Bug problems of the non-Y2K kind

By John V. Currie -- Logistics Management, 2/1/2000

In this age of global commerce, it's easier than ever to ship things around the world. Sometimes, it's too easy--as evidenced by the unwelcome exchange of non-native species of plants and animals with our trading partners. Alien species have done irreparable harm to ecosystems into which they have accidentally or illegally been introduced.

Last year, the U.S. Department of Agriculture (USDA) identified a harmful "hitchhiker" called the Asian long-horned beetle, which had made its way from China to the United States by boring into wood used for dunnage or pallets. These "boring" visitors took up residence in hardwood trees in or near cities where infested cargo was discharged, and they have had a devastating effect on trees in those areas.

What does this have to do with hazardous materials? In order to stem the influx of the insect and its larvae, the USDA requires that containers or cargoes that contain wood from China, including pallets or dunnage, be fumigated with a poison gas. Because containers that have been fumigated contain poisonous vapors or gases, they must be transported on oceangoing vessels as hazardous cargo and must be listed on the dangerous cargo manifest. Shippers are required to display a sign on the container doors that warns against entry until the container has been ventilated.

One of the authorized fumigation options is to permeate the container and its wood materials with methyl bromide, a toxic gas. Recently the Animal and Plant Health Inspection Service (APHIS) has detected high levels of methyl bromide residue in shipping containers arriving from the People's Republic of China. The agency has said that this poses a health hazard to its inspectors. As a result, the regulations now require that fumigated containers be aerated to bring the concentration of the fumigant below hazardous levels.

But that's not the end of it. The government of the People's Republic of China now has charged that an insect called the pinewood nematode is finding its way into China from Japan and the United States in wood or lumber derived from conifers such as pine, hemlock, spruce, and fir. Therefore, it has issued new rules that require solid wood packing materials (including bracing and dunnage material) made from coniferous trees to be heat-treated and certified before it enters China.

The exporter must complete a "Certificate of Heat Treatment" and have it endorsed by a USDA-APHIS Plant Protection and Quarantine Office. If there is no conifer wood in the shipment, shipping papers may contain declarations such as "This shipment contains no solid wood packing material" or "The solid wood packing material in this shipment is not coniferous wood." If a certificate does not accompany the shipment, Chinese authorities may return it to the United States, separate the cargo from its packing material and repack it at the importer's expense, or destroy both the shipment and the packing materials.

Countries that now mandate treatments to eliminate wood-borne pests now include the United States, Canada, Japan, New Zealand, Australia, and China. Undoubtedly the list will grow. Shippers, carriers, forwarders, freight handlers, and all others who may have reason to enter the confined space of a fumigated freight container should be aware of the health hazards resulting from these pest-control activities.

John V. Currie has taught hundreds of college courses, industry training programs, and public seminars on hazardous-materials transportation management and regulatory compliance. His firm, Currie Associates Inc., provides safety and compliance audits, consulting services, customized training manuals, and public and in-house seminars. He may be contacted at 1118 Bay Road, Lake George, NY 12845. Phone: (518) 761-0668. E-mail: mail@currieassociates.com. Web site: www.currieassociates.com.