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

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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.

12. 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 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)

13. 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.

14. 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.

15. 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.

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

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

18. Inspection

19. Inspection

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

21. 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.

22. 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.

23. Further Information
Canadian Food Inspection Agency:
Secretaría de Medio Ambiente y Recursos Naturales
Animal Plant Health Inspection Service: