Wood Packaging – Customs Efforts & Recent Detections

As noted in my blog of July 15, damaging pests continue to enter the country in wood packaging. The most comprehensive study indicates that tree-killing pests are found in an estimated 13,000 containers entering the country each year – or 35 per day.
These pests are present despite requirements adopted 9 or more years ago that wood packaging be treated.

Types of cargo packaged in wood are inspected by agricultural specialists within the Bureau of Customs and Border Protection , a division of the Department of Homeland Security. CBP agricultural specialists work at 167 sea, air and land ports of entry.  See an article about CBP efforts to curb introductions of tree-killing pests posted at http://www.cbp.gov/frontline/2014/12/frontline-december-forest-prime-evil.

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
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

According to the CBP in the above article, the types of commodities imported that have the highest rates of SWPM-related pest interceptions are metal and stone products (including tile), machinery (such as automobile parts and farm equipment), electronics, bulk food shipments and finished wood articles.
These imports have a long-standing record of pest presence – as described in Chapter 4 of my lengthy report on tree-killing pests.

According to the CBP , 48% of the wood packaging entering the country that does not comply with the treatment requirements comes from Mexico. Mexican maquiladoras are factories that import material and equipment duty-free, then assemble a wide range of products – auto parts, apparel, electronics, furniture, and appliances. Mexico’s 3,000 maquiladoras account for half of Mexico’s exports.
China has the second worst record.
Of course, we import lots of stuff from both countries! However, the China situation is particularly disturbing because the U.S. has required that wood packaging from China be treated since the beginning of 1999 – 16 years!
The ports receiving highest numbers of shipments with non-compliant wood packaging materials have consistently been those along the U.S.-Mexico border, especially in Texas: Laredo, Pharr, more recently Brownsville & Houston. Other ports receiving high volumes of non-compliant wood packaging include Blaine, Washington; Long Beach, California; and Romulus, Michigan.

USDA APHIS and CBP have cooperated in a program under which insect larvae found in wood packaging are identified as to species. In recent years, they have studied larvae detected in wood packaging from eight ports – Long Beach, Seattle; 2 ports in Florida; and three cities on the Texas-Mexico border. (Remember, there are 167 ports of entry across the country, so this sample represented 5% of all ports.) Found at these ports were an unreported total of insects, including 116 individuals in the same family as Asian longhorned beetle (Cerambycids). Forty-three were from China (including 5 ALB), 20 from Russia, and seven from Mexico (Philip Berger, APHIS, at the annual meeting of the Continental Dialogue on Non-Native Forest Insects and Diseases, November 2014)

Most familiar – and frightening! – examples of pests introduced via wood packaging include Asian longhorned beetle, emerald ash borer, redbay ambrosia beetle and its accompanying fungus, and possibly polyphagous shot hole borer and its accompanying fungus – all described here.

The prospect of receiving additional insects from Asia scares everyone. What if a new pest is as bad as the four we already have? The emerald ash borer has already caused the removal of an estimated 50 million trees and continues to spread to ash trees – and now white fringe trees – throughout America east of the Great Plains. Laurel wilt disease (transmitted by the redbay ambrosia beetle) is rapidly eradicating redbay trees in the southeast, including in Everglades National Park – one of the icons of the American conservation movement. The Asian longhorned beetle has already caused removal of more than 124,000 trees from our cities, suburbs, and nearby woodlands – at a cost to federal taxpayers of more than $500 million. If it escapes eradication programs, it threatens trees in 10% of America’s forests. The polyphagous shot hole borer threatens numerous tree species that, collectively, make up more than half the trees planted in urbanareas in Southern California.

