Customs - Wood Packaging Materials Wednesday, September 23, 2009 The Animal and Plant Health Inspection Service (APHIS) of the U.S. Department of Agriculture is seeking public comments on regulatory options relating to wood packaging material (WPM) used in domestic commerce. Examples of products using such material include crates, dunnage, wooden spools, pallets, packing blocks, etc. The primary objective of current regulations is to decrease the risk of the artificial spread of plant pests such as the emerald ash borer and the Asian longhorned beetle. APHIS has also announced its intent to prepare an environmental impact statement on various potential pest mitigation measures, and seeks comments on that issue as well. The importation of certain types of WPM has been linked to plant pest problems. According to APHIS, the variety of woods and lumber qualities used in the construction of WPM make it susceptible to infestation by a wide range of pests and diseases. Because of that linkage, current regulations restrict the importation of many types of wood articles (see 7 C.F.R. 319.40-1 through 319.40-11). Additionally, regulations in 7 C.F.R. Part 301 contain domestic quarantine requirements for wood pests. Such regulations affect the movement within the United States of logs, lumber, and other unmanufactured wood articles. Quarantine requirements governing movement of WPM vary significantly for different pests, creating a potentially confusing regulatory framework that may present challenges to industry. As a result, APHIS is exploring the development of uniform measures to govern interstate movement of all WPM, in order to facilitate greater comprehension and compliance. APHIS states that it seeks to maximize protection against the spread of plant pests without placing unjustified burdens on domestic commerce and shipping requirements. Specifically, APHIS seeks comments on regulatory options regarding: - The establishment of uniform requirements for domestic handling of WPM, including the feasibility of implementing International Plant Protection Convention treatment standards; - Whether the adoption of “pallet pooling” practices would help to provide sufficient mitigation of pest risks; - Alternative treatments to methyl bromide that could be used to reduce the risk of WPM contributing to the spread of various plant pests; - The potential impacts of increased use of alternative packaging materials such as plastic pallets and/or processed wood; - Whether and how alternative WPM treatment methods could help address environmental concerns, particularly with regard to ozone depletion; and - If treatment of some kind were to be required for all WPM moved interstate, whether the industry would need a phase-in period to allow adaptation time. Note that additional regulatory measures and/or any environmental impact statement would be independent of specific WPM movement restrictions and treatment requirements currently contained in 7 C.F.R. Part 301. Comments on this matter must be received by APHIS on or before October 26, 2009. << view all Alerts and Bulletins