Entry Requirements for Wood Dunnage, Pallets, Crating, or Other Wood Packaging

This document originally appeared at: http://www.inspection.gc.ca/english/plaveg/protect/dir/d-98-08e.shtml
Date Modified: 2002-04-10



PLANT HEALTH AND PRODUCTION DIVISION,
PLANT PRODUCTS DIRECTORATE,
CANADIAN FOOD INSPECTION AGENCY
59 Camelot Drive
Nepean, Ontario, Canada, K1A 0Y9
(Tel: 613-225-2342; FAX: 613-228-6602)

D-98-08

(EFFECTIVE DATE)
April 10, 2002
(2nd Revision)

Title
ENTRY REQUIREMENTS FOR WOOD DUNNAGE, PALLETS, CRATING OR OTHER WOOD PACKAGING

Our File
3520-7-6 / 3525-llLl

I.  SUBJECT

This directive provides the requirements for the entry for all wood packaging, dunnage, pallets, or crating made from non-manufactured wood entering Canada from all areas except the continental United States (U.S.), China and Hong Kong. It also outlines the treatment or disposal procedures for all regulated wood packaging materials not meeting the entry requirement.

All attached dunnage shipped with other regulated wood products, i.e. spacers used withlumber, must comply with the entry requirements for the regulated wood products it is accompanying.

This revision has been undertaken to remove the phytosanitary certificate requirement for the entry of treated wood packaging. Some terminology has been clarified and some sections of the document re-ordered. Methods for the safe handling and disposal of non-compliant material has been added.




Table of Contents

Review
Endorsement
Amendment Record
Distribution
Introduction
Scope
References
Definitions, Abbreviations and Acronyms

1.0 General Requirements

1.1 Legislative Authority
1.2 Fees
1.3 Regulated Pests
1.4 Regulated Commodities
1.5 Commodities Exempt
1.6 Regulated Areas

2.0 Specific Requirements

2.1 Entry of Untreated Non-manufactured Wood Packaging
2.2 Entry of Treated Non-manufactured Wood Packaging

3.0 Inspection Requirements

4.0 Non Compliance

5.0 List of Appendices

Appendix 1 - Approved Methods of Treatment
Appendix 2 - Methods for the Disposal, Treatment or Processing of Non-compliant Wood Packaging
Appendix 3 - Application for Participation in the Non- Compliant Wood Packaging Disposal and Treatment Program




Review

This directive will be reviewed pending the outcome of the Interim Commission on Phytosanitary Measures’ adoption of a new International standard: "Guidelines for Regulating Wood Packing Material Used in the Transport of Commodities". The contact for this directive Joanne Rousson. For further information or clarification, please contact the Forestry section.

Endorsement

Approved by:


__________________________________
Director
Plant Health and Production Division

Amendment Record 

Amendments to this directive will be dated and distributed as outlined in the distribution below.

 Distribution 

1. Directive mail list (Regions, PHRA, USDA)
2. Provincial Government, Industry (via Areas)
3. National Industry Organizations (determined by Author)
4. Internet

Introduction

The risk represented by dunnage and packaging varies depending on the wood quality, conditioning and degree of finishing of the wood. The higher the grade and degree of finishing and conditioning, the less likely is the possibility of infestation. A large percentage of the wood packaging materials moving internationally is composed of low quality, inexpensive wood. In the past, many exotic plant pests have been intercepted on wood dunnage, pallets, crating or other wood packaging. In recent years, inspections of wood packaging associated with various cargoes from areas other than the continental U.S. have revealed the presence of several exotic insect pests of concern to Canada. Examples of plant quarantine pests intercepted are: Anoplophora chinensis, Anoplophora glabripennis, Ips typographus, Hylastes ater, Monochamus sp, and Trichoferus campestris. Also recent introductions of exotic forest pests, like pine shoot beetle (Tomicus piniperda) from Europe into the Great Lakes region of Canada and the U.S., and Asian Long-Horned Beetle (Anoplophora glabripennis) in the Long Island area of New York state, have been linked to international shipments containing wood dunnage or wood packaging material. Many other exotic forest pests have gained entry into North America on non-manufactured wood products used as dunnage or packaging materials.


