TIMBER PRODUCTS February 2017 Newsletter Volume: 02/16/2017

How to Conform

Conformance to the ISPM 15 program is the ultimate responsibility of the producer and TP’s function is to audit the facility’s procedures and material for conformance.  The information below comes from ALSC's Wood Packaging Material Regulations and ISPM 15.  If this information is incorporated into an operation's processes, it will eliminate 90+% of the reasons a facility can be found non-conforming.  There are two areas of importance for ISPM 15 conformance:  administrative (paperwork) and operational.

Administrative

Plant paperwork must be fully completed and available for review on a monthly basis.  Paperwork that is 2 or more months behind is considered non-conforming.  It is important to make sure the following paperwork is kept for a minimum of 2 years and always accessible to TP and ALSC.

• The facility’s QC procedures and any addendums.  TP must see these are present on every inspection.
• A monthly record in board footage of heat treated (HT) lumber a facility receives along with bills of lading or invoices to verify this volume received.  This record should show inbound receipts with a final monthly total included.
• A monthly record in board footage of all material that shipped with the facility’s IPPC or HT number on it.  This footage should be calculated by the facility themselves.  Any WPM or “HT” material that is produced strictly from received “HT” lumber should be tallied separately from material that is heat treated at the facility itself.  There should also be shipping records available to verify the shipment of this material and a separate monthly total section for each category of IPPC marked shipments and HT marked shipments.
• For facilities heat treating, mechanical charts recording the time and temperature for charges being treated need to be available for review as well.  These charts need to be printed up to the day of the inspector’s visit so if there are any nonconforming charges, the material may still be onsite for retreatment.

Operational

The following areas need to be addressed in order for conformance to be met.

• The IPPC marks are permanently assigned to a facility and must not leave its assigned specific location for any reason without prior authorization from TP management.
• Received “HT” lumber must be physically identified as such.  Inbound “HT” material without proper "HT" verification will be non-conforming.  Proper "HT" verification is mostly commonly shown with a full “HT” mark on each piece.  This mark will have:
• A complete and legible “HT” designation.
• A complete identifying symbol, logo or name of the ALSC accredited agency.
• A complete and legible mill origin identification number or name.

• “HT” and “IPPC” marked material must be kept separate from material that is not marked.
• Bark equal to or less than 1-3/16” in width can run the whole length of a board.  If any section of bark is greater than 1-3/16”, then the total surface area must not be more than 50 cm² (7.75 in²).  This is about the size of a credit card.  If in doubt cut it out.
• Obliteration is the complete removal or covering of the IPPC mark.  There must not be any portion of the mark visible (even through paint applied to it) or it is not considered conforming.  If non-obliterated marks equal 5% or less of each pallet size or type, it is considered conforming.  Anything greater than 5% is considered non-conforming.  Always aim for 100% obliteration.
• Stamp Application – The entire IPPC mark (including borders) must be present in order for this to be considered legible.  Marks missing any part can be considered non-conforming.  10% or greater illegible markings are a non-conformance.
• WPM that meets ALSC regulations must be stamped with a complete IPPC mark a minimum of two times on opposite sides of the product to be conforming.  These marks must be 6” from any other information.
• Dunnage material must be marked a minimum of one time.  More marks may be required if the material is to be cut up at a later time.  It is the facility’s responsibility to know how its dunnage marked material is being used to prevent misuse.
• Ink used to apply the IPPC mark cannot be red or orange.
• Heat chambers utilizing probes placed in the thickest wood of the charge must also be placed in the coldest spots in the chamber.  The hole the probe is placed in must be sealed with nonconductive material such as a rubber stopper, plumbers putty or foam like an ear plug.
• Heat chambers using probes placed in the thickest piece of wood must meet the time/temp requirement of 30 consecutive minutes at a minimum of 140°F and have mechanical documentation of this for verification.  Hand written records are not acceptable for this documentation.

This information relates to the most common non-conforming issues seen at facilities and is not meant to be an all-inclusive list.  Additional questions related to ISPM 15 program conformance can be addressed by your inspector or TP management.