic commerce. APHIS specifically mentions risks to U.S. forests and agriculture posed by the emerald ash borer and Asian longhorned beetle. APHIS also intends to prepare an environmental impact statement.
Currently, APHIS requires WPM used to import material into the U.S. to be treated with heat or fumigation with methyl bromide and marked with specific symbols used by the International Plant Protection Convention (IPPC). The IPPC developed the International Standards for Phytosanitary Measures (ISPM-15), which regulates the movement of WPM in international commerce.
The USDA currently authorizes the National Wooden Pallet and Container Association (NWPCA) to execute and monitor the U.S. fumigation program, while the American Lumber Standards Committee (ALSC) executes and monitors the U.S. heat-treatment program. APHIS, ALSC and the wood packaging industry are working together on a program requiring heat-treated wood packaging material to be marked with the ISPM-15 symbol, often called a “bug stamp.” The mark signifies compliance with the ISPM-15 standard.
APHIS is now considering options for regulating the movement of WPM within the U.S. A nationwide standard is needed, according to APHIS, because current rules encompass a variety of domestic quarantine notices for specific pests and regulated articles, quarantined areas and conditions governing the interstate movement of regulated articles from quarantined areas.
“The variety of requirements creates a regulatory framework that may create confusion and present challenges to industry and stakeholder compliance,” says APHIS.
“As a result, we are exploring the development of uniform measures to govern interstate movement of all WPM in order to provide greater ease of comprehension and compliance. This action is supported by various WPM industry groups.”
Among other alternatives, APHIS is considering extending the ISPM-15 international requirements to wood packaging material used for interstate commerce. Another option proposed by APHIS is pallet pooling. “Pooled pallets are constructed from a higher grade of wood than traditional pallets, with strict specifications pertaining to such factors as species of tree and source location,” says APHIS. “Combining IPPC treatments with pallet pooling may provide sufficient mitigation of the pest risk associated with wood packaging material moving domestically in the U.S.”
APHIS is holding four public meetings “to discuss mitigation measures that could be applied to WPM (e.g., crates, dunnage, wooden spools, pallets, packing blocks) used in domestic commerce to decrease the risk of the artificial spread of plant pests such as the emerald ash borer and the Asian longhorned beetle.”
The first two meetings were held Aug. 27 in Washington and Sept. 2 in Portland, Ore. The final meetings are set for Sept. 15 in Houston and Sept. 29 in Grand Rapids, Mich.
At the first two meetings, James Anderson, general counsel to Intelligent Global Pooling Systems (iGPS Co.), a supplier and pooler of plastic pallets, praised plastic pallets and attacked wood pallets. “We believe that substituting plastic pallets for wood pallets will not only preserve and protect U.S. agriculture and forests, it will significantly improve the environment and reduce risks to the U.S. food supply,” Anderson said at one meeting. “Plastic pallets are a lighter, stronger, safer and more environmentally friendly alternative to wood pallets for storing and shipping goods.
“Plastic pallets do not deplete our forests, while wood pallets have been a major factor in deforestation,” he added. “Nearly 40% of all hardwood harvested in the U.S. is for pallets, about two-thirds of which are limited use, one-way pallets. Each year, wood pallets use up 7.7 billion board feet of lumber, enough trees to cover an area 10 times the size of Manhattan. Over the past 150 years, deforestation has contributed an estimated 30% of the atmospheric buildup of carbon dioxide, a major greenhouse gas.”
The attorney also said insects and bacteria cannot penetrate plastic pallets and reminded APHIS of an Aug. 11 letter from iGPS to the U.S. Food and Drug Administration (FDA). The letter, drafted by Bob Moore, iGPS chairman and CEO, urges Dr. Stephen F. Sundlof, director of the FDA’s Center for Food Safety and Applied Nutrition, and Michael R. Taylor, senior advisor to the commissioner, to “launch a comprehensive investigation of wood pallets and the risks they may pose to the nation’s food supply.”
Moore writes: “The over 1 billion wood pallets in circulation in the U.S. are a breeding ground for harmful bacteria and carry other undesirable substances that can cross-contaminate food. Wood is inherently porous and can easily absorb bacteria and fluids, creating a risk for food products where Listeria, E. coli and salmonella are a concern.”
The following day, NWPCA fired back, releasing a statement in support of FDA testing pallets for food safety. “To aid this process, NWPCA is submitting several studies already conducted by the European food industry to meet the European Commission Hygiene Directive introduced in 2000,” reads the notice from Bruce Scholnick, president of NWPCA. “The European food industry conducted a number of field and laboratory tests on wood and plastic pallets and found wood to be equal to, and in some cases superior to, plastic. Apparently, plastic is made up of minuscule honeycomb patterns that hold onto bacteria in a way that wood does not.”
The NWCPA leader also calls for an investigation into plastic pallets. “We are also asking that they [the FDA] include a safety test for deca-bromine chemical fire retardant, which is infused in the iGPS plastic pallets,” Scholnick writes. “In fact, according to the company’s own lifecycle analysis, there are 3.4 pounds of deca in each iGPS pallet.
“After pallets are roughed up in the normal wear and tear of the material handling and warehouse system, those chemicals are bound to leach into the products they carry,” he continues. “The FDA needs to test the older plastic pallets to see how much deca dust is getting onto our food.”
Comments to APHIS about the proposed rulemaking are due Oct. 26.
Insect photo courtesy of Pennsylvania Department of Conservation and Natural Resources, Forestry Archive, Bugwood.org.
