Category: wood packaging

Here we go again … another Asian longhorned beetle population established in the U.S.

For the ninth time in 24 years, the Asian longhorned beetle (ALB) has been found in North America – this time in South Carolina.

This means thousands – perhaps tens of thousands – of trees will be removed. Thousands more will be injected with imadacloprid. Millions of dollars will be spent. There will be uncounted aesthetic and spiritual losses. There will be unmeasured damage to at least the local environment – which probably includes bottomland hardwood forests – protection of which South Carolina has declared to be a conservation priority. All this destruction is necessitated by the need to prevent catastrophic damage to North America’s hardwood forests by the ALB.

By early August I have learned that the South Carolina outbreak has been present for seven years or longer, and that it might be related to the Ohio outbreak (which was detected in 2011 but was probably introduced at least four years earlier). APHIS reports that, as of the end of July, nearly 1,300 infested trees had been detected. The area around the neighborhood where the detection was made is swampy – complicating search and removal operations and probably home to many box elder and willows – preferred hosts for the ALB.

Why did we let this happen? Why do we persist with a policy that has allowed repeated introductions of this pest via the well-documented wood packaging pathway? After all, we learned about this risk 22 years ago – after the ALB introductions to New York and Chicago. We have had plenty of evidence that the policy is failing. We know how to stop this. Why do we – through our elected and appointed government officials – not act to prevent it?

What We Need: a New, Protective Policy

With live pests continuing to be present in wood packaging 14 years after the U.S. and Canada imposed the treatment requirements in ISPM#15 – and 21 years after we required China to treat its wood packaging – we urgently need better federal policy. I have long advocated:

• USDA APHIS join Bureau of Customs and Border Protection in penalizing violators for each violation; stop allowing five violations over a 12-month period before applying a penalty.
• APHIS and the Canadian Food Inspection Agency (CFIA) should apply their rights under Section 5.7 of the World Trade Organization Sanitary and Phytosanitary Agreement to immediately prohibit China from packaging its exports in wood. China can use crates and pallets made from such alternative materials as plastic, metal, or oriented strand board.
• APHIS and CFIA should being the process of supporting permanent application of this policy to China and other trade partners with poor compliance records. This step would require that they cite the need for setting a higher “level of protection” and then prepare a risk assessment to justify adopting more restrictive regulations.
• USDA Foreign Agriculture Service (FAS) should assist U.S. importers to determine which suppliers reliably provide wood packaging that complies with ISPM#15 requirements.
• USDA FAS and APHIS should help importers convey their complaints about specific shipments to the exporting countries’ National Plant Protection Organizations (NPPOs; departments of agriculture).
• APHIS should increase pressure on foreign NPPOs and the International Plant Protection Convention more generally to ascertain the reasons ISPM#15 is failing and to fix the problems.
• APHIS should fund more studies and audits of wood packaging to document the current efficacy of the standard, especially
  • Update the Haack study of pest approach rate.
  • Determine whether high rates of pest infestation of wood bearing the ISPM#15 mark results from fraud or failures of treatment – and whether any failures are due to mistakes/misapplication or shortcomings in the treatment themselves.
  • Allocate the risk among the three major types of wood packaging: pallets, crates, and dunnage. 

See also the recommendations of the Tree-Smart Trade program at www.tree-smart-trade.org

Tree-Smart also has a Twitter account: @treeSMARTtrade

Justification

The ALB poses a threat to 10% of US forests and nearly all of Canada’s hardwoods, so eradication of the South Carolina outbreak is essential. For a longer discussion of ALB introduction history, the threat, and eradication efforts to date, visit here. https://www.dontmovefirewood.org/pest_pathogen/asian-long-horned-beetle-html/).

Another ALB Outbreak in the US: No Surprise

This Chinese insect is a world traveler. It has been detected 36 times outside its natural range: in North America, Europe, and Japan. Seventeen of these outbreaks have been detected since 2012 (Eyre & Haack 2017). These 17 introduction have occurred six years or later after the 2006 implementation of the International Standard for Phytosanitary Measures (ISPM) #15 – which was intended to reduce the likelihood of such introductions. .Ten of the outbreaks have been eradicated (Eyre & Haack 2017; APHIS press release October 2019).  This includes four in the United States and Canada; see here.

Despite U.S. and international efforts, ALB and related pests have been detected continuously in imported goods. U.S. and European data (Eyre and Haack 2017) document rising numbers of Cerambycids detected in wood packaging in recent years. (For a description of pest prevention efforts, see Fading Forests II and III here and this blog).

It is also not surprising that the newly introduced pest is from China. It has long been among countries with the worst records on implementing ISPM#15. 

The APHIS-CBP joint study of pest interceptions over the period 2012 – 2017 (Krishnankutty et al. 2020b) found the highest numbers of interceptions came from Mexico, China, and Turkey. During the period 2011 – 2016, China accounted for 11% of interceptions (APHIS interception database – pers. comm. January 2017).

These numbers reflect in part the huge volumes of goods imported from China. But China’s poor performance has continued, perhaps even increased in recent years. For example, consider the choice of wood used to manufacture packaging. Authorities recognized by the late 1990s that wood from plantations of Populus from northern China was highly likely to be infested by the Asian longhorned beetle. Yet, more than a dozen years later, this high-risk wood was still being used: between 2012 and 2017, the ALB was intercepted six times in wood packaging made of Populus wood – each time originating from a single wood-treatment facility in China (Krishnankutty et al. 2020b).

The location just outside Charleston also is not a surprise. Charleston ranked seventh in receipt of incoming shipping containers in 2018. Charleston received 1,022,000 containers, or TEUs measured as 20-foot equivalents, in 2018 (DOT report). This was a 14% increase over the 894,000 TEUs in 2017 http://www.marad.dot.gov/MARAD_statistics/index.html – click on “trade statistics”, then “US Waterborne trade” (1st bullet).  I expect decreased import volumes in 2019 and 2020 due to the tariffs/trade war and the 2020 economic crash linked to the Covid-19 virus.

