Draft Revision of ISPM No. 15, Regulating wood packaging

material in international trade

IPPC member consultations 2008

Steward: Greg Wolff

Reason for revision• Appropriate time frame for review of the original standard

• Outcomes of 2005 International Workshop on the Practical Application of ISPM No. 15:– Several ambiguities and concerns noted in the text– Experiences in the practical implementation of the standard

shared– impediments to implementation and absences of guidance

identified

• Work carried out on elucidating role of bark in relation to phytosanitary risks presented by wood packaging

• Concerns over impacts of methyl bromide use

Most significant changes • Clarification of scope• Removal of veneer peeler cores from exempted articles• NPPO responsibilities• Timing of treatment vs. marking• Guidance on reuse, repair, remanufacture• Guidance on cooperation with other bodies• Guidance on actions following non-compliance• Addition of bark removal requirement• More guidance on treatments• More detailed guidance on marking and changes to the mark

Structure of the standard

1. Basis for Regulating2. Regulated Wood Packaging Material (includes exemptions)3. Phytosanitary Measures for Wood Packaging Material4. Responsibilities of NPPOs include:

• regulatory considerations• guidance on marking• Provisions for repair and remanufacture of wood packaging material• Transit arrangements• Procedures upon import• Measures for non-compliance at point of entry

• ANNEX 1 - Approved treatments associated with wood packaging material• ANNEX 2 - The mark and its application

• APPENDIX 1 - Methods of secure disposal of non-compliant wood packaging material• APPENDIX 2 - Guidelines for heat treatment

Scope of the standard

The standard describes:

• Phytosanitary measures that reduce the risk of introduction and spread of quarantine pests associated with the movement in international trade of wood packaging material made from raw wood

• Wood packaging material covered by this standard includes dunnage but excludes wood packaging made from processed wood (e.g., plywood) [added in revision]

• The standard does not address contaminating pests or organisms that are not plant pests [added in revision]

Basis for Regulating• Wood originating from living or dead trees may be infested by

pests• Wood packaging is frequently made of wood that may not have

undergone sufficient processing or treatment to kill pests • The origin of wood packaging is difficult to determine, so its

phytosanitary status is difficult to determine• Risk analysis and individual consideration of measures is

frequently not possible for wood packaging • ISPM No. 15 describes phytosanitary measures that reduce

significantly the risk of spread and introduction of most quarantine pests as well as a number of other pests that may be associated with wood packaging

• [Text on technical justification removed during revision]

Regulated and “exempted” articles[Format changed during revision]• Wood packaging material includes: crates, dunnage, pallets and spools• Due to known risks, wood packaging material covered by the standard includes

“wood-like” material, such as bamboo and palm [added in revision] • The following articles are considered low risk and to be exempt from the provisions

of the standard:– wood packaging made from thin wood (6 mm or less in thickness)– wood packaging made of processed wood, such as plywood, particle board,

oriented strand board or veneer (i.e., created using glue, heat or pressure, or a combination of these)

– wine/spirit barrels that have been heated during manufacture– most but not all gift boxes for commodities made from wood that has been

processed/manufactured in a way that renders it free of pests– sawdust, wood shavings and wood wool

[veneer peeler cores were removed during revision]

Approved phytosanitary measures• Approved measures involve a combination of treatments and marking of

the wood packaging material [added during revision]• These phytosanitary measures should be accepted by all NPPOs as the

basis for authorizing the entry of wood packaging material without further requirements [modified during revision]

• Wood packaging treated in accordance with the standard shall be identified by marking with an official mark, consisting of the symbol used in close conjunction with codes identifying the specific country and producer of the wood packaging material (described in Annex 2) [added during revision]

• All components of such a mark are referred to collectively as “the mark”. Use of the mark addresses issues related to verification of compliance with the treatments contained in the standard [added during revision]

• The mark should be accepted by all NPPOs as the basis for authorizing the entry of wood packaging material [added during revision]

New treatments and alternative arrangements

• Existing treatments may be reviewed and modified [as has occurred with previous revisions to the annex], and other treatments for wood packaging material may be adopted [modified during revision]

• Alternative requirements for wood packaging material may be established bilaterally between countries. In these cases, the mark shown in Annex 2 must not be used [modified during revision]

Responsibilities of NPPOs • Both exporting and importing countries have responsibilities and must

verify that the requirements have been met (reference to Article I.1 of the IPPC also presented) [added during revision]

• Responsibilities include ensuring that: [modified in revision]– related authorized systems meet all necessary requirements of the standard– wood packaging (or wood for wood packaging) bearing the mark has been

treated appropriately– certification and marking systems are monitored in order to verify compliance

