Worldwide Study Confirms ISPM#15 is not Protecting Forests – What Do We Do Now About Pests in Wood Packaging?

 

You know that the continuing pest risk associated with imports of wood packaging is among my biggest concerns. See, for example, fact sheets here and blogs here and here.

A new book about the family Cerambycidae (edited by Wang 2017; reference at end of blog) confirms that longhorned beetles continue to be introduced to many countries via this pathway, more than a decade after widespread implementation of the international standard governing wood packaging (ISPM#15). Furthermore, data from several countries confirm that China continues to fall short … but that problems are more widespread.

The Wang book finds that 16 outbreaks of the Asian longhorned beetle (ALB) were detected between 2012 and 2015.

Unless otherwise noted, the information provided here comes largely from the book’s chapter on biosecurity coauthored by Dominic Eyre and Robert A. Haack (see link below). Opinions stated are mine, unless specified otherwise.

In some cases – which I will note – further details are from my earlier posts.

While I think the risk of introduction of highly damaging pests via the wood packaging pathway is well documented in Wang (2017) and other publications, no one can truly quantify this risk because of shortcomings in countries’ data. Available data come primarily from countries’ records of pest “interceptions” – usually at points of entry.  However, interception data are inadequate to conclusively establish the lack of a threat for a particular trade or to provide a fair comparison of the relative threat of particular trades. Most interception databases have the following shortcomings (Eyre and Haack are summarizing points made by a third scientist – Lee Humble – in an earlier article):

(1) interception databases are not based on random sampling, which is necessary to measure the “approach” or “infestation” rate;

(2) inspections which find no pests are not recorded, so we cannot know what proportion of incoming shipments are infested;

(3) once inspectors have discovered a quarantine pest in a shipment, the consignments may be destroyed without further inspection, and thus other exotic organisms can be missed;

(4) only a small percentage of individual shipments are inspected; and

(5) organisms often are not identified to species due to difficulty of identifying larvae.

Furthermore,

(1) trade volumes and sources can change rapidly;

(2) the number of consignments inspected varies from year to year in response to national and regional plant health and wider government priorities;

(3) the method and intensity of quarantine inspections can vary within and among countries and as well as over time; and

(4) different proportions of consignments from different trades can be inspected, reflecting the perceived quarantine risks of each trade.

Still, scientists try to analyze the available data because propagule pressure may be the most important factor in determining whether an exotic pest becomes established.

What have they found?

Data from both the United States and Europe document that problems of non-compliance continue in recent years – more than a decade after adoption of ISPM#15.

United States:

  • Since APHIS interception records began being computerized in 1985, Cerambycidae have been among the most frequently intercepted insect families associated with wood products and packaging. The top five countries for infested shipments during the period 1984 – 2008 were China, Italy, Mexico, Turkey and Spain. A country’s rank is linked in part to import volumes – which are very high for China, Canada, and Mexico. Because the  U.S. inspects very limited quantities of wood packaging from Canada, its absence from the top five may be misleading [discussed in my blog from February, here.

Another factor explaining these countries’ rankings is the continued – in fact increasing! – presence of pests in wood packaging accompanying imports of tile and quarry products (e.g., marble, slate). Many of these imports are from Italy, Spain, and Mexico. Interceptions on these imports increased significantly from the mid-1990s to 2008. The increase in these interceptions is most alarming because it shows USDA leaders have not yet taken effective action to curtail this risk, despite its being evident since record-keeping began.

 

  • Over the period Fiscal Years 2010 through 2016, the U.S. Bureau of Customs and Border Protection has detected nearly 5,000 consignments in which cases the wood packaging harbored a pest in a regulated taxonomic group. APHIS experts identified 2,500 insects taken from wood packaging during this period; a quarter were Cerambycids. A second APHIS analysis of a subset of the wood packaging-associated insects found examples from 39 countries, including 212 shipments from Europe; 130 shipments from Asia; and 341 shipments from the Americas – almost exclusively Mexico. [These detections are discussed in my blog from February, here.