Why US and International Policy Still Fails

Leung et al. (2014) estimated that implementation of the International Standard of Phytosanitary Measures (ISPM)#15 resulted in only a 52% reduction in pest interceptions. They concluded that continued implementation at the 2009 level of efficacy could triple the number of wood borers established (not just intercepted) in the U.S. by 2050.

Since 2010 the Department of Homeland Security’s Bureau of Customs and Border Protection (CBP) has found an average of 794 shipments infested by pests each year (Harriger). In 2019 specifically, live pests were found in 747 shipments (Stephen Brady, CBP, April 2020). These violations were occurring four to 13 years after the U.S. began implementing ISPM#15 in 2006. According to my calculations, based on estimates of pest approach rates by Haack et al. (2014), these detections probably represented about eight percent of the total number of infested shipments entering the country each year.

And there are good reasons to think this estimate is low. First, Haack et al. (2014) did not include imports from China, Canada, or Mexico in their calculations. Both China and Mexico rank high among countries with poor compliance records. Second, Haack and Meissner based their calculations on 2009 data – 11 years out of date. Since 2009, ISPM#15 has been amended to make it more effective. The most important change was restricting the size of bark remnants that may remain on wood. Also, countries and trading companies have 11 more years of implementation – so they might have improved their performance. I have asked several times that APHIS commission a new analysis of Agriculture Quarantine Inspection Monitoring data. We all need an up-to-date determination of the pest approach rate, not only before but also after the CBP action. Without it, there’s no evidence whether the more aggressive enforcement stance CBP adopted in 2017 (see below) has led to reductions in non-compliant shipments at the border.

Another demonstration of the failure of ISPM#15 is the repeated presence of the velvet longhorned beetle (Trichoferus (=Hesperophanes) campestris) in wood packaging and its establishment in at least three states (Krishnankutty, et al. 2020a; also see the discussion in my recent blog here).

Astoundingly, data indicate that 97% of wood packaging infested with pests bears the stamp certifying that the wood has been treated according to the requirements of ISPM#15 – and hence should be pest-free (Eyre et al. 2018; CBP interception data). In other words, the presence of the stamp is not a reliable indicator of whether the wood has indeed been treated nor that it is pest-free. Scientists have speculated for years why this is the case. ALB’s new arrival provides an impetus to finally answer this question and to ensure policy reflects the answer.

What Federal Agencies Are Doing to Better Prevent Introductions

In contrast to such a comprehensive approach, this is what changes are under way.

CBP strengthened its enforcement in November 2017. The agency’s total “enforcement actions” increased by 400% from 2017 to 2018 (Sagle, pers. comm). The 2019 data show decreases, in absolute numbers, from earlier years in all categories: a 19% decrease below 2010-2018 in average number of shipments intercepted; a 13% decrease in number of shipments intercepted because the wood packaging lacked the ISPM#15 mark; and a decrease of 6% in the number of shipments intercepted that had a quarantine pest (Stephen Brady, CBP, April 2020). However, one year of interception data do not provide a basis for saying whether CBP’s stronger enforcement has resulted in a lower number of shipments in violation of ISPM#15 approaching our shores. Again, I call for APHIS to repeat Haack et al. (2014) study.

Harriger reported that CBP is also trying harder to educate importers, trade brokers, affiliated associations, CBP employees, and international partners about ISPM#15 requirements. CBP wants to encourage them to take actions to reduce all types of non-compliance: lack of documentation, pest presence in both wood packaging and shipping containers, etc.

APHIS has not altered its long-standing policy of allowing an importer to rack up five violations over a 12-month period before imposing a penalty. Instead, APHIS has focused on “educating” trade partners to encourage better compliance. For example, APHIS worked with Canada and Mexico – through the North American Plant Protection Organization — to sponsor workshops for agricultural agencies and exporters in Asia and the Americas

APHIS also planned to host international symposia on wood packaging issues as part of events recognizing 2020 as the International Year of Plant Health. These symposia have been postponed by travel and other restrictions arising from the coronavirus pandemic.

The Broader Significance of Continuing Wood Packaging Problems

The premise of the international phytosanitary system – the Agreement on the Application of Sanitary and Phytosanitary Standards (SPS Agreement) and the International Plant Protection Convention (IPPC) – is that importing countries should rely on exporting countries to take the actions necessary to meet the importing countries’ plant health goals. The ISPM#15 experience undermines the very premise of these international agreements.

If we cannot clean up the wood packaging pathway – which involves boards or logs that are, after all, already dead – it bodes poorly for limiting pests imported with other commodities that are pathways for tree-killing pests – especially living plants (plants for planting). Living plants are much more easily damaged or killed by phytosanitary measures, so ensuring pest-free status of a shipment is even more difficult.  (A longer discussion of the SPS Agreement and IPPC is found in Chapter III of Fading Forests II, available here.

SOURCES

Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)

Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the US. PLoS ONE 9(5): e96611.

Kevin Harriger, US CBP. Presentations to the annual meetings of the Continental Dialogue on Non-Native Forest Insects and Diseases over appropriate years. See, e.g., https://continentalforestdialogue.org/continental-dialogue-meeting-november-2018/

Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020a. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera:) in the United States. Annals of the Entomological Society of America, XX(X), 2020, 1–12

Krishnankutty,  S., H. Nadel, A.M. Taylor, M.C. Wiemann, Y. Wu, S.W. Lingafelter, S.W. Myers, and A.M. Ray. 2020b. Identification of Tree Genera Used in the Construction of Solid Wood-Packaging Materials That Arrived at U.S. Ports Infested With Live Wood-Boring Insects. Commodity Treatment and Quarantine Entomology

Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org

Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory

USDA APHIS interception database – pers. comm. January 2017.

USDA APHIS press release dated September 12, 2018

U.S. Department of Agriculture, Press Release No. 0133.20, January 27, 2020

U.S. Department of Transportation, Maritime Administration, U.S. Waterborne Foreign Container Trade by U.S. Customs Ports (2000 – 2017) Imports in Twenty-Foot Equivalent Units (TEUs) – Loaded Containers Only at https://ops.fhwa.dot.gov/freight/freight_analysis/nat_freight_stats/docs/06factsfigures/fig2_9.htm and

US Department of Transportation. Port Performance Freight Statistics in 2018 Annual Report to Congress 2019  https://rosap.ntl.bts.gov/view/dot/43525

Posted by Faith Campbell

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.