Scope This directive is for the use of importers, CFIA inspectors, Customs & Revenue Canada, and exporters and plant protection organizations.
References NAPPO Standard 978.008

Department of the Secretary of State of Canada. The Canadian Style: A Guide to Writing and Editing. Toronto, 1993.

Canadian Food Inspection Agency. D-98-10 Import requirements for wood dunnage, pallets, crating or other wood packaging materials originating in China and Hong Kong special administrative region.

Canadian Food Inspection Agency. D-95-14 Importation of log, lumber and other unmanufactured wood products from all areas other than the Continental United States.

This directive supersedes D-98-08 (1st Revision), dated January 24, 2000. This policy does not supersede D-98-10 or D-95-14.

Definitions, Abbreviations and Acronyms

All definitions contained within the North American Plant Protection Organization, Glossary of Phytosanitary Terms, August 15, 1999 ; within the International Standards For Phytosanitary Measures, Glossary of Phytosanitary Terms, ISPM, Pub. No. 5, 1999 and within Amendments to the Glossary of Phytosanitary Terms, October 31, 2000 are included in this document.


Bark The external layer of a woody plant not including the vascular cambium which has the potential to harbour pests.
Bark-free wood Wood from which all evidence of bark has been removed.
Chemical Pressure Impregnation The process of impregnating wood with preservative or fire retardant chemicals by placing the wood and chemical in a pressure chamber.
CPI Chemical Pressure Impregnation
Dunnage Wood packaging material used to support a consignment but which does not remain associated with the consignment.
Manufactured wood Articles comprised wholly of wood-based products such as plywood, particle board, oriented strand board, veneer, wood wool etc., which have been created using glue, heat and pressure or a combination thereof.
NPPO National Plant Protection Organization
National Plant Protection Organization Official service established by a government to discharge the functions specified by the International Plant Protection Convention
Raw wood Wood which has not undergone processing or treatment.
Wood chips Untreated, raw wood fragments broken or shredded from logs or branch surfaces.
Wood packaging Wood or wood products (excluding paper products) used in supporting, protecting or carrying cargo
Wood packing Wood chips, sawdust or other processed wood product used to stabilize a commodity

1.0 General Requirements

1.1  Legislative Authority

The Plant Protection Act, S.C. 1990, c 22
The Plant Protection Regulations, S.O.R./95-212
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part I (05/13/2000)

1.2 Fees

The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. For information regarding fees associated with imported product, please contact the Import Service Centres (ISC) at the following phone numbers: Eastern ISC 1-877-493-0468; Central ISC 1-800-835-4486; Western ISC 1-888-732-6222. Anyone requiring other information regarding fees may contact any local CFIA office or visit our website at www.inspection.gc.ca.

1.3 Regulated Pests

Numerous. The following are examples of quarantine pests of Canada:

Insects

Rosy gypsy moth (Lymatria mathrua)
Gypsy moth (Lymantria dispar, Asian biotype)
Nun moth (Lymantria monacha)
Bark beetles (Ips typographus, Hylastes ater)
Boring beetles (Anoplophora spp., Callipogon relictus, Tetropium castania, Tetropium fuscumn, Trichoferus campestris, Monochamus sp.)
Wood boring wasps (Sirex noctilio)
Pine shoot beetle (Tomicus piniperda)

Pathogens

Watermark disease of willow (Erwinia salicis)
Bacterial canker of poplar (Xanthomonas populi)
Oak wilt (Ceratocystis fagacearum)
Dutch elm disease (Ophiostoma ulmi and Ophiostoma novo-ulmi)
Scleroderris canker (Gremmeniella abietina)
Sudden oak death (Phytophthora ramorum)
An unnamed disease affecting alder in Europe (Phytophthora sp.)

All other pests listed in Canada’s list of regulated pests.

1.4 Regulated Commodities

All species of non-manufactured wood used as dunnage, pallets, crating, or other packaging.

Note: logs, wood with bark attached, lumber, wood chips, bark chips, bamboo products, decorative wood items and cones without seed and other forest product imports are regulated by policy directive D-95-14.

