- Why Wood?
The sustainable standards of ISPM 15 regulations apply to recycled wood pallets and prevent them from spreading wood boring insects across international borders. These standards help ensure recycled wood pallet and crate companies do their part to protect the environment. ISPM 15 separated recycled pallets into two categories: repaired and remanufactured.
When a pallet company buys broken, heat treated, recycled pallets from their customer, most of the pallets require some repair. The pallet company brings the recycled pallets to their facility to sort through them. They fix the repairable pallets and salvage the others for parts.
Buying used pallets is like buying a used car. You could buy a reliable used car that might have had the transmission, radiator, or other parts replaced and it will still be safe and effective to drive. It’s the same car it always has been; it’s simply had a part or two replaced. In the same way, replacing the bad parts of a pallet extends the life of the pallet. ISPM 15 has two categories for recycled pallets. The first category is repaired pallets, referred to in section 4.3.2 of ISPM 15.
Repaired pallets have had up to one-third of the components replaced. This is like the new car that had its radiator replaced. Everything is still new except for that one part. However, once a pallet reaches the end of its life, it’s dismantled and the usable boards are stacked and separated for re-use on other pallets. The unusable boards are recycled into products like wood chips or sawdust for different industries.
It’s possible to make a pallet entirely from recycled boards. If a pallet has had more than one-third of its boards replaced, then ISPM 15 considers it remanufactured, referred to in section 4.3.3 of ISPM 15. This is like the car that has had its engine, transmission, and radiator replaced with parts (new or used) all sourced from different places. When a remanufactured pallet has been repaired with lumber sourced from different locations, separate rules apply. Processes need to be followed to ensure that pallet is ISPM 15 compliant and won’t spread wood-boring pests from one country to another.
The governing agency for each ISPM 15 participating country distributes a unique number to be assigned to a stamp. Each company that participates in the ISPM 15 program must clearly stamp each heat treated wood product that leaves their facility with their number. That way, the source of each wood product can be traced in case there’s a problem. Depending on the pallet’s origin, a used pallet can sometimes have more than one stamp on it to certify heat treatment. In the United States, it’s required that all previous stamps be obliterated before a pallet is heat treated. Only then can a new stamp be applied.
The language of ISPM 15 is used as a minimum requirement for all countries that participate. The agency that oversees ISPM 15 in each country has the authority to include additional standards. Put differently, the rules that apply to businesses in Canada are different than the rules that apply to businesses in the United States. The agency that oversees the Canadian ISPM 15 program is the Canadian Food Inspection Agency. In the United States, it’s the American Lumber Standards Committee. Refer to links below for more information.
The spread of the Zika virus within the United States has changed the protocol for exporting shipments to other countries. However, this hasn’t changed the way wood pallets are prepared for export. As described in our previous post, the ISPM 15 requirements exist to prevent the spread of wood-boring insects across international borders. Mosquitos are not wood boring insects. The types of mosquitos that spread the Zika virus breed in pools of water. To prevent the spread of Zika, cargo containers and airplanes are subject to special treatment.
China, in particular, is strict on this rule. According to the American Journal of Transportation, China’s fumigation requirement is effective for all shipments from the US after August 5, 2016. On September 2nd, they modified the requirement to apply only to shipments originating from Florida. Products being shipped don’t have to be exposed to the fumigation process if certain conditions are met. For instance, fumigating the empty container prior to loading the cargo into it is considered acceptable. Another method it to keep the temperature at 15 degrees Celsius or less during transit. Passenger and cargo airplanes must also comply with these regulations. The space in commercial airlines for storing baggage and in the passenger seating areas should be fumigated prior to departure. Airlines must supply proof of fumigation to the Chinese government.
Wood pallet companies that supply pallets for export are not responsible for fumigating cargo containers. Pallet suppliers have no obligation beyond the ISPM 15 requirements to certify the lumber on their pallets has been heat treated. The ISPM 15 requirements pallet companies must follow are intended to prevent the spread of wood-boring insects that could harm forest sustainability. The National Wood Pallet and Container Association has been working closely with the U.S. Department of Agriculture (USDA) on this subject and had determined:
The ZIKA virus is a human health issue and is related to mosquitos, not wood-boring insects. Therefore, the recognized heat treatment or fumigation of export wood pallets for ISPM 15 compliance is not applicable for ZIKA compliance of the shipment. The entire consignment and container must be anti-mosquito treated and certified pre-shipment. There is no action a wood pallet company can do to assure ZIKA compliance for their customer’s shipment. It is the shipper’s responsibility to ensure the entire shipment is ZIKA compliant.
Inbound shipments without proof of anti-mosquito treatment will be fumigated at the port of discharge in China by the authorities without prior notice. It is the Consignee’s responsibility to inform Shipper (at origin) to provide a certificate proof of treatment before loading the shipment.
These regulations are in place to prevent the spread of Zika virus by mosquitos. The Zika virus was discovered in Uganda in 1947 and is common in Africa and Asia. According to the CDC, as of September 14, 2016, in the United States there have been 43 cases of locally acquired Zika and all of them occurred in Florida. Thus, only outgoing shipments originating from Florida going to China are subject to fumigation; however, these requirements are subject to change. As of September 14, 2016, there are 3,132 cases of US citizens who have contracted Zika by means associated with travel.