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Materials handling: U.S. Department of Agriculture seeks public comment on potential changes to wood packaging regulations

Lorie King Rogers, Associate Editor -- Logistics Management, 9/2/2009

WASHINGTON—The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) is seeking information from the public on potential approaches for dealing with the interstate movement of wood packaging material (WPM).  WPM includes crates, dunnage, wooden spools, pallets and packing blocks used in domestic trade.

Currently, APHIS regulates the movement of logs, lumber and other unmanufactured wood articles due to the presence of wood pests such as the Asian long-horned beetle (ALB) and the emerald ash borer (EAB) within specific areas of the United States.  The artificial spread of these pests has been linked to the domestic movement of WPM, and poses a potentially serious threat to U.S. agriculture and forests. APHIS is looking at ways to protect the environment without placing an unjustified strain on domestic commerce and shipping requirements. 

“We recognize this is an area that requires additional information,” said Andrea McNally, assistant director of public affairs at the APHIS. “We are in the initial stages of a fact finding mission that will help the APHIS determine whether or not to generate a proposal to modify the current regulations.” 

Wood packaging materials are used to ship nearly every type of commodity or product shipped domestically, including the 1.2 billion wooden pallets that are currently in circulation in the United States. Nearly 93% of all goods move on pallets, according to the National Wooden Pallet & Container Association (NWPCA), the trade association that represents the pallet industry.

International commerce is already regulated. In 2004 APHIS adopted ISPM 15, an International Plant and Phytosanitary Standard that requires all imported wood packaging to be fumigated or heat-treated before it is admitted into the United States.

One option under consideration is to apply that same regulation to domestic commerce, a move that is supported by industry groups like the NWPCA, according to Bruce Scholnick, president of NWPCA. “We believe that some kind of regulation is inevitable and it’s preferable to the state-by-state, piecemeal approach in place now,” Scholnick said. “It’s confusing to pallet users and is unfair to wood packaging companies in quarantine states.”

Uniform standards would remove the confusion and level the playing field for all domestic manufacturers of wood packaging materials. They also work. “In the five years since the ISPM 15 was adopted by more than 140 nations, it has proven to be 99.9% effective,” Scholnick said.

APHIS is seeking input on 13 questions, including comment on alternatives to methyl bromide to treat wood products. With that information, APHIS will prepare an environmental impact statement that will examine the potential impact these alternatives might pose to the human environment. 

According to APHIS’ McNally, the timetable for any next steps in the process is unclear. “Our actions will depend on the number and content of comments the APHIS receive,” she said. “That will determine if and when we go forward with drafting a proposal.”

Consideration will be given to comments received on or before October 26. 

Comments may be submitted online at www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=APHIS-2009-0016. All comments submitted here will be available for public viewing.

To submit comments in writing, send two copies to Docket No. APHIS-2009-0016, Regulatory Analysis and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road, Unit 118, Riverdale, MD 20737-1238.  Please state that your comment refers to Docket No. APHIS-2009-0016.

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