Most pallets that are exported from the US must be Heat Treated in order to gain entry into countries throughout the world

General Questions

WHAT IS WOOD PACKING MATERIAL?

Wood Packing Material (WPM), also known as solid wood packing material (SWPM) and non-manufactured wood packing (NMWP), is defined as “wood packing other than that comprised wholly of wood-based products such as plywood, particle board, oriented strand board, veneer, wood wool etc., which has been created using glue, heat, and pressure or a combination thereof.” This includes pallets, crating, packing blocks, drums, cases, load board, pallet collars, skids, etc.

ARE PALLETS ONLY AFFECTED?

No. The standards require all dunnage, including skids or runners used to transport bundles of lumber, to be heat treated as well.

CAN I APPLY THE MARKINGS AS SHOWN EVEN IF THERE IS NO AGENCY OVERSIGHT PROCESS ESTABLISHED WITHIN MY COUNTRY RIGHT NOW?

No, each National Plant Protection Organization (NPPO), the United States organization is USDA’s Animal Plant Health Inspection Service (APHIS), is responsible for oversight of the program, the use of marks must be coordinated with the NPPO. Companies that use the marks improperly will be investigated, possibly prosecuted, and probably fined.

WHAT LIABILITY DO I HAVE FOR THE HEAT TREATMENT PROCESS ON MY PRODUCTS? DOES PRODUCT LIABILITY INSURANCE COVER THIS PROCESS?

A manufacturer produced, heat treated and affixed a quality mark or grade stamp upon the treated wood packaging material. The material purchased and used for its intended purpose by a company that shipped their product overseas whereupon the port authority denied delivery due to the fact the pallet was not properly heat-treated and potentially contained a form of pest or bacteria. The shipping company then wanted to initiate legal proceedings against the manufacturer of the pallet for this scenario could only be a monetary loss as no physical damage occurred to their shipped product.

In the above example the general and products liability policy would not respond, as there was an absence of "bodily injury or property damage." Furthermore, the policy excludes coverage for "Impaired Property." Impaired property is defined as a product that has a defect, deficiency, inadequacy or contains a dangerous condition. The policy also excludes the recall of products, work, or impaired property. Unfortunately the above scenario is an uninsurable occurrence.

The shipper could bring suit against the manufacturer and the insurance company would have the "right" to defend but not a "duty to defend."

There must be a physical loss to the shipper’s property for the General Liability policy to respond. To change the above scenario, if it was determined that pests infiltrated the product and caused damage, and the proximate cause of the pests was attributed to improper heat treating, then the policy could respond to incurred damages, but this could be difficult to litigate since a pallet changes hands constantly. But again, the recall expense of the pallet would still be excluded.

Products recall coverage only covers the following expenses:
Communication Expenses (telephone, radio, TV, newspaper);
Production of written announcements (printing, stationary, postage);
Paying employees overtime in excess of normal levels;
Compensating persons, other than employees, needed to provide phone coverage;
Shipping, or handling or warehousing of the recalled product;

Disposing of the product that cannot be reused, but only to the extent that the risk has been specifically billed for such expense.

The coverage does not pay for costs associated with redistribution or replacement of the withdrawn products with like products, or the repair of the withdrawn product.

In synopsis, the likelihood of a claim or suit arising out of properly treated wood is minimal. But our highly litigious society you don’t ever know and anything is possible. This is only an educated opinion. The Service Corporation recommends that you review your policy with your insurance professional and legal counsel.

HOW MANY COUNTRIES ARE MEMBERS OF THE IPPC?

The United Nations Countries number is 170 Countries. The IPPC is a convention of these members.

WHY STANDARDS OR REGULATIONS?

