EAB, Invasive Pests Increase Likelihood of National Wood Pallet Treatment Requirement
By Chaille Brindley
Date Posted: 2/1/2008
If you are located or do business in Indiana, Illinois, Maryland, Michigan, Ohio or Pennsylvania, you have probably already heard about the Emerald Ash Borer (EAB) and its impact on forests and wood packaging. Federal and local authorities have set quarantine restrictions on ash lumber and wood products coming from infested areas. Within the next couple of years, those restrictions may extend to all domestic wood packaging, especially pallets and dunnage. Currently, government officials are talking with private industry and scientific leaders about widening restrictions in an effort to stop the the spread of the EAB and other non-native pests.
Everything is still at the exploratory stage. No specific strategy or plan has been finalized. Generally, what is being discussed is a national requirement that all new and used wood pallets be treated according to the ISPM-15 standard. A national treatment requirement would likely eliminate much of the confusion and risk associated with wood packaging. The compliance burden would be equalized among the entire country while eliminating the need to manage treated and untreated packaging inventories. But it would come at a cost.
Mandatory treatment would likely lead to higher prices since it does cost money to treat and monitor compliance. Given the higher resin and steel prices currently impacting other alternatives, wood pallets will likely remain the most cost competitive option even if mandatory treatment is required.
Smaller pallet producers may not be able to comply due to the cost or sophistication required to participate. However, the government is trying to work with all the stakeholders involved to ensure that there is enough treatment capacity if a national requirement is adopted. It is expected that enforcement of a national standard would take place at the pallet manufacturing/recycling level. Pallet users would not really be involved in this aspect unless an infestation problem was traced back to activity it did. According to one participant in a recent meeting by government officials and industry leaders, most appeared to agree that something has to be done.
The spread of pests is both an international concern and a domestic issue as states and localities try to fight off the EAB and other pests. Invasive species is a serious issue because of the effectiveness of certain pests in killing large amounts of standing timber. Waiting until the pest is at your door may be too late for many invasive species. Some suggest that it is very shortsighted to let the initial costs associated with treatment cause the destruction of the industry’s longstanding inventory.
If you want to see what this does, just look to Canada where the mountain pine beetle has decimated forests in British Columbia. Experts, industry representatives and government officials have discussed a number of issues, such as the need for a requirement, the cost, the treatment capacity, a phase-in period, environmental concerns, compliance monitoring, etc. Here are some issues to consider:
- Just ash or other tree species? —It is clear that concerns abound for more than just the EAB, which targets ash trees. Also, the difficulty of determining tree species for most people would make a species-specific requirement difficult to enact and enforce. It is likely that any national treatment requirement would cover all wood species.
- When? — A number of time frames were discussed. It seems like everyone agrees that some sort of phase-in period is necessary. But how long should that be? Suggestions range from six months to two years. A major factor in that process is the ability of the industry to respond to any new requirement.
- Phase-in implementation by region or set one national implementation date? — One proposal called for a regional implementation strategy. Some criticized this because it causes competitive concerns for those on either side of the boundary lines. This could extend beyond just pallets to even pallet users. Or at least that concern was voiced by one big pallet user during the call.
- What about methyl bromide? — Using it for international shipping is one thing. Using it for a domestic quarantine is another. It would likely require environmental studies and other extra hurdles for the government. This could mean that companies using methyl bromide might be put into a situation where switching to heat treatment is the only viable option.
- Treatment capacity? — How long will it take to ramp up treatment capacity? There are numerous factors from using HT lumber to excess capacity from hardwood lumber treaters to new capacity that can be brought on line.
- Harmonization with Canada? — Canadians are already taking measures to deal with the EAB threat. It is expected that Canada would likely comply with whatever restrictions the United States placed on incoming pallets although its producers would want a reasonable time frame to respond. Canada is planning to institute restrictions on lumber and pallets coming from EAB quarantine areas within the United States. Discovery of the beetle near Toronto has increased Canadian concern for enhanced protection measures. You can find out more information by visiting http://www.canadianwoodpackaging.ca/news.asp
Pallet and wood packaging users should be aware of a number of factors. First, no national requirement has been put in place at this time. Interested parties are only discussing it. As has already been covered by the trade press, there are quarantines for various states and localities related to certain pests.
Wood packaging is still a viable and cost effective option for most domestic and international unit load situations. Most of the real burden associated with ISPM-15 compliance should fall on your packaging vendor. Generally, as long as the pallet is properly marked and treated you should not have any problem.
The severity of the concern over invasive species points to a widespread treatment requirement at some point in the future. This does not mean you should ignore the issue until the last minute. You should make sure that you are working with reputable pallet suppliers that are in compliance with any current restrictions. This is especially true if you are located in an area affected by the EAB. You can find out more about this by visiting www.emeraldashborer.info.
MaterialsHandling.Net will carry more information as the pallet treatment issue develops.
