CBP photo
This month is the 14th 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
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