Setting Priorities for Surveillance

Despite Customs and Border Protection’s heroic efforts to target inspection of wood packaging shipments, based on histories of non-compliance of specific importers’ wood packaging (which I have often praised), the majority of larvae occurring in wood packaging would probably not be intercepted by inspectors. Instead, they would be transported to the cargo’s intended destinations (Wu et al. 2020). I described these problems in the preceding blog about the velvet longhorned beetle (VLB).

As I have noted in the past, CBD detects an average of 800 shipments per year with non-compliant wood packaging. That figure is less than five percent of the 16,500 infested shipping containers that might enter the country each year, based on the estimate by Haack et al., (2014) that one tenth of one percent of incoming wood packaging might be infected.

So there is always a need to improve surveillance for pests that inspection fails to catch. We can do that in at least the following ways:

1) better target detection efforts on the most likely areas where a pest might establish

2) improve collection and use of pest-related information to determine probable hosts, pathways of movement, and potential impacts.

Discovering How the Pest Moves

Sometimes improvements must be linked to individual species – although assisted by knowledge about species with similar life histories, e.g., similar hosts or flight periods or about its close relatives (see Ray’s development of a VLB lure; full citation at end of this blog).  

Other times, improvements might result from more generalizable adjustments.

For example, the pathway analysis undertaken by Krishnankutty and colleagues is one approach to improving geographic targetting. They analyzed aspects of  the velvet longhorned beetle’s pathways of introduction: 1) the types of imports associated with VLB-infested wood packaging; 2) ports where the beetle has been detected in recent years; plus 3) the presence and calculated probable volume of imports for the types of commercial operations considered likely to transport the beetle.

This analysis required access to detailed data from many sources. They included 1) interception data revealing the types of products most often associated with infested wood and the intended destinations of intercepted cargoes; 2) the North American Industry Classification System data listing locations of businesses likely to utilize these products; 3) the beetle’s climatic requirements; and 4) the locations of actual detections of VLB as revealed by Cooperative Agricultural Pest Survey (CAPS) and other trapping programs.

Approaches to Learning More

Relying on traps to detect new pests has several advantages. These include the relative ease of scaling up to larger areas, and – sometimes — the ability to use general lures that attract a variety of insects. Some insects are attracted only, or primarily, to specific lures. Labor intensiveness (and expense) varies with how many traps must be deployed, whether the sites are easily accessible, difficulty extracting trapped insects, and the difficulty sorting the dead insects to find the species of interest.

A second approach is more labor-intensive and expensive, but it gives more information on the target species. This approach is to rear intercepted insect larvae in logs inside containers (to prevent escape) until they reach maturity and emerge. This approach facilitates determination of the species (it is difficult to identify larvae) … and allows an evaluation of feeding behavior – which translates into assessment of the damage caused to the tree.

The Canadian Food Inspection Agency (CFIA) began applying this survey method in 2006. CFIA collects logs from trees in declining health at high risk sites, such as industrial zones, current and historic landfills, and disposal facilities where large volumes of international wood packaging and dunnage are stored for extended periods of time. The logs are obtained from trees removed as part of municipal hazard tree removal programs. CFIA takes the logs to one of four research laboratories (in Toronto, Nova Scotia, Montreal, and North Vancouver), where they are placed in rearing chambers and allowed time to see what insects emerge. The logs are also dissected to reveal the type of damage caused by the insects – that is, determine whether insect was cause of tree mortality [Bullas-Appleton et al. 2014) .

The United States is applying the same approach, but less systematically.

APHIS developed a short-term project aimed at addressing two challenges: identifying larvae found in wood packaging to the species level (larvae intercepted at the border are often identified only to family); and gaining valuable information about the failure of currently required phytosanitary treatments as regards particular genera and species.

In a cooperative project begun in 2012, the DHS Bureau of Customs and Border Protection (CBP) collected live larvae of Cerambycidae and Buprestidae (and, since September of 2015, Siricidae), intercepted during inspection at initially six, later 11 U.S. ports.

These larvae were sent to an APHIS containment facility where many were reared to adults. Upon emergence, adult specimens were killed and identified by experts working for the National Identification Service. DNA barcodes of dead larvae and the reared adults were defined and compared and any  new information was added to public genetic databases. These DNA barcodes have enhanced the capacity of anyone involved in pest interception and detection to rapidly identify larval stages. In 2017, APHIS determined that it had detected almost the full range of species that might be transported in wood packaging, and stopped funding the project.

As of June 2017, the APHIS project had received 1,289 intercepted wood borers (1,052 cerambycids, 192 buprestids and 45 siricids) from 45 countries (See Nadel et. al 2017). The extensive analysis of velvet longhorned beetle described in my previous blog link was greatly assisted by the resulting data.

Years before the APHIS project, USDA Forest Service wanted to try applying rearing techniques to aid early detection of insects in the country. At first, the scientists asked residents of Washington, D.C. to identify street trees that appeared to be infested with pests. Those trees were then cut and sections placed in rearing containers to allow scientists to determine what was causing the problem (Harvard Science).

The project was transferred in 2015 to Boston and New York. The Boston location is an arboretum; the advantage of this site is that it has 1) a diversity of tree species; 2) trained staff; and 3) detailed records of most trees on-site (Harvard Science). Project scientists now accept material from stressed, diseased, or dying trees. This material is loaded into sealed barrels and allowed two years for insects to emerge. Since 2015, project scientists have examined 8,605 beetles comprising 223 species. These studies have resulted in 16 new state records, records of some Scolytinae that are rarely collected from traditional trapping methods; documentation of  new host associations; and discovery of one previously undescribed species — Agrilus sp. 9895 (See DiGirolomo, Bohne and Dodds, 2019).

