On July 1, 2010 The AHC began a project funded by the Wood Education & Resource Center titled "Preparing for the Implementation of a Mandatory Phytosanitation Treatment for All Wood Packaging Material (WPM) in the U.S." This project was designed with a goal of assisting the domestic wood packaging material (dWPM) industry with understanding and implementation of expected USDA APHIS rules aimed at reducing the spread of invasive species, such as the emerald ash borer, via WPM.
The primary objective of the project, as originally proposed, was to publicize and promote awareness and understanding of the Proposed Rule to regulate WPM (Wood Packaging Material) in domestic interstate commerce to the WPM industry in the US, in an effort to engage the industry in providing input and comments to APHIS as the final rule was developed.
With the publication of the document “Risk Assessment for the Movement of Domestic Wood Packaging within the United States”, APHIS has concluded that a rule mandating phytosanitary treatment of WPM in domestic interstate commerce is not feasible at this time. However, APHIS still recognizes that domestic WPM represents a risk to a variety of valuable resources. Specifically stated by APHIS, - Despite its potential to transport pests, dWPM does not easily lend itself to regulation because the wood packaging industry is fragmented and of variable composition due to the large volume of dWPM. Domestic WPM is difficult to permanently track and it may become reinfested after treatment. In addition, the inability to distinguish between various potentially regulated (i.e., dWPM) pathways and non-regulated pathways (raw logs, railroad ties, etc.) creates confounding issues for regulation. For these reasons, development and implementation of efficacious regulatory oversight may not be feasible for dWPM. However, a variety of risk reduction mitigations could be applied on a voluntary or focused regulatory basis.
Given this situation, a revised scope of work was requested for the project. The revised scope of work’s primary goal is developing and implementing a strategy for the suggested voluntary mitigation that can minimize and even eliminate the need for a formal regulatory program of domestic WPM in the future. The revised work plan/task list is as follows:
1. Publicize APHIS's decision to forego a formal regulatory program for domestic WPM, that includes distribution through AHC listserve, AHC Phytosanitation website, and any other feasible outlet.
2. Develop a list of all possible mitigation strategies that can be cost effectively applied.
3. Convene a panel of WPM manufacturers to seek input on a voluntary mitigation strategy.
4. Seek collaborators to formulate, establish, promote, and implement a voluntary mitigation strategy, including NWPCA (National Wooden Pallet and Container Association, Pallet Enterprise magazine, APHIS and any other interested organization.5. Develop a draft voluntary mitigation strategy for review by collaborators and industry panel. Finalize the voluntary mitigation strategy based on input from collaborators and industry stakeholders.
6. Conduct a series of meetings, seminars, etc. around the eastern hardwood region to explain the overall situation, the benefits of a voluntary mitigation strategy, and the voluntary mitigation program developed with industry stakeholder input as part of this project. These will be focused on state forestry/industry association meetings and other pertinent venues. -- A minimum of 4 webinars will be offered during the grant period to discuss the mitigation strategies. Further, a minimum of 4 on-site seminars will be scheduled during the grant period to further discuss same and to promote awarenesst. These will be scheduled regionally, in part, to focus on WPM industry concentrations, such as Ohio. Attempts will be made to schedule these seminars as part of ongoing meetings by various state forestry associations, state forester association meetings, and state utilization personnel meetings.
7. Develop a general PowerPoint presentation that can be distributed to interested individuals and organizations to further promote awareness and engagement.
This posting along with a Listserv mailing concerning the change in the position of APHIS on regulating dWPM fulfils task 1. With APHIS declining to regulate dWPM there would seem to be no need for a mitigation strategy making task 2 more of a challenge. However, APHIS did make suggestions on voluntary practices the industry could follow. The change of scope for this project looks to best management practices (BMP’s) to accomplish two things. The first is to reduce the likelihood of future regulations by encouraging the industry to follow practices originating within the industry that will mitigate the spread of invasive species (such as segregating ash logs and wood followed by proper phytosanitation treatment and maintain an accurate paper trail). The second is based on the conclusion presented in the risk assessment that pooled pallets are less likely to spread invasive species than “white wood” pallets. The latter has the potential to result in an increase in the use of pooled pallets to the detriment of the white wood pallet industry – a key building block of the hardwood industry as a whole.
We have convened a panel of WPM manufactures and begun to take input from them, fulfilling task 3. Task 4 is underway and this posting seeks to encourage WPM stakeholders to get involved, helping find collaborators in order to move forward with task 4. As implied above, some BMP's have been implemented by forward thinking businesses. One of these is stringent separation of all ash logs and lumber from other wood species along with the paperwork. Ash wood used in WPM is treated at the higher level of 60O C for 60 minutes.
The APHIS risk assessment noted the positive aspects of "pooled pallets" (CHEP and PECO are the largest pooled wood pallet companies) for reducing the spread of invasive species. A problem arises with this strategy because it puts the "whitewood" pallet section of the industry at a disadvantage. Further, in 2010 the retail company Costco presented a mandate hit to all of its’ suppliers. Costco specified that, except for special instances, it would no longer accept stringer pallets after 2010 suggesting iGPS (the largest plastic pooled pallet company), CHEP, or PECO to its suppliers.
In response to this Pallet Logistics & Unit Load Solutions, Inc., doing business as 9BLOCTM, initiated a collaboration of pallet producers and recyclers and their customers working together to ensure delivery of exceptional pallets of high quality, performance and durability on an industry-wide basis. The 9BLOCTM paradigm is currently based, solely, on a block pallet design (diagram below) and either southern yellow pine or Douglas fir. The executive summary of the 9BLOCTM program can be viewed here.
The 9BLOCTM industry network will be composed of independent, mostly entrepreneurial individuals or companies (which have in the past produced most of the whitewood pallets), joining together to compete in the global supply chain market by providing high performance block wooden pallets and seamless logistic services to a vast number of firms, spanning a broad spectrum of industries. Theoretically, this will allow the whitewood section of the industry to compete on a more equal footing with iGPS, CHEP and PECO.