They are designed to stop the spreading of exotic pest to other countries. In the past exotic pests have proven detrimental to key U.S. species. One of the more dramatic infestations resulted from the introduction of the chestnut blight. It was brought over from China 100 years ago and quickly spread through the Appalachians, destroying Native American chestnuts and eradicating the species from major round wood and nut makers.
Recently, Chicago neighborhoods have been clear-cut in vain attempts to control the Asian Longhorned Beetle, which was brought into U.S. warehouses via packing materials. New York Central Park has also been heavily hit by several pests.

The new standards will standardize the countries into one standard instead of having standards for each individual country. It is also prevents countries using the standards to control or limit trade.

WHAT METHODS CAN BE USED TO SATISFY THE STANDARDS?

Acceptable treatment measures include heat treatment of solid wood components and fumigation of packing material with methyl bromide.

The official heat treatment program recognized by the USDA Animal Plant Health Inspection Service and the IPPC calls for solid wood components (hardwood and softwood) of packing material to be brought to a core temperature of 56º C (about 133º F) for a minimum of 30 minutes. The product must be stamped or marked by a registered agency.

WHO WILL BE AFFECTED BY THESE MEASURES?

These regulations will not only affect pallet, box, and crate manufacturers/users, but also anyone shipping lumber over seas using solid wood skids and sticks.

No. There must be a resident quality mark for each facility where the treatment has taken place.

HOW IS LOOSE DUNNAGE BEING TAKEN CARE OF?

Dunnage is to be stamped with the quality stamp that has “HT DUN” written on it. It is to be heat treated and must comply to the ISPM15 standards also.

standards do not clearly outline this practice.

CAN BRANDERS BE USED ON MACHINERY TO BRAND THE PALLETS AS THEY ARE BEING MADE INSTEAD OF AFTER THEY ARE HEAT TREATED?

No. The American Lumber Standards Committee indicates that this is not an acceptable practice. The quality mark must be placed on the material after it is treated.

CAN A ROLLING MARK BE USED ON THE SIDE OF PALLETS?

Yes, a rolling mark may be used after the treatment process.

I HAVE BEEN RECEIVING SOFT WOOD AND HARD WOOD THAT HAVE JUST BEEN STAMPED "HT" ... BUT NOT THE GRADE STAMP THAT INCLUDES THE AGENCY LOGO AND PLANT NUMBER. CAN THIS HT LUMBER BE USED TO CONSTRUCT THE PALLETS FOR A STAMP (OR QUALITY MARK)?

No, the heat treated lumber must have the grade stamp that is audited by an agency prior to placing the quality mark. This is the same answer that was given in the course, but there was some doubt about it. I confirmed it with the American Lumber Standards Committee.

WILL LUMBER SHIPMENTS BEING SHIPPED AS A COMMODITY IN ITSELF BE AFFECTED?

The IPPC standards only apply to non-manufactured wood packaging material used in transporting commodities.

HOW LONG DOES HEAT TREATMENT LAST?

Once components or pallets have gone through the heat treatment process, they are “heat treated” until removed from use.

WHAT IS A TYPICAL KILN SCHEDULE FOR HEAT TREATING HARDWOOD?

It would seem that most will heat treat the assembled pallets rather than that in cant form. (It may prove too difficult to saw and nail HT boards that have lost much of their moisture.) There are a few ways to prove that core temperature reaches 140º Fahrenheit. One includes direct measurements of core temperature by placing probes into drilled holes. The other requires the use of live steam with a maximum wet bulb-dry bulb depression of three percent. Schedules have been developed based on specific gravity, lumber dimension, and chamber temperatures.

HOW DO WE HANDLE RECYCLED PALLETS?

Recycled pallets must be completely treated. If packaging materials are repaired the entire unit must be retreated and marked.

 

 

 

 

Above  is an example of a Heat treating stamp issued by Timber Products Inspection, Inc www.tpinspection.com

All Heat Treating facilities have their own number to identify and certify the pallets that they Heat Treat for their customers. Westside has gone through a certification process with TP and is audited monthly to ensure compliance with USDA/APHIS and IPPC regulations.