SOURCES

Bullas-Appleton, E., T. Kimoto, J.J. Turgeon. 2014. Discovery of Trichoferus campestris (Coleoptera: Cerambycidae) in Ontario, Canada and first host record in North America. Can. Entomol. 146: 111–116 (2014).

Marc DiGirolomo, Michael Bohne, Kevin Dodds. 2019. Presentation to the 19^th Annual Meeting of the Continental Dialogue on Non-Native Forest Insects and Diseases https://continentalforestdialogue.files.wordpress.com/2019/12/bohne.continentaldialogue1.pdf  USFS – Durham, NH – 19^th Dialogue meeting

Haack, R. A. 2006. Exotic bark- and wood-boring Coleoptera in the United States: recent establishments and interceptions. Can. J. For. Res. 36: 269–288.

Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the United States. PLoS ONE 9(5): e96611. doi:10.1371/journal.pone.0096611

Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera: Cerambycidae) in the United States. Annals of the Entomological Society of America, 113(2), 2020, 88-99.  https://doi.org/10.1093/aesa/saz051    

Nadel, H. S. Meyers, J. Molongoski, Y. Wu, S. Lingafelter, A. Ray, S. Krishnankutty, A. Taylor.  2017. Identification of Port Interceptions in Wood Packing Material Cumulative Progress Report, April 2012 – June 2017

Ray, A.M., J. Francese, Y. Zou, K. Watson, D.J Crook, and J.G. Millar. 2019. Isolation and identification of a male-produced aggregation sex pheromone for the velvet longhorned beetle, Trichoferus campestris. Scientific Reports 2019. 9:4459. https://doi.org/10.1038/s41598-019-41047-x

Posted by Faith Campbell

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.

Many highly damaging wood-borers have been introduced to North America in wood packaging.

One woodborer, a beetle in the Cerambycidae, has been introduced multiple times to the United States — both before and after implementation of ISPM#15, the international regulations designed to stop such introductions. This is the velvet longhorned beetle (VLB) (Trichoferus (=Hesperophanes) campestris). Independent scientists have recently documented how VLB is introduced and where it is established.

I first blogged about the VLB three years ago. At that time, I asked why APHIS had not undertaken a quarantine and other actions to contain or eradicate the beetle, which was clearly established in an orchard in Utah (Wu et al. 2020; full source citations appear at the end of the blog). Now, the VLB is established in three states and has been detected in many more (details below).

It appears that the VLB will not cause significant damage. I hope this proves true, because it is certainly travelling here on a regular basis. While the most detailed study of the VLB’s potential impact in North America is not yet complete, early indications are that the beetle attacks mostly dying or dead trees.

A Widespread and Adaptable Pest

The VLB is native to China, Central Asia, Japan, Korea, Mongolia, and Russia. It has also been recorded in several European countries. The risk of introduction is broader, however. VLB has established throughout the Middle East and Europe, as well as parts of South and Central America. U.S. officials have intercepted live VLB individuals in shipments originating from these introduced populations, i.e., Brazil, Italy, Mexico, and Spain (Ray et al. 2019).

Wu et al. (2020) studied the genetic diversity of VLB specimens collected by in the United States by 1) trapping at several locations and 2) by testing those intercepted in wood packaging at U.S. ports. The scientists found high levels of diversity between and even within each limited geographic population. These results indicate that VLB has been introduced numerous times via the wood packaging pathway. They also found some evidence that introduced VLB populations might be expanding so it is important to understand pathways of spread within the country (Wu et al. 2020).

Where VLB is in the United States

The VLB is now officially considered to be established in Cook and DuPage counties, IL; Salt Lake County, UT; and Milwaukee, WI. [Krishnankutty et al. 2020).

However, adults have been detected in 26 counties in 13 additional states, plus Puerto Rico, since 1992. Since a trapping survey for woodborers began in 1999, this joint federal and state Cooperative Agricultural Pest Survey (CAPS) has trapped VLB in Colorado (2013), Illinois (2009), New Jersey (2007, 2013), New York (2014, 2016–2018), Ohio (2009, 2017–2019), Pennsylvania (2016), Rhode Island (2006), and Utah (2010, 2012–2019). (Krishnankutty et al. 2020). Also, Oregon detected VLB in 2019 (Oregon Department of Agriculture 2019).

Interceptions in Wood Packaging

The velvet longhorned beetle has been detected frequently in wood packaging since at least the middle 1980s (when APHIS began recording interceptions) (Haack 2006). (Haack’s study covered 1985-2000, before implementation of the International Standard on Phytosanitary Measures (ISPM) #15.)

APHIS’ official interception database listed 60 separate interceptions of VLB in the more recent ten plus-year period June 1997 – November 2017 – which overlaps pre- and post-implementation of ISPM#15. Eighty-eight percent of these interceptions were in wood packaging. Seven percent were in wood products. The remaining seven percent were in passenger baggage or unidentified products.

As has been the case generally since ISPM#15 was adopted, a high percentage — 65.4% — of the intercepted wood packaging during this period bore the mark certifying compliance with the ISPM#15 treatment requirements. Unsurprisingly, China was the origin of 81.6% of the intercepted shipments infested by pests (Krishnankutty et al. 2020).

In the most recent data studied, all from the period after implementation of ISPM#15 — 2012 – 2017, 28 VLB were found in analyses of a sample of wood packaging (Nadel et al. 2017). (I will discuss this study and other detection tools in a separate blog.)

In agreement with earlier findings, the most high-risk imports were determined to be wood packaging for stone, cement, ceramic tile, metal, machinery, manufactured wood products (furniture, decorative items, new pallets, etc.), and wood-processing facilities (Krishnankutty et al. 2020).

These findings largely confirm what we already know about the wood packaging pathway and high levels of non-compliance with ISPM#15 by Chinese shippers. What is APHIS going to do about this well-documented problem? APHIS certainly shouldn’t ignore these findings on the grounds that this particular wood-borer is less damaging than many others. Any chink in our phytosanitary programs that allows transport and entry of VLB can – does! – allow introduction of other woodborers.