 

Europe has had a similar experience.

  • Interception records included in EUROPHYT show 306 Cerambycidae interceptions on wood packaging over the period 1998 – 2013. The number of interceptions recorded in 2012 and 2013 are double those of all previous years. Each year, the majority are on wood packaging from China.
  • Most interceptions of ALB (distinct from detections of establishments) have occurred after the shipment cleared border inspection procedures, e.g., in warehouses.
  • As with the U.S., while the majority of non-compliant shipments are from China, the problem is worldwide: Europe has also found various species of longhorned beetles in wood packaging from various European countries (inside and outside the European Union), other Asian countries, Africa, Australasia, and the Americas.
  • Austria inspected 451 consignments of stone imports received April 1, 2013 – April 14, 2014. Forty-four consignments (9.8%) were found to be out of compliance with ISPM#15. Live Cerambycidae were found in 38 consignments (8%), including ALB. This finding confirms the widespread awareness that stone imports rank high for non-compliant wood packaging.

 

Regulatory Authorities’ Response (or lack thereof)

Europe

  • Since March 31, 2013, the European Union has required inspection of 90% of consignments of slate, marble, and granite and 15% of consignments of two other categories of stone imports.

CBP agriculture specialists in Laredo, Texas, examine a wooden pallet for signs of insect infestation. [Note presence of an apparent ISPM stamp on the side of the pallet] Photo by Rick Pauza
United States

  • As noted by Haack et al. (2014) (reference below), as of 2009, approximately 13,000 containers harboring pests probably enter the U.S. each year. That is 35 potential pest arrivals each day. [This issue is also discussed in the fact sheet and blogs here and here.
  • The United States has not specified an obligatory inspection rate for such high-risk imports as stone and tile. Instead, it relies on Customs and Border Protection to target import shipments suspected of being out of compliance based on past performance of importers, suppliers, and types of imports.
  • Several relevant issues are discussed in the blog in February 2017 (second blog linked to above). First, I noted that the U.S. Department of Homeland Security Bureau of Customs and Border Protection – over the seven-year period Fiscal Years 2010 through 2016 – has detected nearly 5,000 cases of wood packaging harboring a pest in a regulated taxonomic group. Comparing the estimate by Haack et al. 2014 with the CBP data indicates that Customs is detecting about 6% of all pest-infested shipments.
  • Furthermore, about 26% of infested wood pieces detected by CBP were found in wood that was marked as having been treated according to ISPM#15 requirements. What does this mean? Fraud? Accidental misapplication of the treatments? Or are the treatments less effective than hoped? What are USDA and other responsible agencies doing to clarify the causes?
  • CBP staff reported that only about 30 import shipments (out of nearly 21,000 shipments found to be in violation of ISPM#15 requirements) have received a financial penalty. How can USDA and Customs officials justify this failure to enforce the regulations?

 

 

What Can Be Done to Close Down the Wood Packaging Pathway

 

I suggest that our goal should be to hold foreign suppliers responsible for complying with ISPM#15. One approach is to penalize violators. APHIS and Customs might

  • Prohibit imports in packaging made from solid wood (boards, 4 x 4s, etc.) from foreign suppliers which have a record of repeated violations over the 11 years ISPM#15 has been in effect (17 years for exporters from Hong Kong & mainland China). Officials should allow continued imports from those same suppliers as long as they are contained in other types of packaging materials, including plastic, metals, or fiberboards.
  • Fine an importer for each new shipment found to be out of compliance with ISPM#15 in cases when the foreign supplier of that shipment has a record of repeated violations.

 

There would need to be a severe penalty to deter foreign suppliers from simply changing their names or taking other steps to escape being associated with their violation record.

 

At the same time, the agencies should work with non-governmental organizations and importers to promote creation of an industry certification program that would recognize and reward importers who have voluntarily undertaken actions aimed at voluntarily exceeding ISPM#15 requirements so as to provide a higher level of protection against invasive species that would otherwise potentially be introduced into the United States.