– inspection procedures are established

• Treatment and marking must be under the control of the NPPO which should supervise, audit or review the application of the treatments and marking by authorized third parties [modified in revision]

• Treatment should be carried out prior to marking [added during revision]

Reuse, repair, remanufacture• Wood packaging treated and marked in accordance with the standard and not

repaired or remanufactured does not require re-treatment or re-marking when being reused [added during revision]

• NPPOs should ensure that for repaired wood packaging (less than one third of components replaced) only wood treated and marked in accordance with the standard is used [added during revision]

• If there is any doubt that all components of a unit of repaired wood packaging material have been treated, the repaired wood packaging should be re-treated. In this case, previous marks must be permanently obliterated and new marks applied [added during revision]

• If more than one-third of the components of a unit of wood packaging are replaced, the unit is considered to be remanufactured. Re-manufactured wood packaging intended for trade must have any previous applications of the mark permanently obliterated, must be re-treated and re-marked [added during revision]

Transit, import, non-compliance• Countries thorough which untreated wood packaging moves may require

phytosanitary measures in order to ensure that wood packaging material does not present risks

• Since wood packaging materials are associated with most traded commodities cooperation with various bodies (including non-phytosanitary bodies) is important, for example cooperation with customs organizations to facilitate identification of shipments with wood packaging and potential non-compliance [added during revision]

• Where wood packaging material is found to be non-compliant (e.g., not marked appropriately) or there is evidence of a failure of a treatment, action may be taken

• Minimal impact should be pursued for such actions, which may include detention, removal of non-compliant material, treatment, destruction, or reshipment. An appendix also exists on this issue [added during revision]

• The NPPO of the importing country should notify the exporting (or manufacturing) country in cases where live pests are found. NPPOs are also encouraged to notify cases of missing marks and other cases of non-compliance [added during revision]

Annex I - Treatments• When a revised treatment schedule is adopted, wood packaging treated under

the previous treatment schedule does not need to be re-treated [moved during revision]

Bark removal [Added during revision]• Removal of bark is required in addition to other treatments, however :

– any number of small pieces of bark (less than 3 centimetres in width, regardless of the length) may remain

– bark pieces greater than 3 centimetres in width, with a total surface area of less than 50 square centimetres may also remain

Heat treatment• Heat treatment: minimum temperature of 56°C for a minimum of 30 continuous

minutes throughout the entire profile, including core [modified during revision]• Various energy sources or processes may be suitable for achieving the heat

treatment requirements, e.g., kiln-drying, chemical pressure impregnation, microwave, etc. [added during revision]

Annex I – Treatments (cont’d)Fumigation• NPPOs are encouraged to promote the use of the alternatives to methyl

bromide measures approved in this standard [added during revision]

• Bark removal must precede fumigation [added during revision]

• Treatment schedule now presented on basis of minimum CT (concentration-time product) over 24 hours [added during revision]

• Monitoring of concentrations must be carried out at a minimum at 2, 4 and 24 hours

• Original treatment schedule now presented as one example of how to achieve minimum CT requirements

• List of factors for maximising efficiency, efficacy and, to some extent, safety of fumigation for NPPOs to address presented [added during revision]

Annex 2 – Marking [Annex significantly modified during revision]• The ISPM No. 15 mark consists of:

– country code– producer code

treatment codes now removed]• More details provided on country and producer codes• More guidance and detail on the presentation of the mark, accompanied by several

examples of acceptable marks• For composite units of wood packaging comprising both treated and processed wood

material, the mark may appear on the processed wood components to ensure that the mark is visible and legible

• Dunnage requires special consideration as it may not be cut to final length until loading occurs. Options for ensuring that treated dunnage is marked appropriately include:– marking of dunnage along its entire length at very short intervals– additional marking of treated dunnage in a visible location after cutting

Appendix I – Secure disposal of non-compliant wood packaging

[Entirely new appendix added during revision]Contains and elaborates on the guidance on disposal originally presented in the body of standard• Non-compliant wood packaging material may require treatment or

secure disposal in order to prevent escape of pests• Optional secure disposal may be used when treatment is either not

available or is not desirable. Methods recommended include:- incineration- deep burial in sites approved by appropriate authorities- processing appropriately to eliminate pests - other effective methods endorsed by the NPPO

• Where required, secure disposal should be carried out with minimal delay

Appendix 2 – Guidelines for heat treatment

• Currently simply a ‘placeholder’ to identify that guidance on maximising efficiency and efficacy of heat treatment will be added to the standard

• No guidance is currently presented