The VLB also has been found in rustic furniture – often after the furniture has been sold to consumers. I discussed a 2016 example of this pathways in my February 2017 blog. Krishnankutty et al. (2020) suggest other possible pathways are wooden decorative items and nursery stock, particularly penjing (artificially dwarfed trees and shrubs).

Krishnankutty et al. (2020) note the importance of proper disposal of wood packaging once the cargo reaches its destination. Have any state phytosanitary officials enacted regulations targetting this source of invaders?

The Risk to North America’s Forests Is Unknown

A climate-based model described in Krishnankutty et al. (2020) suggests that climate appears to be suitable for VLB across much of the continental United States, northern Mexico, and southern Canada. Only Florida, southern Texas, and high elevation and coastal regions of the western United States and Mexico states are unlikely to support the velvet longhorned beetle, based on climate. (The study did not consider whether host trees would be present.)

Asian and European sources list a broad host range consisting of at least 40 genera of conifers, hardwoods, and fruit trees (Krishnankutty et al. 2020). Still, as noted above, new studies seem to indicate a minimal impact on healthy trees in North America. Indeed, the principal Utah outbreak is in an orchard littered with pruned material.

With so many suitable hosts across so much of the country, the potential for damage is frightening.

Setting Priorities for Surveillance

The availability of data on both port interceptions and multiple detected outbreaks provides an opportunity to test procedures for carrying out early detection surveys. Improving the efficacy of early detection is critical since – as Wu et al. (2020) note – — the majority of infesting larvae would probably not be intercepted and would subsequently be transported to the cargo’s intended destinations. This is despite CBP’s best efforts to target inspection of wood packaging shipments based on shippers’ histories of non-compliance, targeting that I strongly support.

In response to this concern, Krishnankutty et al. (2020) analyzed pathways of introduction – 1) the types of imports associated with VLB-infested wood packaging, 2) ports where the beetle has been detected in recent years, plus 3) the presence and calculated probable volume of imports of types of commercial operations considered likely to transport the beetle. These included wholesale and retail sellers of products known to be risky and businesses involved with wood fuel processing, log hauling, logging, and milling of saw lumber (Krishnankutty et al. 2020).

They could test the value of this approach by comparing the calculated “intended destination counties” declared at import to actual detections of T. campestris. VLB was detected (by CAPS or other surveys) in either the same or a neighboring county for 40% of the intended destination counties.

This seems to be a high introduction rate; detections will probably rise now that a species-specific lure is available. What could this mean for the establishment rate? Is anyone going to repeat the comparisons to track such changes? Unfortunately, we lack sufficient data to compare the VLB establishment rate (whatever it turns out to be) to the rate for other wood-borers.

Focusing on their original intentions, Krishnankutty and colleagues considered the 40% correlation between intended destinations and VLB detections to be sufficiently rewarding to be one basis for setting priorities for surveys (Krishnankutty et al. 2020).

Krishnankutty et al. (2020) say that recognition of three established populations and widespread destinations of potentially infested wood packaging to climatically suitable areas points to the need to determine whether additional populations are already established – or might soon become so. I add this need is further supported by the frequent detections of low numbers of the VLB in at least seven other states (see above). They call for enhanced surveillance to determine where the VLB is.

Improved surveillance is now facilitated by Dr. Ann Ray’s identification of a specific pheromone that can be synthesized in a lab and used to lure VLB to traps. The pheromone is much more effective in attracting VLB than previous food-like lures used by CAPS as general-purpose attractants for wood-boring insects.APHIS had provided about $50,000 over four years from the Plant Pest and Disease Management and Disaster Prevention program (which receives funding through the Farm Bill) to Dr. Ray’s search for the species-specific pheromone.

I will discuss detection efforts in a separate blog.

SOURCES

Bullas-Appleton, E., T. Kimoto, J.J. Turgeon. 2014. Discovery of Trichoferus campestris (Coleoptera: Cerambycidae) in Ontario, Canada and first host record in North America. Can. Entomol. 146: 111–116 (2014).

Haack, R. A. 2006. Exotic bark- and wood-boring Coleoptera in the United States: recent establishments and interceptions. Can. J. For. Res. 36: 269–288.

Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera:) in the United States. Annals of the Entomological Society of America, XX(X), 2020, 1–12

Nadel, H. S. Meyers, J. Molongoski, Y. Wu, S. Lingafelter, A. Ray, S. Krishnankutty, A. Taylor. 2017. Identification of Port Interceptions in Wood Packing Material Cumulative Progress Report, April 2012 – June 2017

Oregon Department of Agriculture, Plant Protection & Conservation Programs. 2019. Annual Report 2019.

 Ray, A.M., J. Francese, Y. Zou, K. Watson, D.J Crook, and J.G. Millar. 2019. Isolation and identification of a male-produced aggregation sex pheromone for the velvet longhorned beetle, Trichoferus campestris. Scientific Reports 2019. 9:4459. https://doi.org/10.1038/s41598-019-41047-x

Wu, Y., S.M. Krishnankutty, K.A. Vieira, B. Wang. 2020. Invasion of Trichoferus campestris (Coleoptera: Cerambycidae) into the United States characterized by high levels of genetic diversity and recurrent intros. Biological Invasions Volume 22, pages1309–1323(2020)

Posted by Faith Campbell

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.

This month is the 14^th anniversary of United States’ implementation of International Standard for Phytosanitary Measure (ISPM) #15 with the goal of reducing the risk of pest introduction via wood packaging. 

Implementation of the international standard has apparently reduced the “approach rate” of pests in wood packaging, but not sufficiently (See my previous blog).

In this International Year of Plant Health (USDA/APHIS full citation at end of this blog), it is essential to understand how well the wood packaging program is working. Evaluating its current efficacy is especially important for protecting our forests. One key scientific society recognizes this: organizers of  the Entomological Society of America’s Grand Challenges Summit in Orlando next November have chosen wood packaging as the theme.  

Unfortunately, information essential to evaluate the efficacy of ISPM#15 – both worldwide and as implemented by USDA APHIS – is not yet available.

