ISPM15 Questions & Answers
Q&As - ISPM15 Meeting on Tuesday 25th January 2005
Question 1:
With regard to Australia, please clarify the treatment
acceptable for panel products.
Answer:
The Forestry Commission attempted to clarify this issue via AQIS
prior to the TIMCON meeting but it did not receive a response. It
was understood that treatment certificates are being accepted and
that no problems had been encountered by exporters. The Forestry
Commission and TIMCON will post any updates regarding the use of
panel products as Wood Packaging Material on the websites as soon
as they are received.
Question 2:
With regard to the calibration of dataloggers and probes for heat
treatment chambers – why does the Forestry Commission insist
upon temperature recording equipment being UKAS calibrated and certificated
annually, which is more expensive than the equipment simply being
tested against UKAS certified equipment.
Answer:
The Forestry Commission must provide Assessment Agencies with a
calibration check that is easy to perform and ensures that treatment
facilities are working to a common standard. UKAS calibration and
certification is recognised internationally. It is difficult to
ensure that calibration is performed to a common standard if various
companies and individuals with varying standards and competencies
are permitted to certify calibration tests. However, if a company
supplies the Forestry Commission with details of an alternative
protocol it will present it to the UKWPMMP Advisory Council for
consideration.
Question 3:
With regards to the repairs of Wood Packaging Material, please give
the details of acceptable repair.
Answer:
If you alter the identity of the Wood Packaging Material, then re-treatment
must be done and the original
mark must be obliterated.
Question 4:
With regard to HT or MB, how long does the treatment last?
Answer:
Both treatments are considered to be permanent.
Question 5:
Various issues concerning second hand pallets being sold and repaired
– with HT marks on them.
Answer:
The FC confirmed that planned statutory regulations for the UKWPMMP
will make it an offence to repair or alter Wood Packaging Material
without the terms of the UKWPMMP and leave original manufacturer’s
and treatment marks on the repaired articles. These marks must be
obliterated and new ones applied if the articles are subjected to
re-treatment during repair or remanufacture operations.
Question 6:
Methyl Bromide – what are the phase out dates?
Answer:
It was confirmed that the use of Methyl bromide is shortly to be
phased out, although there will remain exemptions for certain quarantine
and pre-shipment uses.
Question 7:
Dunnage entering the EU from Third Countries - what is required?
Answer:
From 1st March 2005, dunnage must either be ISPM15 compliant OR
on a temporary basis until 31st December 2007 it must meet the minimum
landing requirement for dunnage ie. bark free and free of pests
and signs of live pests. From 31st December 2007, it must be ISPM15
compliant i.e. treated and marked to the same standard as Wood Packaging
Material.
Question 8:
Various issues about traceability of pallets – fraudulent
use of people’s marks – how to stop it?
Answer:
Fraudulent use is not unique to WPM or the UKWPMMP and is a concern
in all areas of enforcement. New Statutory Regulations due to be
introduced in summer 2005 will cite this as an offence and prosecutions
would be pursued with vigour. FC will act upon confidential information
to trigger investigations.
Question 9:
Is there any tests to prove that treatment types have been performed?
Answer:
There is no test to confirm that timber has been heat treated. There
is an expensive laboratory test that can be done to confirm that
Wood Packaging Material or a commodity has been exposed to Methyl
Bromide, but doesn’t give an indication of the gas concentration
use during the fumigation and must be performed as soon as possible
after treatment.
Question 10:
I have three registered sites all in the same street – can
I have one registered number to cover all three sites so that I
can reduce my Programme costs?
Answer:
Unique Forestry Commission registration numbers are SITE SPECIFIC
with the exception of fumigation companies, so therefore, each site
must be registered.
Question 11:
Do treatment facilities have to mark each piece of timber with their
registration mark when supplying treated timber packs to wood packaging
manufacturers?
Answer:
NO. The packs of timber simply have one mark applied to the pack
to identify it as a treated pack. If individual pieces are to be
used for dunnage then the treatment facility may mark each piece.
The treatment facility has no way of knowing what timber is being
used in the manufacture of a finished article and therefore the
manufacturer should apply their own mark to fabricated articles
to provide traceability of that article.
Question 12:
Can the UKWPMMP fees be reduced for manufacturers dealing in small
volumes of purchased heat treated material for limited WPM article
manufacture.
Answer:
Changes to the fees structure must be agreed with the UKWPMMP Advisory
Council. At a meeting of the Advisory Council members on 8th February
2005, it was decided that ‘As the existing system is working
well and charges are competitive with other countries, it was agreed
that there will be no alteration of the UKWPMMP fees’. Regarding
reduced fees for small volume users, it was agreed that this proposal
would complicate the system. It was agreed that a clarification
note would be sent out to all programme participants stating this
resolution.
Question 13:
In your 10th Jan "Update" it does not specify for some
countries if a certificate is required or not, how can this be clarified?
Do we assume none required if not specified?
Answer:
If a country is implementing ISPM15 as a landing requirement for
Wood Packaging Material, it can be assumed that a phytosanitary
certificate is not required as one of the main concepts of ISPM15
is to provide certification via the wood mark and not via a separate
piece of paper.
Question 14:
Europe, my understanding is that from 1st March 2005 the wood packaging
entering the EU from Third Countries will need a stamp but NOT a
certificate?
Answer:
That is correct - all Wood Packaging Material entering any of the
25 EU member States from a third country (note Switzerland should
is regarded as an EU member State) should be treated and marked
to ISPM15 standards and there is no requirement for a phytosanitary
certificate. Some less developed countries which have not put in
place wood marking programmes and therefore cannot meet ISPM15 requirements
are currently making representations to Brussels requesting that
the EU member States should accept phytosanitary certificates indicating
the treatment types in lieu of wood marks and these are currently
being considered. It should be noted that there is no requirement
to treat and mark wood packaging material which is simply moving
between EU member States.
Question 15:
Australia, you said yesterday that they will NOT ACCEPT PLYWOOD
CASES (Manufactured Wood Product) unless the Plywood is further
Heat Treated or Fumigated. We have been under the misunderstanding
that Australia accepted the manufacturing process of the MWP to
be acceptable, I now need to talk again to ALL my customers and
explain my mistake - please clarify when this became apparent. What
have I missed?
Answer:
We had indications that Australia were going to continue to control
processed wood packaging material prior to their implementation
of ISPM15 on 1st September 2004 but we did not get any details until
the end of the year after having pressed AQIS for a response. They
finally provided us with a statement which we could pass on to the
trade and this has now been published on both the Forestry Commission's
and TIMCON's websites. As soon as we receive details of AQIS's review
of panel product controls we will publish them on the websites.
Question 16:
I have received information from one of my colleagues in USA concerning
implementation dates in EU. I would be grateful if you could clarify
some details. 'Implementation date is 01 Mar 05 for all new WPM.
However existing WPM in circulation or storage will not need to
be regulated until Dec 2007.' Does this only |
