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TIMBER PRODUCTS December 2019 HT Newsletter Volume: 12/05/2019
Online Newsletter
Matt McGowan - WPM Program Manager
mmcgowan@tpinspection.com
mmcgowan@tpinspection.com
Office: 770.785.4769
Mobile: 678.480.2451
Mobile: 678.480.2451
For more information on the IPPC program
Please contact:
Matt McGowan
WPM Program Manager
Peachtree City GA
Office 770.785.4769
Mobile 678.480.2451
The unauthorized and/or fraudulent use of the TP IPPC mark is illegal and a situation we take seriously. Anyone with information regarding the misuse of IPPC marks should contact TP's WPM Manager immediately. Thank you for helping to protect the integrity of the ISPM 15 program which is vital to our business and economy.
Christmas Thoughts
Christmas is the spirit of giving without a thought of getting. It is happiness because we see joy in people. It is forgetting self and finding time for others. It is discarding the meaningless and stressing the true values. Thomas S. Monson
There is no better time than now, this very Christmas season, for all of us to rededicate ourselves to the principles taught by Jesus the Christ. It is the time to love the Lord, our God, with all our heart - and our neighbors as ourselves. Thomas S. Monson
For it is in giving that we receive. Francis of Assisi
We wish everyone a very Merry and Blessed Christmas and a Happy New Year! We will be closed on the following dates to enjoy the holidays with our families:
December 24th and 25th
December 31st and January 1st
We will reopen for business as usual on January 2nd. We are thankful for the privilege to be of service to all our clients.
Concerns with Pallet Recyclers Not in the ALSC Program
There are many concerns by ALSC licensed recycling facilities regarding those recyclers not in the ALSC program shipping IPPC marked pallets into the marketplace and representing them as IPPC conforming. Can they legitimately do this?
The short answer is no. If a recycler is not being monitored by an accredited agency with ALSC for ISPM 15 conformance, then they cannot represent pallets they are selling as IPPC conforming unless they have documentation that the pallets were retreated by an ALSC monitored heat treating facility.
What if they use exempt material to repair pallets (i.e. plywood) or simply employ a reuse (passthrough) program?
ISPM 15 Section 4.1 states:
"Treatment and application of the mark (and/or related systems) must always be under the authority of the NPPO. NPPOs that authorize use of the mark have the responsibility for ensuring that all systems authorized and approved for implementation of this standard meet all necessary requirements described within the standard, and that wood packaging material (or wood that is to be made into wood packaging material) bearing the mark has been treated and/or manufactured in accordance with this standard. Responsibilities include:
- Authorization, registration and accreditation, as appropriate
- Monitoring treatment and marking systems implemented in order to verify compliance (further information on related responsibilities is provided in ISPM 7 (Phytosanitary certification system))
- Inspection, establishing verification procedures and auditing where appropriate (further information is provided in ISPM 23 (Guidelinesfor inspection)).
The NPPO should supervise (or, as a minimum, audit or review) the application of the treatments, and authorize use of the mark and its application as appropriate. To prevent untreated or insufficiently/incorrectly treated wood packaging material bearing the mark, treatment should be carried out prior to application of the mark."
The USDA interprets this as any processes employed by a facility in order to represent pallets as ISPM 15 conforming must meet the monitoring criteria to verify conformance. This includes the use of exempt material to repair wood packaging or the implemention of a passthrough program. Facilities not monitored in the IPPC program are not authorized or approved to implement the ISPM 15 standard and cannot represent what they are shipping as IPPC conforming wood packaging eligible for international trade. Such acts are fraudulent and can be subject to fines and penalties if caught and convicted.
How are violators caught and held accountable?
Many times this occurs at the overseas port where an interception (discovery of evidence of evasive pests) is made. The USDA will be given information on the U.S. exporter of the IPPC marked pallets and are then able to trace these pallets back to the original wood packaging provider. If the provider is found not to be in the program, the USDA will pursue criminal charges against the operation. In these situations, the USDA has successfully prosecuted violators noting that "violations of ISPM 15 requirements under the Plant Protection Act have resulted in a variety of enforcement actions, including an administrative decision and order, civil penalties of as much as $100,000, and federal felony convictions."
The USDA also warns exporters purchasing IPPC marked wood packaging from unmonitored operations that, "the alteration and distribution of certified wood packaging material is noncompliant with the APHIS regulations and ISPM 15. US exporters using such materials expose themselves to international fees, fines, and possible bans by our trading partners. Repair and re-manufacture companies producing and distributing noncompliant wood packaging material could be held liable by the exporter and/or prosecuted by the Department of Justice."
Recyclers participating in the IPPC program can rest assured knowing that the USDA takes a serious stance against facilities that choose to disregard ALSC and ISPM 15 requirements to legally ship IPPC marked pallets and will take legal action whenever possible.