ISPM 15 Standards

AKA The Story of Bug Free Pallets

    The issue of Bug Free Shipping Pallets would come to a head in October 2001 when the European Union issued an emergency measure requiring the treatment and marking of all new and used coniferous non-manufactured wood packaging material originating in the US and Canada effective immediately.  The  European Union's emergency measure would lead to the development and implementation of ISPM 15 Standards for nearly every developed country through the International Plant Protection Convention (IPPC) of the United Nations.

    The European Union's emergency measure followed an outbreak of Pinewood Nematode in Portugal and additional sightings of the Pinewood Nematode in some of the Scandinavian countries.  The European Union (EU) determined the Pinewood Nematode infestation in Portugal could be traced directly to the non-manufactured wood packaging material (NMWP) commonly used as packaging material, such as pallets and dunnage, for shipments to various EU ports of entry.

    The pinewood nematode is a microscopic eelworm, native to pine forests in North America, whose spread in North America is controlled by the North American Woodpecker (aka the North American Woodpecker Full Employment Act).  Outside of North America the Pinewood Nematode lacks a primary predator and has caused significant coniferous (pine, fir, spruce etc) and other soft wood mortality in China and Japan. 

    Because the Pinewood Nematode had expanded to China and Japan and the fact that pallets are commonly recycled by shippers, the EU emergency measure also applied to Japan, China and other Pacific Rim countries which may or may not have infestations of the pinewood nematode at that time.

    The EU emergency measure allowed the continued importation of hardwoods (oak, maple etc) for use as NMWP without restriction because the Pinewood Nematode will not invade the hardwood species.  The soft coniferous woods would require one of 3 treatment programs and approved markings applied to the NMWP.  Processed woods such as plywood or particle board would be exempt from the required treatment and markings because wood is cut thin and heat processed during the manufacturing.

     Within days of the original EU declaration, what was to eventually become technically known as ISPM-15 regulations or ISPM-15 standards, was derisively known at the Bug Free Pallet requirement.  The requirements are not funny, but the bug free pallet moniker has hung around never less.

Application of ISPM 15 to the Ceramic Industry

     Within days of the EU's emergency measure, the ripple effect was felt through the entire ceramic and pottery industry.  The largest manufacturers were hit first as multiple container loads of equipment and glazes were stopped at various European ports of entry and required additional fumigation before entry to the destination country could be allowed.

    As it is well known that Dogwood Ceramic Supply actively exports to some European countries we were among the first ceramic distributors to receive notice of the EU's decision, first by Scioto Molds and then later by Paragon.

    Faced with weeks or even months of the inability to export our goods (depending upon how our manufacturers handled the situation) Dogwood Ceramic Supply quickly acquired several stacks of plastic pallets so that we could continue to export to the Europe.  It was a good thing we acted when we did because within days of our plastic pallet purchases the supply of plastic pallets across the USA had been sold to vendors facing the same shipping dilemma as ourselves.

    Eventually the majority of the ceramic and pottery industry reacted.  Even though ISPM 15 complaint packaging materials are far more expensive than low cost pine pallets and packaging materials, Paragon was the first manufacturer to fully comply with what would become known as the ISPM 15 Standards by switching to heat treated (and certified) lumber for all aspects of kiln packaging.  Paragon's logic for switching the kiln crating to ISPM 15 Compliant lumber was for two pretty simple reasons: 1)  better internal operations with one type of wood packaging material and 2) they are never sure of the final destination of the kiln being purchased from distributor stock.  Even Mackie's Slip would eventually switch to hardwood pallets because of the overall simplification of using ISPM 15 Compliant pallets for every shipment rather than having two different pallet sources and stacks in the warehouse.

   However, as much as we would like, compliance to the ISPM-15 standards within the ceramic and pottery industry is not complete.  Many of the pallets used in the clay industry are not compliant with ISPM-15 standards simply because they assume the product will only be used within the Continental USA or Canada.  And some of the small mold companies refuse to comply with the ISPM-15 standards because of the cost issue associated with heat treated or otherwise compliant packaging materials.  Other some of the ceramic mold companies only offer ISPM-15 complaint packaging materials when they are specifically requested.  This lack of standardization across our industry continues to create issues from time to time as those who are unaware of the ISPM-15 standards attempt to export ceramic equipment and/or supplies.

ISPM 15 Standards Today

    In 2003 the International Standard for Phytosanitary Measures Publication 15 (aka ISPM-15 or ISPM 15 Standards) was developed directly from the 2001 EU emergency measure.  The main purpose of the ISPM 15 is to prevent the international transportation and spread of disease, insects and pests which could negatively affect plants or an entire ecosystem.

    The US Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) thru the US Customs and Border Protection Service is responsible for implementation and enforcement of ISPM-15 for goods to be imported into the United States effective September 2004 per US 7 CFR 317.40.  APHIS has further recognized several families of timber pests (insects) which may be found alive on imported wood products even following proper treatment.  When these families of pest are found on imported wood products the entire shipment will be immediately re-exported at the expense of the shipper.

    Currently US Law exempts shipments between the US and Canada from the ISPM-15 requirements because the porosity of the US-Canadian border applies to both people and bugs.

(Ok, the law isn't exactly written that way...
but think about it, it is a little hard to keep our little bugs from flying or walking over the border and visa-versa.)

    That said, USDA/APHIS as well as their Canadian counterparts will be conducting hearings starting in January 2011 regarding the application of the ISPM-15 regulations for any shipment that crosses the Canadian-US border.  In spite of the porosity of the US-Canadian border for insect travels (and just about anything or anybody else) it is anticipated that ISPM-15 regulations will eventually apply those shipments effective during 2012 if for no other reason than to standardize the tasks of US and Canadian Customs at every border crossing.

    For further information concerning the proper marking of ISPM-15 compliant NMWP please refer to ASTM D6253 Treatment and/or Marking of Wood Packing Materials as well as appropriate governmental agencies.

ISPM 15 Standards, Postscript

    We continue to hear from customers outside of the United States who request, no demand, that we forgo the more expensive ISPM-15 complaint packaging for shipments to their country.  Often these potential customers proclaim that others in our industry are ignoring the US and international laws regarding ISPM-15 complaint materials.  We hope these proclamations are just weak attempts to save money on shipping costs.

   Maybe they are, maybe they are not.

   What we do know is that if aggressive monitoring and prevention practices had been in place in prior decades the United States would not be facing the infestation of Formosan Termites (Coptotermes formosanus) or the imported Red Fire Ant (Solenopsis invicta).  Something to think about the next time you want to take a short cut or shave a few pennies off the shipping costs.

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A little lesson on the historical development and impact of the ISPM-15 Standards, also known as the bug free pallet requirement, on the ceramic industry.