While no one denies the threat from insects native to Asia, we should not be complacent about insects from Mexico. Although we are neighbors, our forests are separated by deserts – allowing insects to evolve there to which our trees are vulnerable. Three wood-boring beetles native to Mexico and possibly some U.S. border states are already causing havoc to U.S. trees – goldspotted oak borer, soapberry borer, and walnut twig beetle and its accompanying fungus (all described here).  The first two were introduced to vulnerable forests through movement of firewood, not wood packaging. The third – the walnut twig beetle – might be native to California, although thousand cankers disease is killing native California walnuts throughout the state so something is different than it used to be.

goldspotted oak borer
goldspotted oak borer

When Customs officials detect wood packaging that does not comply with ISPM #15 (“noncompliance” means one of three things: the wood does not bear the ISPM #15 stamp; or the stamp appears to be fraudulent; or signs of pests are detected), that wood must be re-exported immediately, usually with the associated commodity. If any insects present pose an immediate risk of introduction, e.g., if adults are emerging, the shipment might need to be fumigated before re-export.
Re-exported shipments – and any treatments – cause importers to lose income and face costly delays. Still, the continuing presence of non-compliant wood packaging indicates that these inconveniences are insufficient to prompt importers to take all precautions possible to ensure that packaging used by their suppliers and brokers comply with the requirements.

Why don’t importers use alternative packaging made from plastic, steel, or composites that would not harbor tree-killing insects? Plastic pallets also weigh much less than wooden ones, so transport costs are reduced. Customs has pointed out the advantages. … Still, packaging material made from wood is comparatively plentiful, cheap, easy to repair, biodegradable. So it continues to dominate the market.
What steps can be taken by the U.S. government and importers to minimize the presence of insects in packaging?
• U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with the regulations.
• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .
• USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.
• The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)
• Importer’ contracts with suppliers routinely specify penalties for delivery delays; the contracts should be amended to add penalties for noncompliant wood packaging.
• A decade ago, USDA APHIS funded research which developed an ingenious method for detecting mobile pests inside a container. It was an LED light attached to a sticky trap. Placed inside a container, the light attracted snails, insects and possibly other living organisms. The whole mechanism was attached to a mailing container that could be pre-addressed for sending to a lab that could identify the pests. Why was this tool never implemented?

Posted by Faith Campbell

Wood-borers in Wood Packaging: How Did We Get to This Crisis?

shipping containershipping container being unloaded at Long Beach

The rising numbers of tree-killing wood-boring insects introduced to the U.S. (see  blogs from July 15 and August 3 & fact sheet and sources linked there) are a result of ballooning of trade volumes and use of wood packaging.

This irruption of trade was made possible by adoption of the shipping container to transport a wide range of goods.Moving from place to place are not just finished products but also components that originated in one country and that are to be assembled in another country.

How the shipping container revolutionized trade and manufacturing is detailed by Marc Levinson in his book, The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger (Princeton University Press 2008). The transformation affected not only trade between countries, but also within countries, with some regional economies growing while others faltered.

Dr. Levinson recognizes that he has not addressed environmental damage caused by massive movement of cargo. While Dr. Levinson does not explain which damage he is thinking about, I doubt that he includes introductions of non-native wood-boring pests.

(I don’t know enough about the ballast water pathway to understand the impact of containerized shipping on introductions of aquatic invaders, but it seems likely to be an important factor through three factors: directing trade to new port areas; the ships’ huge size; and taking on of ballast water for those segments of a voyage carrying fewer filled cargo containers. On the other hand, Dr. Levinson says that a balance of cargo moving both ways on a trade route is an important factor in determining which ports thrive.)

Before containers, port costs represented the highest proportion of transport costs. Those costs are no longer an important consideration in determining manufacturing and transport choices. Nor is distance as important as before. What is most important are ports that can move large volumes of goods efficiently. The manufacturer or retailer at the top of the chain finds the most economical place for each step in the manufacturing and assembly process without regard to its location.

The containerization revolution was rapid. Containers were first used in international trade in 1966; within three years, nearly one-third of Japanese exports to the U.S. were containerized, half of those to Australia. In the decade after containers were first used in international trade, the volume of international trade in manufactured goods grew more than twice as fast as the volume of global manufacturing production, 2.5 times as fast as global economic output. Large numbers of specialized container ships were built, at ever-increasing sizes. The largest container ship in 1969 could carry 1,210 20-ft containers. By the early 2000s, ships being built to carry 10,000 20-foot containers; or 5,000 40-foot containers.