1.5 Commodities Exempt

All manufactured wood used as dunnage, pallets, crating or other packaging.

Wood particles used as wood packaging such as: sawdust, wood shavings, used as packaging materials.

1.6 Regulated Areas

All countries outside the continental US, China and Hong Kong. The requirements for China and Hong Kong are described in D-98-10.

2.0 Specific Requirements

2.1  Entry of Untreated Non-manufactured Wood Packaging

 A Permit to Import is not required.

A Phytosanitary Certificate is not required.

All non-manufactured wood used as dunnage, pallets, crating or other packaging materials accompanying cargo from areas other than the continental U.S., China and Hong Kong must be: free of bark; free of pests (ie. any pest life stage of a pest: egg, larvae, pupa, adult, mycelium, fruiting bodies) and free of signs of living pests (ie. fresh frass, galleries or grub holes, bluestain)

2.2 Entry of Treated Non-manufactured Wood Packaging

A Permit to Import is not required.

A Phytosanitary Certificate is not required.

All treated non-manufactured wood packaging (including dunnage) accompanying a cargo from regulated areas (as defined in section 1.6) may be treated by one of the methods specified in Appendix 1. The details of the treatment must appear on a document (e.g. fumigation certificate, treatment certificate, commercial invoice, etc.), endorsed by the NPPO of the exporting country.

The CFIA may approve the entry of treated wood packaging without a document endorsed by the NPPO of exporting country provided the country has in operation a certification system for the approval and monitoring of facilities producing wood packaging. This certification system must ensure that wood packaging is treated in accordance with one of the methods specified in Appendix 1. A logo or mark, officially endorsed by the NPPO must be permanently affixed to each unit of wood packaging and must identify specifically the facility endorsed by the NPPO of the exporting country. Facilities must be approved by the NPPO to affix this mark to the treated wood packaging and the system of marking provided to the CFIA prior to any shipments being received. Please contact a local office of the CFIA to determine countries that have been approved.

3.0 Inspection Requirements

CFIA inspection staff will inspect vessels, berth facilities and imports containing wood packaging at a rate specified within regional work plans. Inspectors will inspect wood packaging for signs or symptoms of pests.

4.0 Non Compliance

Any regulated material found to be in non-compliance with the entry requirements specified, will be ordered removed from Canada or disposed of. In cases where a CFIA inspector has determined that it is both practically feasible and does not constitute a biological risk to introducing a pest, the non-complying imported commodity may be treated. Treatment may only be permitted when the person in possession of the non-compliant wood packaging has been registered in the Non-compliant Wood Packaging Disposal and Treatment Program (See Appendix 3). Treatment must occur in a manner approved by CFIA as identified in Appendix 2, within a designated time frame to be determined by an inspector.

Note: while awaiting shipment, ship borne dunnage may be stored either on board a vessel or at a Canadian berth in a fashion that will prevent infestation.

In the case where, a Canadian port or berthing facility receives dunnage from marine vessels, the port or berthing facility is responsible for ensuring that the dunnage is placed in a closed container (e.g. closed disposal bin, etc.). The port or berthing facility must ensure that the material is securely covered and where permitted by CFIA to be moved by a transporter to a disposal facility according to the procedures set out in Appendix 2.

All movement of non-compliant wood packaging must be authorized by CFIA on movement certificates issued to individuals in care and control of the non-compliant item. In some cases where a port or berthing facilities routinely receives dunnage, etc., the CFIA may issue a master movement certificate which permits ongoing disposal or processing of the non-compliant wood packaging.

Provided dunnage is maintained in the manner described above it may be used on outgoing ships provided the dunnage meets the entry requirements of the receiving country.

5.0 List of Appendices

Appendix 1 - Approved Methods of Treatment

Appendix 2 - Methods for the Disposal, Treatment or Processing of Non-compliant Wood Packaging

Appendix 3 - Application for Participation in the Non- Compliant Wood Packaging Disposal and Treatment Program


APPENDIX 1

APPROVED METHODS OF TREATMENT

1. Kiln Drying

All wood packaging material must be dried by heating in a kiln to a minimum internal core temperature of 56°C for 30 minutes. The wood must achieve a moisture content of below 20 percent, as expressed as a percentage of dry matter.

