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TIMBER PRODUCTS May 2024 HT Newsletter Volume: 05/02/2024
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
Director of Wood Packaging
Peachtree City 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.
Quotes from the 1950's
“Have you seen the new cars coming out next year? It won’t be long before $5000 will only buy a used one.”
“If they raise the minimum wage to $1, nobody will be able to hire outside help at the store.”
“I never thought I’d see the day all our kitchen appliances would be electric… They are even making electric typewriters now.”
"The American mind has not come to a realization of the evil which has been introduced into our midst. It rejects even the assumption that human creatures could espouse a philosophy which must ultimately destroy all that is good and decent.” J. Edgar Hoover
"Once a government is committed to the principle of silencing the voice of opposition, it has only one way to go, and that is down the path of increasingly repressive measures, until it becomes a source of terror to all its citizens and creates a country where everyone lives in fear." Harry S. Truman
“I am afraid that many among you are more concerned about making a living than making a life. You are prone to judge the success of your profession by the index of your salary and the size of the wheelbase on your automobile, rather than the quality of your service to humanity. The misuse of Capitalism can also lead to tragic exploitation.” Martin Luther King
"No amount of lying will alter the truth,—but lying can alter the willingness of a people to accept the truth.” Dean B. McLaughlin
“The one thing that doesn’t abide by majority rule is a person’s conscience.” Harper Lee
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.