When Dr. Levinson wrote his book in 2005, the equivalent of 300 million 20-foot containers were crossing the world’s oceans each year.

The container revolution interacted with “just-in-time” manufacturing, which required rapid and reliable transport. Large companies signed written contracts with suppliers and shippers which included penalties for delays.

In the U.S., Long Beach quickly became the principal port because it (as well as Oakland and Seattle) had excellent rail connections to the interior. By 1987, one-third of containers from Asia destined for the East Coast landed at Long Beach and crossed the U.S. by rail. Perhaps counter to our expectation, only one-third of containers entering southern California in 1998 contained consumer goods. Most of the rest contained intermediate or partially processed goods as part of the new international supply and manufacturing chain.

containers at Long Beach Containers at Long Beach

On the East coast, Charleston SC and Savannah similarly grew because of transport connections – this time, primarily highways.

So, global trade is huge and growing; and the shipping container moves immense quantities of goods from one ecosystem to another and provide shelter for a vast range of hitchhiking living organisms (in addition to insects in the wood, there can be other insects’ eggs attached to the sides of the container, snails, weed seeds, even vertebrates – a raccoon once staggered out of a shipping container that had crossed the Atlantic from the U.S. to France!).

We need to imagine, test, and apply a variety of tools to suppress the numbers of living organisms traveling in shipping containers.

For example,
• if importer-supplier contracts specify penalties for delivery delays, we should ask why don’t importers amend the contracts to add penalties for non-compliant wood packaging?
• Might the Bureau of Customs and Border Protection incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program.
• A decade ago, USDA APHIS funded research which developed an ingenious method for detecting mobile pests inside a container. It was an LED light attached to a sticky trap. Placed inside a container, the light attracted snails, insects and possibly other living organisms. The whole mechanism was attached to a mailing container that could be pre-addressed for sending to a lab that could identify the pests. Why was this tool never implemented?

We can’t stop the trade, but we can be much more aggressive in adopting measures to minimize pest introductions.

Posted by Faith Campbell

Non-Native Pest Threat to Forests of the West Coast

As we Americans import more stuff, the risk of new pest introductions rises, too. Many tree-killing insects arrive as larvae living in crates, pallets, and other forms of wood packaging. While the USDA requires that incoming wood packaging be treated to prevent pests, this regulation has not prevented pests from entering the country on wood packaging.

piece of wood packaging with Cerambycid larva; detected in Oregon
piece of wood packaging with Cerambycid larva; detected in Oregon

A study has found that perhaps 35 shipping containers harboring tree-killing pests reach our ports each day (Haack et al. 2014). At this rate, in just 35 years, America might suffer invasion by more than 100 new wood-boring species. This would result in a tripling of borers introduced to U.S. (Leung et al. 2014).

Already, wood-boring beetles have been among the most damaging tree-killing pests introduced to the U.S. Our environment certainly doesn’t need invasions by three times as many new wood-borers!

West-coast ports receive lots of incoming shipping containers. Long Beach alone receives about half of the nearly 25 million shipping containers arriving at the U.S. each year. So it is alarming that high-risk insects, including the Asian longhorned beetle (ALB), continue to be found in wood packaging (Berger 2014).

Imported goods that are heavy are more likely to be packaged in wood and that thus pose the greatest pest risk. The highest risk commodities are
• machinery (including electronics) and metals;
• tile and decorative stone (such as marble or granite counter tops) (Harriger 2014).
The west coast ports of Seattle, Los Angeles/Long Beach, and San Francisco all rank in the top 15 out of 3,500 (1/2 of 1%) cities nation-wide for imports of tile and decorative stone, machinery and metals (Colunga-Garcia et al. 2009).

Not only do west coast cities import high volumes of risky goods; a significant proportion of the trees growing in those cities are vulnerable to these pests. Seattle’s three to four million trees belong to more than 300 species – although a mere seven genera constitute two-thirds of the trees (Ciecko et al. 2012). It has been estimated that just four non-native pests (ALB, gypsy moth, emerald ash borer, and “Dutch” elm disease) could cause $3.5 billion in damages. The ALB alone threatens 39.5% of all trees lining the city’s streets (City of Seattle 2013).

