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TIMBER PRODUCTS June 2019 HT Newsletter Volume: 06/14/2019
Online Newsletter
Matt McGowan - WPM Program Manager
mmcgowan@tpinspection.com
mmcgowan@tpinspection.com
Office: 770.785.4769
Mobile: 678.480.2451
Mobile: 678.480.2451
For more information on the IPPC program
Please contact:
Matt McGowan
WPM Program Manager
Conyers GA
Office 770.785.4769
Mobile 678.480.2451
The unauthorized and/or fraudulent use of the TP IPPC mark is illegal and a situation we take seriously. Anyone with information regarding the misuse of IPPC marks should contact TP's WPM Manager immediately. Thank you for helping to protect the integrity of the ISPM 15 program which is vital to our business and economy.
Education is the Key to Conformance
The most important areas for facility personnel to be cognizant of when considering ISPM 15 conformance are:
- Bark
- Obliteration
- Legibility
TP understands this and has created a set of modules for our clients to utilize in their training of personnel who need to know the requirements for ISPM 15 conformance. These training modules are in both English and Spanish and can be utilized in several ways:
- They can be printed and handed out to specific personnel.
- They can be reviewed online directly from a computer.
- They can be projected on a wall for group training.
Regardless of how they're utilized, they have been developed for your use so take advantage of these modules and employ them wherever and whenever they are needed. Simply click on the link below and then on the "WPM Training Resources" tab to see and access all training modules.
https://www.tpinspection.com/auditing-services/export-wood-packaging
Your inspectors are a great resource as well for information and training. Let us know if there are other areas you would like to see training modules developed. We see our relationship with TP clients as a partnership and while conformance is each facility's responsibility, TP wants to ensure we provide all the tools needed to properly train personnel on site.
Handling Used IPPC Marked Pallets
Many recyclers receive a mix of IPPC marked and unmarked pallets from a variety of sources. In this newsletter, we will discuss how to properly manage used IPPC marked pallets under several different scenarios. This article applies to facilities participating in the IPPC program and monitored by an ALSC accredited agency.
Used IPPC marked pallets are addressed on several levels in the American Lumber Standard Committee, Inc's Wood Packaging Material Regulations (November 7, 2014). First, a discussion on marked pallets in need of repair. If an IPPC marked pallet needs repair, Section 5.6.10 states:
"The existing ISPM 15 quality mark shall be obliterated when ISPM 15 quality marked wood packaging material is:
- Repaired: The existing quality marks on the wood packaging shall be obliterated unless the facility has an agency approved process in place to assure compliance to Section 4.3.2 of ISPM 15 in all respects, including assurance that all components of the repaired wood packaging material have been treated in accordance with the standard. When the existing quality marks on repaired wood packaging are obliterated, such wood packaging shall be remarked as ISPM 15 compliant only after the wood packaging material has been subjected to the heat treatment process.
- Remanufactured: The existing quality marks shall be obliterated. Such wood packaging shall be remarked as ISPM 15 compliant only after the wood packaging has been subjected to the heat treatment process."
ALSC treats repaired and remanufactured the same. If any wood is replaced or altered on an IPPC marked pallet, then the IPPC marks on the pallets must be obliterated on all areas of the pallet including its interior and stringer ends.
As a reminder, obliteration is the complete removal of the IPPC mark. If the mark can still be seen, even through paint already covering the mark, it is not considered obliterated and additional paint should be applied.
What if an IPPC marked pallet is not repaired at a facility?
If you do not repair a pallet but it appears to have been repaired or altered in the past, ALSC has clarified that any IPPC marks must be obliterated from the pallet. This is due to there being no way to verify the pallet was re-treated after the repair or alteration seen was done.
What if the IPPC marked pallet is not repaired onsite and it doesn't appear to have ever been repaired?
ISPM 15 categorizes this as a "Reused" pallet (what we commonly refer to as a Passthrough pallet) and Section 4.3.1 of ISPM 15 defines what is required for WPM to be considered “Reused”.
"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 reapplication of the mark throughout the service life of the unit."
Those pallets that meet the definition of “Reused” can be sorted from other used pallets and shipped as IPPC conforming without re-treating. It is important to create an addendum that describes the passthrough sorting process employed to avoid any possible confusion during an audit.
What if a facility simply receives pallets, does nothing to them and ships them right back out?
There are a couple of things to keep in mind with this scenario. First, there is no exception for used pallets that are being wholesaled or shipped domestic only. If an IPPC marked pallet is received at an ISPM 15 monitored facility and appears to have been repaired or altered, the marks must be obliterated. Second, Section 5.6.5 of ALSC Regulations state:
"When the quality mark of an accredited agency is applied, each wood packaging product shall be marked and wood packaging products bearing a quality mark shall not be mixed with non-marked products."
Regardless of a situation where all a facility does is receive pallets and then reships them, IPPC marked and unmarked pallets cannot be combined. So in a situation where IPPC marked and unmarked pallets are mixed together, the IPPC marks will need to be obliterated so no pallets in the shipment are IPPC marked when they leave the facility.
What about leased pallets?
Leased pallets (CHEP, PECO, etc.) that are not owned by the facility and are simply waiting for removal are not subject to review by the facility UNLESS the facility is repairing these pallets. If this is the situation, the facility is responsible for making sure any pallet that is repaired or appears to have been repaired has the IPPC marks removed and is re-treated before another IPPC mark is re-applied.