 

What You Can Do

  • Tell your member of Congress and Senators that you are worried that our trees are still being put at risk by insects arriving in wood packaging. Ask them to urge the USDA Secretary Sonny Perdue to take the actions outlined above in order to curtail introductions of additional tree-killing pests.
  • Talk to your friends and neighbors about the threat to our trees. Ask them to join you in communicating these concerns to their Congressional representatives and Senators.
  • Write letters to the editors of your local newspaper or TV news station.

 

Use your knowledge about pests threatening trees in your state or locality in your communications!

 

Other Introduction Pathways for Cerambycids

tree removals in Tukwilla, WA to eradicate citrus longhorned beetle; photo by Washington State Department of Agriculture

Plants for planting

Other studies have confirmed that importation of living plants (called by regulators “plants for planting”) is a high-risk pathway for introducing tree-killing pests. See the Eyre and Haack chapter for a summary.

This is as true for highly damaging Cerambycids as for other types of plant pests. One of the most damaging is the citrus longhorned beetle (CLB) (Anoplophora chinensis). CLB [https://www.dontmovefirewood.org/invasive-species/] poses an even greater threat to North American forests than ALB – it has a wider host range and climate-matching models show that it could establish across most of the United States. CLB were detected in a nursery in Tukwilla, Washington, in 2001; the pest was eradicated. Nine CLB outbreaks have been detected in Europe; three are considered eradicated (Eyre & Haack 2017).

Eyre and Haack (2017) report that in Europe of the 455 Cerambycidae intercepted over the period 1998 – 2013, 54 were on imported in living plants. These included probably 49 citrus longhorned beetle (CLB). Most were detected primarily on maple nursery stock that originated China (32), with smaller numbers from other countries, including Netherlands (8), and Italy (where CLB has been established).

New Zealand has intercepted 74 CLB on plants for planting over the 28 year period 1980 – 2008.  One third of this total was intercepted in 2008.

 

Authorities’ Responses (or lack thereof)

Europe

  • Since 2012, the European Union has required that 10% of CLB host plants imported into the European Union should be destructively sampled (that is, dissected to see whether insects are present internally).
  • This requirement supplements a broader requirement that plants for planting be treated as a high risk commodity. Member states are required to inspect all incoming P4P consignments. This requirement is, however, undermined by much more lenient requirements regarding movement of plants among EU member states – some genera are not regulated … others are controlled by Plant Passports – an industry-led scheme.  [For more on this issue, see my blog from October 2016 here.

 

United States

  • APHIS issued a Federal order tightly restricting imports of CLB hosts from Europe in 2013 – four years after a CLB outbreak was detected in a part of the Netherlands which is a center for the production of hardy ornamental nursery stock for European and probably American markets.
  • APHIS proposed to revise its overall plant importation regulations (the “Q-37 regulations) to rely more on integrated management by the exporting nurseries in contrast to port inspections. This rulemaking has stalled. [See my blog about this here.]

 

Finished Wood Products

While no country is keeping comprehensive records, finished wood products have transported longhorned beetles.  Eyre and Haack (2017) concluded that upholstered furniture presents one of the highest risk among the finished wood products – partly because imports are rising rapidly, partly because insect-damaged wood can be hidden under the upholstery. New Zealand found that some Asian manufacturers place good quality wood on visible surfaces and poor quality timber (insect damaged and bark covered) in internal sections. Officials inspected 49 couches and found that 30 had wood with bark, 19 had insect contaminants, and 32 had visible insect damage. Fungal samples were isolated from 11 of the couches. They found 4 longhorned beetles.

 

References

Wang, Q. (Ed.). 2017. Cerambycidae of the world: biology and pest management.  Boca Raton, FL: CRC Press

The chapter on biosecurity is available here:  http://treesearch.fs.fed.us/pubs/54552

A chapter on Cerambycid impacts in urban and rural forests is available here: http://treesearch.fs.fed.us/pubs/54543

 

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

 

Posted by Faith Campbell

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