Implementation of ISPM 15 in the NAPPO Region Shane Sela Chair, NAPPO Forestry Panel Canadian Food Inspection Agency

1500 H.T. facilities & 1300 W.P. facilities NAPPO Production 420 H.T. facilities & 350 W.P. facilities 1500 H.T. facilities & 1300 W.P. facilities 113 W.P. facilities

Overview of NAPPO Export Systems Registered facilities operate under quality/certification system Use and tracking of only accredited heat treated or fumigated wood in certified WP Controlled application of certification stamp Inventory control of treated/untreated products

Overview of U.S. System Performance based HT providers/users of treated wood establish day to day practices within accreditation standards APHIS contract with third party auditor/accreditor to oversee system (July 2001) Standard XX establishes specific WP production rules Standard PS 20 establishes H.T. requirements

U.S. Certification of H.T. Wood Accredited agency verifies compliance Heating chamber & schedule sufficient to prescribed standards (PS 20) or Purchase accredited marked lumber Plant health marks used to maintain traceability

U.S. W.P. Production Certified W.P. compliant when: Produced from HT grade marked lumber or Constructed from non-heat treated lumber which once in W.P. form is heat treated in an approved chamber Allows producer to apply ISPM 15 compliant mark

Overview of Canadian System Performance based Two regulatory documents specify requirement for facilities/auditors Outlines standards for accreditation of auditors and facilities Administrative and legal requirements Application, management commitment to compliance, etc. Operate under a Quality Plan Heat treatment processes W.P. production

Canadian W.P. Production Produced from CFIA certified wood KD or HT (56°C/30 min.) or MBr. treated wood (not widely used) Recycled from certified W.P. and/or certified wood

Canadian Requirements Treatment schedules must be developed/equivalent to generic process Monitor and record of treatment processes Monitoring/testing of equipment Records and documentation Segregation (domestic/ export) Actions to deal with non-conforming/non-compliant products Training/training records Source of treated wood

Overview of Mexican System Prescriptive requirements Facility must comply with minimum treatment standards NOM-144-SEMARNAT-2003 SEMARNAT inspects facilities and verifies treatment and traceability compliance

Mexican Standards for W.P. SEMARNAT verifies facility production of H.T. through direct testing Specific requirements for heat chambers (air circulation, measurement of temperatures, moisture control, etc.) Most facilities produce both H.T. and W.P. Requirements to maintain records attesting to ongoing production using H.T. wood.

Controlling Wood Packaging Imports Canada adopted ISPM 15 in January 2004 US adopted in September 2004, Mexico in January 2005 ISPM HT or MBr NPPO oversight Slight technical distinctions between the three Revision to existing policy document D-98-08 which required bark and pest freedom without specific certification. Original controls demonstrated that pest loads associated with W.P. imports were significant. Current requirements in line with ISPM 15. Controls applied to all countries but the U.S. Controls on the U.S. are achieved through pest specific policies (i.e. regulatory controls for PSB, GM, SOD, etc.) Adoption of current requirements followed WTO notification, nine months prior (March 2003)

Controlling Wood Packaging Imports Staged Enforcement Strategy September 16th 2005 all move to hard enforcement of non-compliant shipments To keep in line with other NAPPO members, CFIA has taken a soft enforcement strategy Control of pests (treatment or disposal of infested material Notification of non-compliant importers that they must comply with requirements in the future. Canada will move to hard enforcement once other NAPPO members are ready to apply ISPM 15. Hard enforcement will include refusal of the commodity to enter Canada.

Inspection Methodology Review of manifested goods Border surveillance Mexico: distinction of border material vs moving inland Instructions to border services (Customs, etc.) High risk material re-directed for inspection Breakdown inspections carried out Inland inspections – destination inspections Strategy for various inspection avenues is listed. Customs watches = targeting of frequently non-compliant importers Breakdown inspections are carried out at customs terminals. These are thorough inspections of containers for a variety of reasons including inspection for non-compliant wood packaging. Port staff review incoming manifests of goods in transit. They will notify inland offices of shipments moving within Canada, and inspections can be carried out at suffrage warehouses.

Canadian Example: Sealed Container is Re-directed for Inspection Start of typical inspection process. CFIA reviews manifests at one of our port offices. Once a high risk commodity is identified, CFIA notifies Canada Customs that orders the container re-directed to an inspection station.

Gas Testing 1. Inspector verifies that the container is safe to open using a MBr measuring device (drager tube).

Material is Offloaded for Inspection 3. Importer pays the cost of off-loading the material

Inspection

Inspection

Inspection 1. Heavy materials are lifted onto inspection platforms, where the bottom of the material can be inspected.

Inspection of Port Dunnage 2. Port inspectors order ports to retain dunnage in closed bins, until they are inspected. If compliant the wood is allowed to be re-used, if not, the material is ordered disposed off.

Education 2. Various education efforts are employed. Here signs are placed at port areas to prevent dock hands from removing dunnage before inspection. Other items of education include: the CFIA website, pamphlets targeting brokers and importers, articles in association (e.g. Canadian Manufacturers Association, Canadian Brokers and Agents, Chambers of Shipping, etc.) publications.

Further Information Canadian Food Inspection Agency: www.inspection.gc.ca/english/plaveg/for/cwpc/wdpkge.shtml Secretaría de Medio Ambiente y Recursos Naturales www.semarnat.gob.mx/wps/portal/.cmd/cs/.ce/155/.s/4044/_s.155/4014 Animal Plant Health Inspection Service: www.aphis.usda.gov/ppq/swp/export.html