1. IPPC member consultations 2008 Steward: Greg Wolff
Draft Revision of ISPM No. 15, Regulating wood packaging material in international trade
IPPC member consultations 2008
Steward: Greg Wolff

2. 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

3. 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

4. Structure of the standard
Basis for Regulating
Regulated Wood Packaging Material (includes exemptions)
Phytosanitary Measures for Wood Packaging Material
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

5. 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]

6. 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]

7. 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]

8. 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]

9. 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]

10. 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]

11. 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]

12. 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]

13. 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]

14. 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]

15. 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

16. 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

17. 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