OR

2. Fumigation

Wood may be fumigated with methyl bromide at normal atmospheric pressure at the following rates:


Temperature Duration Dosage Rate
4.5 to 20.5 °C (40 to 69°F) 16 hrs. 80 gms/m3 (5 lbs/1000 ft3)
21°C (70°F) or above 16 hrs 48 gms/m3 (3 lbs/1000 ft3)

OR

Wood may be fumigated with sulphuryl fluoride at normal atmospheric pressure at the following rates:

Note: non-compliant wood packaging accompanying an importation may not be brought into compliance by fumigating the material in Canada with sulphuryl flouride.


Temperature Dosage Rate
15.5°C or above 64g/m3 for 24 hrs
4.5°C to 15.5 °C 80g/m3 for 32 hrs
OR 4.5°C to 15.5 ° 104g/m3 for 24 hrs

OR

3. Chemical Treatment

Chemical impregnation treatment with preservative solution of chromated copper arsenate (CCA) at strength of 1.72% oxides containing 0.58 to 0.68% arsenic acid and 0.80 to 0.95% chromium trioxide.

Note: non-compliant wood packaging accompanying an importation may not be brought into compliance by treating the material in Canada with this chemical preservative solution.

OR

4. Other treatment methods

The CFIA may approve other treatment measures, if it can be proven that such measures are effective in minimizing the risk of quarantine pests associated with the raw wood commodity. Importers should contact a local office of the CFIA to enquire about the use of other treatments. All costs associated with the verification that an alternative treatment method is effective in precluding pest movement into Canada, is to be borne by the importer.




APPENDIX 2

METHODS FOR THE DISPOSAL, TREATMENT OR PROCESSING OF NON-COMPLIANT WOOD PACKAGING



  1. Methods for the Disposal, Treatment or Processing of Non-compliant Wood Packaging

    CFIA may permit the movement and disposal, treatment or processing of non-compliant wood packaging provided facilities capable of meeting the standards prescribed here exist to conduct the disposal or treatment, that all costs incurred in the certification, inspection, monitoring, disposal, processing and/or treatment of wood packaging is absorbed by the importer or the person in care and control of the wood packaging and that the material is disposed or treated in a manner that precludes the transmission of pests to Canada. The following methods may be used to dispose or treat non-compliant wood packaging:

    • incineration or deep burial to a depth of no less than 3 metres that will not be disturbed, or,
    • treatment by kiln drying or fumigation as specified in Appendix 1. Note sulphuryl fluoride fumigation and CPI treatment may not be used for the treatment of non-compliant wood packaging in Canada.
    • processing to produce wood by-products such as wood dust, wood mulch, wood fuel, paper finish mulch, recycled fibre wood and oriented strand board or,
    • other methods as approved by the Plant Health and Production Division of the Canadian Food Inspection Agency.

  2. Transportation of Non-compliant Wood Packaging from Point of Entry to the Site of Disposal, Treatment or Processing

    Regardless of the process (described in section 1 of Appendix 2) by which non-compliant wood packaging is to be handled, the material may only be moved, if the transporter is approved by CFIA as specified on a Movement Certificate issued to the person in care and control of the non-compliant wood packaging. The wood must be moved in a closed container directly to the site at which treatment or disposal is going to occur.