Our most up-to-date information on U.S. enforcement is from Kevin Harriger, Executive Director for the Agriculture Programs and Trade Liaison office, U.S. Customs and Border Protection (CBP). In his report to the annual meeting of the Continental Dialogue of Non-Native Forest Insects and Diseases in November 2019, he stated that over the past three years, CBP detected a regulated pest, on average, in 30% of wood packaging intercepted because it was not compliant with ISPM#15. Unfortunately, Mr. Harriger did not provide the actual number of shipments inspected or seized.

The absence of specific numbers means I cannot compare the 2019 findings to previous years. My calculation of Mr. Harriger’s data provided to the Dialogue in previous years showed that over the nine-year period Fiscal Years 2010 through 2018, CBP detected 9,500 consignments harboring a regulated pest. Ninety-seven percent of the shipments found to be infested with a pest bore the ISPM#15 mark. The wood packaging was from nearly all trading countries. CBP staff say the reason for this high proportion of pests in wood packaging is fraud.

A European study of imports of stone from China over the period 2013-2016 focused on a recognized high-risk commodity. Nevertheless, the Europeans reached the same finding: 97.5% of consignments that harbored pests bore the ISPM#15 mark. They concluded that the ISPM-15 mark was of little value in predicting whether harmful organisms were present (Eyre et al. 2018).

There is considerable dispute about which categories of packaging are most likely to be infested. The categories are pallets, crates, spools for cable, and dunnage (wood used to brace cargo and prevent it from shifting). Unfortunately, Mr. Harriger shed no light on that issue. He did report that 78% of non-compliant shipments over the last three years was in packaging associated with “miscellaneous cargo”, e.g., machinery, including electronics; metals; tile and decorative stone (such as marble or granite counter tops). This association has been true for decades (see Haack et al. 2014). Another 20% of the non-compliances were associated with fruit and vegetable cargoes. This probably reflects the combination of large volumes of produce imports from Mexico and that country’s poor record of complying with wood packaging requirements.

It has been reported that in recent years, CBP inspectors have repeatedly found pests in dunnage bearing the ISPM#15 mark and associated with “break bulk” cargo (goods that must be loaded individually; not transported in containers or in holds as with oil or grain). Ships that carry this sort of. Problems appear to be acute in Houston. While most of the criticism of non-compliant wood packaging refers to countries in Asia and the Americas, at least one of the Houston importers obtains its dunnage in Europe.

There is even a question about the volume in incoming goods. CBD says that approximately 13 million loaded containers enter the country every year by rail, truck, air, or sea.  However, my calculation from U.S. Department of Transportation data (see reference) was that more than 22 million shipping containers entered the U.S. via maritime trade in 2017.

In 2017, CBP announced a new policy under which it will assess a penalty on each shipment in which the wood packaging does not comply with ISPM#15. Previously, no penalty was assessed until a specific importer had amassed five violations over a twelve-month period.

FY2019 was thus the second year under the new policy. I had hoped that Mr. Harriger would provide information on the number of penalties assessed and any indications that importers are strengthening their efforts to ensure that wood packaging complies. However, he did not.

He did report that CBP has expanded outreach to the trade. The goal is reducing all types of non-compliance – lack of documentation, pest presence, etc. in both wood packaging and shipping containers. Outreach includes awareness campaigns targetting trade, industry, affiliated associations, CBP employees, and international partners.

Still, authorities cannot know whether the actual “approach rate” of pests in wood packaging has changed in response to CBP’s strengthened enforcement because they lack a scientifically valid study. The most recent study – that reported in Haack et al. 2014 – relied on data up to 2009 – more than a decade ago. It indicated an approach rate of approximately 0.1% (Haack et al. 2014).

Unfortunately, USDA APHIS has not yet accepted researchers’ offer to update this study.

We do know that pests continue to be present in wood packaging 14 years after the U.S. put ISPM#15 into force.

I call for:

1) Determining the relative importance of possible causes of the persistent pest presence problem – fraud, accidental misapplication of treatments, or other failures of treatment;

2) Enhanced enforcement by APHIS as well as CBP;

3) Stepped up efforts to help US importers by APHIS and  the Foreign Agricultural Service– by, e.g., providing information on which foreign suppliers of wood packaging and dunnage have good vs. poor records; conveying importers’ complaints about specific shipments to the exporting countries’ National Plant Protection Organizations (NPPOs), such as Departments of Agriculture;

4) Raising pressure on foreign NPPOs and the International Plant Protection Convention more generally to ascertain the specific reasons ISPM#15 is failing and to fix the problems identified.

Alernative Materials – Plastic!

I have also advocated for shifting at least some wood packaging – e.g., pallets and some crates – to alternative materials. For example, USDA APHIS could require exporters with bad records to use crates and pallets made from materials other than solid wood, e.g., plastic, metal, or oriented strand board. Or companies could make that shift themselves to avoid phytosanitary enforcement issues and penalties.

People recoil from the idea of using plastic and there are increasing concerns about the breakdown of plastics into tiny fragments, especially in water. But it’s also true that the world is drowning in plastic waste. Surely some of this could be recovered and made into crates and pallets with environmentally sound technology.

The Washington Post reported in November that an Israeli company is converting all kinds of trash – including food waste – into plastic, and molding that plastic into various items, including packing crates.

UBQ Materials takes in tons of rotting food, plastic bags, dirty paper, castoff bottles and containers, even broken toys. It then sorts, grinds, chops, shreds, cleans and heats it mess into first a slurry, then tiny pseudo-plastic pellets that can be made into everyday items like trays and packing crates.

Another Israeli company, Plasgad, uses plastic to make pallets, crates and other products.

Some who were skeptical now are more interested, including the president of the International Solid Waste Association  and the chief executive of the Plastic Expert Group. 

So – can we address three environmental problems at the same time – mountains of waste, methane gas releases contributing to climate change, and one (important) pathway for the movement of tree-killing pests?

SOURCES

Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)

Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the United States. PLoS ONE 9(5): e96611. doi:10.1371/journal.pone.0096611

Harriger, K., Department of Homeland Security Bureau of Customs and Border Protection, presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 2017.