San Francisco has an estimated 669,000 trees; 12% are at risk to the ALB (Nowak et al. 2007). Apparently no one has yet estimated the numbers of trees at risk to sudden oak death (SOD), goldspotted oak borer (GSOB), or polypagous shot hole borer (PSHB).

It is essential that USDA APHIS act more aggressively to prevent additional introductions of pests via wood packaging. (For a longer discussion of the wood packaging pathway, visit my previous blog posted on July 15th). In brief:
• APHIS & the Bureau of Customs and Border protection should penalize all importers whose wood packaging does not comply with decade-old regulatory requirements.
• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program
• APHIS should re-consider the advantages of requiring importers to switch to packaging made from materials other than wooden boards.
• The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the international standard’s treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)

SOURCES
Berger, P. Executive Director, PPQ Science and Technology, Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014

Ciecko, L., K. Tenneson, J. Dilley, K. Wolf. 2012. Seattle’s Forest Ecosystem Values: Analysis of the Structure, Function, and Economic Benefits; August 2012; GREEN CITIES RESEARCH ALLIANCE; City of Seattle Urban Forest Stewardship Plan 2013.

City of Seattle Urban Forest Stewardship Plan 2013.

Colunga-Garcia, M., R.A. Haack, and A.O. Adelaja. 2009. Freight Transportation and the Potential for Invasions of Exotic Insects in Urban and Periurban Forests of the US. J. Econ. Entomol. 102(1): 237-246 (2009); and raw data for the study provided by the authors.

Haack, R.A., F. Herard, J. Sun, J.J. Burgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetle and Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46.

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. 2014. Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014

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

Nowak, D.J., R.E. Hoehn III, D.E. Crane, J.C. Stevens, J. T. Walton. 2007. Assessing Urban Forest Effects and Values: San Francisco’s Urban Forest. USDA Forest Service. Northern Research Station. Resource Bulletin NRS-8.

 

posted by F.T. Campbell

Government Should Act Now! to Shut Wood Packaging Pathway

Revise Decade-Old Policies that Do Not Prevent Introductions

Despite regulations adopted 9 or more years ago, tree-killing insects continue to enter the U.S. in wood packaging. Aggressive enforcement is needed now to prevent further huge ecological and economic losses.

Disasters already introduced via this pathway

As Americans import more stuff, the risk rises that larvae of tree-killing insects will be enter the country hiding in wooden crates, pallets, etc. – called “solid wood packaging” or SWPM.  For more information on this threat, the agencies responsible, and actions taken or proposed, visit here.

Damaging pests still found in SWPM

USDA APHIS (for more information about APHIS, read “Invasives 101” at www.cisp.us) required treatment of wood packaging from China 15 years ago, and treatment of wood packaging from other trade partners 9 years ago! Yet, a small proportion of incoming wood packaging still carries tree-killing pests. As many as 13,000 shipping containers harboring tree-killing pests probably enter the country each year – or 35 each day. [i] The Asian longhorned (illustrated below) is among the pests still detected in wood packaging from China. [ii]

ALB profile jpg

Cities that import the most goods from Asia are at particular risk – New York, Chicago, Los Angeles and Long Beach. Others are also at risk: Washington, D.C.; Virginia Beach; Jacksonville. [To see a more complete list, visit here]

What the Government Has Done

While USDA APHIS has cracked down on U.S. producers of wood packaging who cheat and is promoting workshops to educate our trade partners on wood packaging treatment requirements (see write-up on www.CISP.us referenced above), the government should do more to protect our forests.

What More Can be Done

  • At present, U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with regulatory requirements.
  • The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .
  • USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.
  • The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)

[i] 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

[ii] Haack, R.A., F. Herard, J. Sun, J.J. Turgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetleand Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46; these authors report six separate introductions; after the article was published, a seventh was detected in Clermont County, Ohio; and a new outbreak was detected near Toronto, Ontario. Also, Philip Berger, Executive Director PPQ Science and Technology, Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014