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TIMBER PRODUCTS September 2023 HT Newsletter Volume: 09/05/2023
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
Director of Wood Packaging
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.
Sound Wisdom from Thomas Sowell
“Some things are believed because they are demonstrably true. But many other things are believed simply because they have been asserted repeatedly—and repetition has been accepted as a substitute for evidence.”
“Some things must be done on faith, but the most dangerous kind of faith is that which masquerades as ‘science.’”
“It takes considerable knowledge just to realize the extent of your own ignorance.”
“I have never understood why it is ‘greed’ to want to keep the money you have earned but not greed to want to take somebody else's money.”
“Back in my old neighborhood, there was a special contempt for the kind of guy who was always trying to get two other guys to fight each other. Today, it is considered a great contribution to society to incite consumers against producers, tenants against landlords, women against men, and the races against each other.”
“It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong.”
“When people get used to preferential treatment, equal treatment seems like discrimination.”
"People who pride themselves on their ‘complexity’ and deride others for being "simplistic" should realize that the truth is often not very complicated. What gets complex is evading the truth.”
“Sometimes it seems as if there are more solutions than problems. On closer scrutiny, it turns out that many of today’s problems are a result of yesterday’s solutions.”
"If people in the media cannot decide whether they are in the business of reporting news or manufacturing propaganda, it is all the more important that the public understand that difference, and choose their news sources accordingly."
"Would you bet your paycheck on a weather forecast for tomorrow? If not, then why should this country bet billions on global warming predictions that have even less foundation?"
Stamp Care
Routine care is required to extend stamp life and ensure a legible mark is consistently being made that conforms to ALSC regulations. It is recommended to blow stamps off with compressed air routinely during use to remove sawdust and other material that can affect the quality of the application, For cleaning stamps, use mild soap and water and a soft-bristled brush (like a tooth brush). Place the brush in the soapy water and gently wash the stamp rinsing it with water once you have finished cleaning it. Soaking stamps is not recommended. If the stamp cannot produce a legible mark after cleaning, it should be removed from service and held for retrieval by your TP inspector.
MARKS RELATED TO ISPM 15 CONFORMANCE
There are three marks involved in the process of creating ISPM 15 conforming wood packaging material (WPM). When applied, each mark must be fully legible meaning all elements of the mark are capable of being read or distinguished. This includes the border for the IPPC mark. These three marks are described in greater detail below.
HT Mark
The HT mark identifies individual pieces of lumber or lumber components as being heat-treated in conformance with ISPM 15 standards. The mark contains a minimum of 3 elements; the facility identification (typically a number), the letters "HT" and the agency trademark. The HT mark must be legibly applied a minimum of one time per individual piece and 100% of pieces must be marked (with a few very specific and highly regulated exceptions). The mark serves to establish a chain of custody between the site that treated the raw materials and the facility that will certify finished WPM as ISPM 15 conforming. This mark is NOT recognized as a replacement for the IPPC mark.
IPPC Mark
The IPPC mark identifies multi-component WPM (i.e. pallets, crates, boxes, etc.) as being heat treated and debarked in compliance with ISPM 15 standards. In addition to the 3 elements of the "HT" mark, the IPPC mark also includes a country code and the IPPC "wheat" symbol. The IPPC mark should be legibly applied a minimum of 2 times on opposite sides of the WPM. These marks should be placed on the WPM so they can be easily seen by Customs if inspected. If the WPM is made up of solid and processed wood materials (i.e. engineered or corrugated board product), ISPM 15 states "where various components are integrated into a unit of wood packaging material, the resultant composite unit should be considered as a single unit for marking purposes. On a unit of wood packaging material made of both treated wood and processed wood material (where the processed component does not require treatment), it may be appropriate for the mark to appear on the processed wood material components to ensure that the mark is in a visible location and is of a sufficient size." To be safe, if you're dealing with a box where solid wood is used as an exterior frame place the IPPC mark on the solid wood frame and not the engineered or corrugated material. If solid wood is used as an interior frame, facilities should not only place IPPC marks on the outside of the box on the processed wood material, but also place marks on 2 pieces of wood opposite each other in the interior frame so Customs can also see IPPC marks on the solid wood frame in the box if it is opened at port.
IPPC DUN (Dunnage) Mark
The IPPC DUN (dunnage) mark typically identifies individual pieces of solid wood used for blocking or bracing as being heat-treated and debarked in conformance to ISPM 15 standards. The DUN mark includes all the elements of the standard IPPC mark but will also include the term "DUN" or "Dunnage" on it. This mark is required to be legibly and visibly placed once on each piece of dunnage. If treated wood is being sent as dunnage to another facility where it will require further cutting, the dunnage mark should be placed in a way where each cut piece would have a full mark displayed on it after cutting. Pieces of wood that do not include all the required elements of the DUN mark should not be used for dunnage. Examples where the dunnage mark would be permissible to use include where a wood piece is attached to opposite ends of a long corrugated pipe box, when bracing is employed in the back of a container or when a piece of wood blocking is used to prevent metal banding from marring equipment. DUN material can be misused and it is the manufacturing facility's responsibility to ensure their customer understands how dunnage can and cannot be used. If a facility provides dunnage to a customer who uses it to build multi-component wood packaging, it is a non-conformance on the facility who dunnage marked the wood for not ensuring the dunnage was properly used.
The 6" Rule
ALSC Wood Packaging Material Enforcement Regulations (November 6, 2020) section 5.6.9 states:
It is the policy of the ALSC that wood packaging facility quality marks, grade marks, grade stamps, labels, brands, certificates or other product description shall not misrepresent wood packaging products, in this program or outside it, including, but not limited to, reference to the IPPC standard directly or indirectly.
According to an ALSC statement; "ALSC has consistently interpreted this provision to mean (as is the case with lumber) that nonstandard grade names, web addresses, marketing language (the category a corporate logo would fall), and other similar information may only be shown on IPPC marked material if it is located at least 6 inches from the grade mark. This interpretation has been enforced by ALSC and accredited ALSC agencies historically without exception."
Further specific language for addition to the ALSC wood packaging regulations was intended to be on Board of Review agenda two years ago for approval, but was overlooked at that time. ALSC realized this and is planning to amend the Wood Packaging Enforcement Regulations to express this policy explicitly. Based on acceptance by the Enforcement Committee, the following sentence will be added to the section 5.6.9:
“Nonstandard grade names, web address, marketing language and other similar information may be shown on IPPC marked material if located at least 6 inches from the IPPC mark.”
ALSC wants facilities to understand that past enforcement of the 6" rule was required and this upcoming clarification in section 5.6.9 will ensure that there is no misunderstanding regardng the application of this standard by facilities or agencies.
This addition to the ALSC regulations will be voted on and likely incorporated into the regulations during the meeting in November. When that occurs, this requirement will be officially in the standard even though it is enforced now.