U.S. Department of Transportation, Maritime Administration, U.S. Waterborne Foreign Container Trade by U.S. Customs Ports (2000 – 2017) Imports in Twenty-Foot Equivalent Units (TEUs) – Loaded Containers Only.

U.S. Department of Agriculture, Press Release No. 0133.20, January 27, 2020

Posted by Faith Campbell

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.

In November, scientists discovered a new ambrosia beetle in symptomatic valley oaks  (Quercus lobata) trees in Calistoga, Napa County. Some blue oaks (Q. douglasii) have also been attacked (Rabaglia et al. 2020). Trees associated with this outbreak showed wilting, defoliation, and broken branches. The infested wood was discolored, presumably by the fungus. The insect, Xyleborus monographus, is native to Europe.

Officials now know that this beetle is found throughout a 15-mile-long area in Napa and neighboring Lake and Sonoma counties. It has probably been there for several years (Rabaglia et al. 2020). One specimen of the beetle was trapped in Portland, Oregon in 2018, but no infestation was detected. The beetle has never been intercepted in California. Nor has it been found in traps designed to detect bark beetles which have been deployed in 11 counties – including several in the San Francisco Bay area but not including Napa or Sonoma.

Like all Xyleborus, adult females tunnel into tree’s trunks, carrying fungal spores in their mycangia (structures in the jaws in which microbes are harbored). Beetle larvae eat the fungi. Beetle reproduction is facilitated by sibling mating within the gallery and by the ability of unmated females to produce male offspring.

Sometimes the beetle’s associated fungi are pathogenic to living trees. One of the fungal species detected in the Calistoga infestation is Raffaelea montetyi, which is reported to be pathogenic to cork oak. The presence of this fungus had been reported in 2018, although the beetle species carrying it was not identified then. This is apparently the first report of this fungus in North America.

Known hosts of beetle X. monographus include European or Eurasian chestnut (Castanea sativa), beech (Fagus orientalis), and European and American oaks (including Q. lobata and Q. rubra).  The possible effects of the beetle and associated fungi on other oak species is unknown. Oaks are acknowledged to be important components of forests and woodlands in California. Ambrosia beetles often attack stressed trees. Since California forests are increasingly frequently stressed by drought, fire, and other pests, they might be especially vulnerable.

The California Department of Food and Agriculture is currently seeking comments on what pest rank to assign the insect.  The comment period closes on March 6^th and I encourage you to consider providing your views.

In their draft document ranking risk, state officials note that a proven host — Q. lobata — is widespread in California and the insect is probably capable of establishing over much of the state. The possible economic impact was described as possibly affecting production of oaks in California nurseries and triggering quarantines.  (Does this mean CDFA expects impacts only on saplings? Is this realistic? CDFA made no mention of costs to urban areas for hazard tree management.)

The risk assessment notes that research by McPherson, et al. (2008) found that ambrosia beetles are attracted to oak trees already infected with sudden oak death (SOD) (Phytophthora ramorum). Therefore, X. monographus could have a synergistic impact with SOD on California oaks – which has already killed an estimated 1.9 to 3.3 million coast live and Shreve oaks.

SOURCE

Rabaglia, R.J. S.L. Smigh, P. Rurgman-Jones, M.F. Digirolomo, C. Ewing, and A. Eskalen. 2020. Establishment of a non-native xyleborine ambrosia beetle, Xyleborus monographus (Fabricius) (Coleoptera: Curculionidae: Scolytinae), new to North America in California. Zootaxa 478 (2): 269-276

Posted by Faith Campbell

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.

For more than a decade, most countries in the world have required that crates, pallets, spools, and dunnage made from wood be treated in accordance with the requirements of the International Standard for Phytosanitary Protection (ISPM)#15 that this treatment be certified by applying an approved stamp to the wood. The goal of the program is to “reduce significantly the risk of introduction and spread of most quarantine pests that may be associated with that material.”

However, experience and studies in both the United States and Europe demonstrate that the ISPM#15 stamp is not a reliable indicator of whether the wood packaging is pest-free.

1) In the United States, over a period of nine years – Fiscal Years 2010 through 2018 – U.S. Customs and Border Protection (CBP) detected 9,500 consignments harboring a pest in a regulated taxonomic group. Of the shipments found with infested wood packaging, 97% bore the ISPM#15 mark (See Harriger reference at the end of the blog). The wood packaging was from nearly all trading countries. 2) In the past two years, CBP inspectors have repeatedly found pests in dunnage bearing the ISPM#15 mark – as reported by U.S. importers of “break bulk” cargo into Houston. While most of the criticism of non-compliant wood packaging refers to countries in Asia and the Americas, at least one of the Houston importers obtains its dunnage in Europe.

3) In Europe, a two-year intensive survey of wood packaging associated with shipments of stone from China to the 28 European Union countries over the period 2013-2016 again found that 97.5% of consignments found to harbor pests bore the ISPM#15 mark (Eyre et al. 2018). The scientists concluded that the ISPM-15 mark was of little value in predicting whether harmful organisms were present. (Eyre et al. 2018, p. 712)

As I have noted in previous blogs and policy briefs, the only in-depth study of the “approach rate” of pests in wood packaging, based on data which is now a decade old, found that 0.1% of incoming wood packaging transported a regulated pest (Haack et al. 2014). Given current trade volumes, as many as 17,650 containers per year (or 48 per day) transporting tree-killing insects might be entering the U.S. (My calculation of this estimate is explained in the blog on “risks of introduction” here.)

The Haack study excluded imports from Mexico, Canada, and China. The first and third countries have records of poor compliance with ISPM#15 requirements, so the “approach rate” for all incoming shipments might well have been higher.

The study of European imports focused on shipments of stone from China – which were deliberately chosen to represent types of imports presenting a high risk of transporting pests. Across Europe, over the four-year period, quarantine pests were detected in 0.9% of the consignments – somewhat higher than the U.S. number, as could be expected. However, there were large variations among participating countries’ findings. Austria and France found 6.95% of consignments inspected were infested, while half of European Union countries found none!