  3. Specific Requirements for Disposal, Treatment or Processing

    Facilities disposing, treating or processing non-compliant wood packaging by the methods described in Section 1 of Appendix 2 must comply with the following specifications:

    • CFIA will only permit deep burial, if the non-compliant wood packaging material is buried at a minimum depth of three metres below the surface; the wood is buried at a site where the re-excavation of the material is not likely to occur in the foreseeable future; that any covenants required on land title to ensure that re-excavation does not occur can be completed.
    • The facility must have completed an Application for Participation as specified in Appendix 3. This application if acceptable to CFIA will be signed by an inspector confirming the facilities participation in the program. Until the facility is approved in this manner, the facility may not receive shipments of non-compliant wood packaging.
    • Facilities must undertake all disposal, treatment or processing in a Canadian establishment designated on the Application for Participation
    • Facilities must afford CFIA staff full co-operation for the purposes of carrying out audits, inspection, sample collection, product inspections, interviews of staff, etc.
    • A facility must have in its employ sufficient competent staff to undertake the requirements specified here and in the Application for Participation.
    • Facilities must ensure that all shipments of non-compliant wood packaging awaiting processing are stored in a closed container for a period from time of entry till the time of processing of no longer than 7 days. Storage areas must be isolated from other domestic wood commodities, material that has already undergone processing and adjacent forested lands by no less than 30 metres.
    • Any wood packaging that is not treated or processed including secondary products produced during processing must be disposed of in the manner approved by an inspector as specified on the Application for Participation in the Non-compliant Wood Packaging Disposal and Treatment Program. Disposal must be completed by no longer than 2 days following primary processing.
    • The period in which treatment, processing or disposal must be carried out may be extended by an inspector, provided the facility has additional mechanisms to mitigate the distribution of pests or there exists environmental conditions which preclude the distribution of pests (e.g. periods may be extended during the winter in some parts of the country). An inspector will provide in writing the period by which treatment processing or disposal must be completed.
    • Facilities must immediately notify a local CFIA office upon the detection of any unusualpests on non-compliant wood packaging or within the disposal or treatment facility.
    • The facility must maintain records pertaining to the handling, storage, processing or treatment of non-compliant wood packaging for a minimum of two years.



APPENDIX 3

APPLICATION FOR PARTICIPATION IN THE NON- COMPLIANT WOOD PACKAGING DISPOSAL AND TREATMENT PROGRAM



Name of Facility:
Name of Contact Person Title:
Address of Facility:
City: Province:
Address of Treatment Site:
City: Province
Telephone: Facsimile: E-mail:
1.  Type of Processing (check) Chipping to less than 2.5 cm Production of wood fuel
  Production of laminated or heat treated products (e.g. wafer board, oriented strand board, etc.)
  Other (describe process)
2. Storage Areas: Storage areas are closed and preclude pest escape
Storage areas are isolated from forested lands or other wood products
3. Indicate time required between receipt of non-compliant wood packaging and time to process:
4. Indicate what components of the non-compliant wood is not processed and how it is disposed of:


Conditions for Treating or Disposing of Non-compliant Wood Packaging:

  1. All wood non-compliant wood will be processed in the manner described above within the time frame provided above.
  2. Any non-compliant wood packaging that is not used for processing as described above, will be disposed in the manner described in 4 above.
  3. The facility will keep records of all shipments of non-compliant wood packaging received (e.g. shipping invoices, copies of movement certificates, etc.) and records of when these shipments were processed, treated or disposed off. Records will be maintained for a minimum of 1 year.
  4. Should a pest be found on non-compliant wood packaging or in the facility the CFIA willbe immediately notified.

I, ___________________________________ the owner/person in possession, care, or control of the above named facility have read and understood all the conditions and obligations stated herein by which I may dispose or treat non-compliant wood packaging (ship’s dunnage, crating or other wood commodities) in accordance with the Non-Compliant Wood Packaging Disposal and Treatment Program.

Further, I am and shall be responsible for and shall indemnify and save harmless Her Majesty the Queen in Right of Canada, including the Department of Canadian Food Inspection Agency, Her Officers, Servants, Employees, Successors and Assigns, from and against all manners of actions, causes of action, claims, demands, loss, costs, damages, actions or other proceedings by whomsoever made, sustained, brought or prosecuted in any manner based upon, caused by, arising out of, attributable to or with respect to any failure, inadvertent or otherwise, by act or omission, to fully comply with the said conditions and requirements.

Dated ,__________________ in the year _____________at ___________________, Province of

_____________________________
Applicant's Signature



Verification of Facility Procedures and Processes and Application Approved by:

_______________________________
Inspector
Canadian Food Inspection Agency

____________________
Date

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