TIMBER PRODUCTS February 2021 HT Newsletter Volume: 02/08/2021

Pass Through Pallets Defined

The "Pass Through" pallet process has been employed by some companies for years while for others it is a new concept.  The "Pass Through" pallet, as it is commonly called in the U.S., is what ISPM 15 terms as "Reused". 

ISPM 15 4.3.1 defines “Reused" (Pass Through) WPM as:

"A unit of wood packaging material that has been treated and marked in accordance with this standard and that has not been repaired, remanufactured or otherwise altered does not require re-treatment or re-application of the mark throughout the service life of the unit."

This definition is synonymous with how the "Pass Through" pallet has been defined.  Therefore, going forward, we will consider the terms "Pass Through" and “Reused” as describing the same thing.

Typically, there is a mixture of repaired and unrepaired pallets that come into a recycler.  Facilities implementing a "Pass Through" program can sort these pallets and segregate those that qualify as "Reused" according to ISPM 15.  Used pallets that meet the definition of “Reused” can be shipped without re-treating or mark obliteration.  Any used pallets received at a facility that do not fit the definition of “Reused”, must have the marks obliterated.  This includes any pallets received by a facility that appear to have been previously repaired or altered.  Any used pallets that do not qualify as a "Pass Through", but need to be ISPM 15 conforming, will need to be heat treated before the treating facility's IPPC mark can be applied.  Facilities that want to put their own IPPC mark on segregated "Pass Through" pallets will need to obliterate any previous IPPC marks and then heat treat them just like any other repaired pallet on site in order for their own mark to be applied.  Keep in mind that once a facility places their IPPC mark on pallets, they are responsible for all areas of conformance on the pallets including bark. Any facility monitored for ISPM 15 conformance may sort for "Pass Throughs" based on the "Reused" section of ISPM 15, but a written addendum should be in place to describe how these pallets are being processed. 

If a facility is not in the IPPC program, they are not allowed to represent any pallets coming from their operation as IPPC conforming since they are not monitored by an ALSC accredited agency.  This includes "Reused" pallets.  The only way an unmonitored facility can legally represent pallets coming from them as IPPC conforming is by having proof the pallets were processed by a facility that is monitored in the IPPC program whether they are purchased from the monitored facility or the monitored facility heat treats and marks the pallets as IPPC conforming for the unmonitored facility.

Recyclers should have a solid knowledge of what signs of repair disqualify a pallet for the "Pass Through" program.  These include evidence of previous nailing, differences in components (age, color, size, species), new nails in components, multiple IPPC marks, presence of plugs, etc.  A pallet with any of these characteristics would be disqualified from being considered a "Pass Through". 

Understanding what is required for conformance related to the "Pass Thorough" / "Reused" program will help any facility to successfully determine if utilizing it will be profitable for them.

Things Change and Rearrange

In these uncertain times, facilities can experience acquistions, relocations, and personnel changes that can directly affect the IPPC program with TP.  When changes in billing, location or personnel occur, please make certain to notify your TP Inspector or our office as early as possible.  Doing so can help to prevent issues like missing marks, payments or invoices.  Our clients are extremely important to us and your cooperation in this area is vital in keeping our information up to date.  Please let us know if you have any questions and thank you for assisting us in this area.