These differences demonstrate the importance of thorough inspections.

The data also indicate that the problem is not decreasing. Austria detected pests in nearly one-fifth (19.6%) of inspected shipments in 2016 – the final year of the study! However, during that same year, only 1.5% of wood packaging lacked the ISPM#15 mark.

So How Should the International Phytosanitary Community React to This Failure?

Data cited in numerous studies indicate that ISPM#15 has probably succeeded in reducing the presence of pests in wood packaging. This progress is good – but insufficient. Our forests need further reductions.

In the meantime, however, the international standard has demonstrably failed to provide a secure method to evaluate the pest risk associated with wood packaging accompanying any particular shipment. The presence of the stamp on pieces of wood packaging does not reliably show that the wood is pest-free. Officials need to determine why. Is it fraud? That would mean deliberately placing the stamp on wood that had not been treated, which U.S. CBP staffers think is occurring (Harriger). The European Union audit team that visited China also thought they detected instances of fraud. They concluded that “the current system of official controls in China does not adequately ensure that SWPM which forms part of consignments of goods exported to the EU is marked and treated according to ISPM No. 15” (Eyre et al. 2018, p. 713). On the other hand, the US importers in Houston say they are pressing their European suppliers to provide pest-free dunnage.

What more could we ask them to do to ensure that they are not receiving fraudulently marked materials?

Perhaps the problem has a different cause. Are the treatments themselves are less effective than expected? One APHIS study found that twice as many larvae reared from wood treated by methyl bromide fumigation survived to adulthood than larvae reared from heat-treated wood; the reason is unclear (Nadel et al. 2016). Unfortunately, it is apparently impractical to determine whether wood was heat treated by looking for changes in the chemical profile of the wood (Eyre et al. 2018).

Nor can we expect inspection of 100% of all risky consignments or detection of 100% of quarantine pests in those consignments that are inspected. Therefore, the European study authors concluded that inspection is best considered as a means of gathering evidence of risk and a deterrent rather than a means of completely preventing pest movement (Eyre et al. 2018).

The European study authors called for review of ISPM#15 as a control system and to investigate compliance at the source (Eyre et al. 2018 p. 714).

What is APHIS doing?

As I have noted previously – here and here – while U.S. CBP adopted a policy in 2017 under which it can penalize importers for each consignment not in compliance with ISPM#15, APHIS has not followed Custom’s lead on this. Instead, APHIS will apply a penalty only when an importer has accrued five violations over the period of a year. (The two agencies are acting under separate legal authorities.) This is yet another example of APHIS taking a less protective stance – as I described in earlier blogs.

Since Customs is now applying the letter of the law, the most useful step would probably be for APHIS (and the USDA Foreign Agriculture Service) to ramp up efforts to assist U.S. importers which are trying to comply. The importers are begging USDA to provide better information to them about foreign suppliers of wood packaging and dunnage. Which have good vs. poor records? USDA could also help importers trying to complain about specific shipments to the exporting countries’ National Plant Protection Organizations (NPPOs; departments of agriculture).  In addition, APHIS could augment its pressure on foreign NPPOs and the International Plant Protection Convention more generally to ascertain the reasons ISPM#15 is failing and to fix the problems.

APHIS has not been idle. The North American Plant Protection Organization (including Canada and Mexico) has sponsored two workshops intended to educate NPPOs and exporters in Asia and the Americas about the standard’s requirements. APHIS is planning to address wood packaging in an international symposium organized under the auspices of the International Year of Plant Health in July 2020 – I will provide details when they become available.

APHIS is collaborating with the Entomological Society of America to host a workshop on wood packaging at the ESA annual meeting in November 2020 – I will provide details when they become available. The Continental Dialogue on Non-Native Forest Insects and Diseases plans to link its annual 2020 meeting to this workshop.

More immediately, the Continental Dialogue on Non-Native Forest Insects and Diseases will have presentations on the wood packaging issue at its annual meeting in just 11 days! in Cleveland

In preparation for the 2020 meetings, APHIS should fund more studies and audits of wood packaging to document the current efficacy of the standard (that is, the pest approach rate); remember, Haack’s study relied on data which are now a decade old. Not only has time passed … Both the standard and U.S. enforcement policies have changed since 2009.

Significance of the Wood Packaging Problems

The apparent failure of the ISPM#15 standard to provide a reliable means to certify treatment raises obvious issues regarding the risk of pest introductions. However, the implications are much broader.

The premise of the international phytosanitary system – the Agreement on the Application of Sanitary and Phytosanitary Standards (SPS Agreement) and International Plant Protection Convention (IPPC) – is that importing countries should rely on exporting countries to take the actions necessary to meet the importing countries’ plant health goals. The ISPM#15 experience casts doubt on this premise. The exporters are not reliably ensuring the cleanliness of their wood packaging. Worse, wood packaging is easier to treat than fruits, vegetables, and living plants (plants for planting). The latter commodities are much more easily damaged or killed by treatments than are boards or even logs – which are, after all, already dead! (A longer discussion of the SPS Agreement and IPPC is found in Chapter III of Fading Forests II, available here.

I hope that the international phytosanitary community will take advantage of the heightened attention and effort associated with the International Year of Plant Health in 2020 to re-examine all aspects of the current global phytosanitary system.

Posted by Faith Campbell

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.

SOURCES

Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)

Kevin Harriger, US CBP. Presentations to the annual meetings of the Continental Dialogue on Non-Native Forest Insects and Diseases over appropriate years. See, e.g., https://continentalforestdialogue.org/continental-dialogue-meeting-november-2018/

Nadel, N., S. Myers, J. Molongoski, Y. Wu, S. Linafelter, A. Ray S. Krishnankutty, and A. Taylor. 2016. Identificantion of Port Interceptions in Wood Packaging Material: Cumulative Progress Report, April 2012 – August 2016

https://www.joc.com/breakbulk/ispm-15-enforcement-leaves-shippers-no-good-nswers_20190717.htmlhttps://www.joc.com/breakbulk/enhanced-enforcement-ispm-15-costing-us-importers-millions_20190725.html