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TIMBER PRODUCTS October 2024 HT Newsletter Volume: 10/08/2024
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 of the Month: Sir Isaac Newton
An object at rest stays at rest, and an object in motion stays in motion at a constant speed and direction unless acted upon by an external force.
The acceleration of an object is directly proportional to the net force acting on it and inversely proportional to its mass
For every action (force applied), there is an equal and opposite reaction.
Atheism is so senseless. When I look at the solar system, I see the earth at the right distance from the sun to receive the proper amounts of heat and light. This did not happen by chance.
As a blind man has no idea of colors, so have we no idea of the manner by which the all-wise God perceives and understands all things.
The motions which the planets now have could not spring from any natural cause alone, but were impressed by an intelligent Agent.
In the absence of any other proof, the thumb alone would convince me of God's existence.
Handling of "Reused" Pallets at WPM Facilities
Used IPPC marked pallets typically fall into three categories, damaged, repaired, and reused (pass-throughs). ALSC has determined that the term “Pass-Through” is not directly defined by ISPM 15 so going forward we will use the term “reused”.
ISPM 15 4.3.1 defines “Reused” 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.
When reviewing inbound pallets at an IPPC program facility, any units that do not fit the definition of reused will require obliteration of any IPPC marks and will then need to be heat-treated before a new IPPC mark can be applied. Used pallets can be sorted and those pallets that meet the definition of reused can be shipped without re-treating. There is no exception for used pallets only being wholesaled or those shipped domestic only. If used pallets are received at a program facility and appear to be repaired or altered, the old marks must be obliterated before they can leave the operation.
Facilities sorting reused pallets should have, at a minimum, a basic written process in place stating that they process both repaired and reused pallets on site. From there, the written addendum can be as complex as the facility wants to make it to fit their processes.
A reused pallet should have already been through the review process for bark and mark legibility, so it is not required that the facility review for bark again (in this category of WPM only). If you happen to see bark or illegible marks on WPM classified as reused, the pallet(s) should be corrected or removed from the reused inventory and placed in the repaired pallet inventory.
-UNLESS-
The reused pallets bear the number of the facility being audited. These reused pallets bearing the operation's number are subject to review for ISPM 15 requirements and is entered as a line item as conforming or non-conforming into the Monthly Audit Report.
ALSC further clarifies their position on this in a ratified response:
**“The staff position has been, and continues to be, that remanufactured WPM or repaired WPM where any doubt exists as to the heat treat compliance of all components shall have any existing ISPM 15 quality marks obliterated. This applies not only to a WPM manufacturer remanufacturing or repairing WPM onsite, but also applies to situations where that WPM manufacturer is aware the WPM has been remanufactured or repaired. Examples include sending WPM offsite to another facility to facilitate remanufacture or repair, bringing in WPM from a supplier known to be a remanufacture and/or repair operation, and receiving WPM from sister facilities remanufacturing or repairing WPM.
In effect, any WPM known to have been remanufactured or repaired where any doubt exists as to heat treat compliance of all components shall have original IPPC quality marks removed.”
(Ratified by ALSC November 14, 2008) (Amended November 8, 2013 to reflect 2009 ISPM15 changes)
EXEMPTIONS:
ISPM 15 & ALSC regulations for used pallets apply only at the location where the program is being implemented and monitored. Used pallets not located where the ISPM 15 program is being implemented (e.g., SHTF) do not fall under these requirements. Facilities with a separate location where used pallets are not sorted and are sold to customers for domestic use only, must have this separate location well defined as independent from the IPPC program facility in order to avoid issues with ALSC.
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 or inspector 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 the mark is re-applied.