CASE STUDY of UK Implementation of ISPM 15

CASE STUDY of UK Implementation of ISPM 15 JOHN MEAD for UK TIMBER PACKAGING and PALLET CONFEDERATION (TIMCON)

TIMCON • UK Trade confederation established in 1957 • 120 members • Manufacture and repair all types of wood packaging • Member of European wood packaging Federation (FEFPEB) • Associate and overseas members enrolled

EUROPEAN IMPLEMENTATION • TIMCON undertook presentations after UK pilot programme success from 2001 • UK operational model taken as example to copy by many EU Countries • Principles and practicies adopted widely • Each Country responsible for their own implementation

ADVISORY COUNCIL Trade Associations • • Timber suppliers New pallet producers Case makers Export packers Repairers and traders Inspection Fumigation Treatment

PILOT CONSULTATION 2001 • Consultative committee seen as VITAL for success • UK voluntary marking programme started • Partnership approach • Developed in line with realities of trade • Based on future requirements of ISPM 15

INDUSTRY COMMITMENT • Saw the trading necessity to have treatments available • Encouraged investment in HT chambers • Worked with Forestry Commission to iron out procedures • Regular consultative meetings important

DETAILED ASSESSMENT REQUIREMENTS for UK COMPANIES • • Reject process defined Designated person on each site Penalties for abuse Appeals procedure established

COSTS and CHARGES • REGISTRATION Fee £uk 400 (~us$700) • COMPANIES INITIAL ASSESSMENT FEE negotiated with assessing companies • 6 monthly RE-ASSESSMENT FEE as above • COSTS of any APPEAL

PRACTICAL PROMOTION • Conferences for Exporters • Presentations to exporting agents • Emphasis on adoption by importing countries • Articles in exporters trade magazines • Many presentations to packaging manufacturing companies

CURRENT IMPLEMENTATION • 500 REGISTERED SITES • Treatment capacity has exceeded demand growth • External assessment companies and producers work together • Slower acceptance in recycling sector companies

TREATMENT CAPACITY AVAILABLE • 49 COMPANIES WITH CHAMBERS • 8 PROFESSIONAL FUMIGATING COMPANIES • 3 ASSESSSMENT COMPANIES

Heat treatment chamber

Computer control data

Probes

CALIBRATION OF EQUIPMENT AND PROBES • Technical calibration must be undertaken at start up • Recalibration of sensitive items is needed regularly • Positioning of probes must be consistent to justify treatment correct • Computer recording must link to audit records

Hand Branding

Marked block

Hand stencilling

Stencilling

Methyl bromide treatment

Costs • Treatment means higher costs • Treatment is a requirement • Non-competitive effect

TREATED RAW MATERIAL IMPORTS • Certified mills in country of origin • Audit trail required through shipment documents • BLUE STAIN • FUNGUS

Imported packs of HT timber

CHAIN OF CUSTODY • Use of imported packs must be capable of being audited • Volumes received must reconcile to use • System must demonstrate consistency and transparency • Responsible person is accountable

Treated pallets segregated in yard

PROTECTION OF MARKS • Integrity of system vital • A level playing field is the objective • Controls have to keep out false marking to protect investment of registered companies • Encourage the passage of information to the plant health authority • Confidentiality of information source maintained • Penalties must be real

ENFORCEMENT • Audits by appointment • Power to inspect • Power to remove registration

PENALTIES • • Warning of concern Required to re-treat and re-mark Payment of further assessment costs Removal of registration for further noncompliance

Repair, remanufacture and recycling • Removal of previous mark and re-treatment and re-marking is required • Reuse without further treatment may be valid in specific known reuse systems

DEMAND by International “User” Corporations • Adopted the KISS principle at the end of their production lines • Too hard to buy and use different pallets • Decisions to “only” buy all pallets treated • Developing steadily an inventory of treated pallets

SUMMARY • Industry Partnership between the “Regulators” and “Regulated” • Companies commitment • Clear and acceptable requirements • Monitoring and controls consistent

Message from PRESIDENT of EUROPEAN PACKAGING FEDERATION • COMMITMENT OF COMPANIES IS VITAL • WOOD PACKAGING QUALITY is IMPROVED by TREATMENT • REGULAR CONSULTATION WITH the National Plant Protection Organization NEEDED

WEB SITES for reference UK EU TIMCON. org fefpeb. org Thank you for your attention