CASE STUDY of UK Implementation of ISPM 15

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CASE STUDY of UK Implementation of ISPM 15

• JOHN MEAD
• for
• UK
• TIMBER PACKAGING and PALLET CONFEDERATION
• (TIMCON)

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TIMCON

• UK Trade confederation established in 1957
• 120 members
• Manufacture and repair all types of wood
  packaging
• Member of European wood packaging Federation
  (FEFPEB)
• Associate and overseas members enrolled

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EUROPEANIMPLEMENTATION

• TIMCON undertook presentations after UK pilot
  programme success from 2001
• UK operational model taken as example to copy by
  many EU Countries
• Principles and practicies adopted widely
• Each Country responsible for their own
  implementation

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ADVISORY COUNCILTrade Associations

• Timber suppliers
• New pallet producers
• Case makers
• Export packers
• Repairers and traders
• Inspection
• Fumigation Treatment

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PILOT CONSULTATION2001

• Consultative committee seen as VITAL for success
• UK voluntary marking programme started
• Partnership approach
• Developed in line with realities of trade
• Based on future requirements of ISPM 15

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INDUSTRY COMMITMENT

• Saw the trading necessity to have treatments
  available
• Encouraged investment in HT chambers
• Worked with Forestry Commission to iron out
  procedures
• Regular consultative meetings important

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DETAILED ASSESSMENT REQUIREMENTS for UK COMPANIES

• Reject process defined
• Designated person on each site
• Penalties for abuse
• Appeals procedure established

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COSTS and CHARGES

• REGISTRATION Fee uk 400 (us700)
• COMPANIES INITIAL ASSESSMENT FEE negotiated with
  assessing companies
• 6 monthly RE-ASSESSMENT FEE as above
• COSTS of any APPEAL

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PRACTICAL PROMOTION

• Conferences for Exporters
• Presentations to exporting agents
• Emphasis on adoption by importing countries
• Articles in exporters trade magazines
• Many presentations to packaging manufacturing
  companies

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CURRENT IMPLEMENTATION

• 500 REGISTERED SITES
• Treatment capacity has exceeded demand growth
• External assessment companies and producers work
  together
• Slower acceptance in recycling sector companies

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TREATMENTCAPACITY AVAILABLE

• 49 COMPANIES WITH CHAMBERS
• 8 PROFESSIONAL FUMIGATING COMPANIES
• 3 ASSESSSMENT COMPANIES

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Heat treatment chamber
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Computer control data
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Probes
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CALIBRATION OF EQUIPMENT AND PROBES

• Technical calibration must be undertaken at start
  up
• Recalibration of sensitive items is needed
  regularly
• Positioning of probes must be consistent to
  justify treatment correct
• Computer recording must link to audit records

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Hand Branding
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Marked block
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Hand stencilling
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Stencilling
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Methyl bromide treatment
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Costs

• Treatment means higher costs
• Treatment is a requirement
• Non-competitive effect

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TREATED RAW MATERIAL IMPORTS

• Certified mills in country of origin
• Audit trail required through shipment documents
• BLUE STAIN
• FUNGUS

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Imported packs of HT timber
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CHAIN OF CUSTODY

• Use of imported packs must be capable of being
  audited
• Volumes received must reconcile to use
• System must demonstrate consistency and
  transparency
• Responsible person is accountable

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Treated palletssegregated in yard
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PROTECTION OF MARKS

• Integrity of system vital
• A level playing field is the objective
• Controls have to keep out false marking to
  protect investment of registered companies
• Encourage the passage of information to the plant
  health authority
• Confidentiality of information source maintained
• Penalties must be real

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ENFORCEMENT

• Audits by appointment
• Power to inspect
• Power to remove registration

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PENALTIES

• Warning of concern
• Required to re-treat and re-mark
• Payment of further assessment costs
• Removal of registration for further
  non-compliance

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Repair, remanufacture and recycling

• Removal of previous mark and re-treatment and
  re-marking is required
• Reuse without further treatment may be valid in
  specific known reuse systems

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DEMAND by International User Corporations

• Adopted the KISS principle at the end of their
  production lines
• Too hard to buy and use different pallets
• Decisions to only buy all pallets treated
• Developing steadily an inventory of treated
  pallets

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SUMMARY

• Industry Partnership between the Regulators and
  Regulated
• Companies commitment
• Clear and acceptable requirements
• Monitoring and controls consistent

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Message from PRESIDENT ofEUROPEAN PACKAGING
FEDERATION

• COMMITMENT OF COMPANIES IS VITAL
• WOOD PACKAGING QUALITY is IMPROVED by TREATMENT
• REGULAR CONSULTATION WITH the National Plant
  Protection Organization NEEDED

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WEB SITES for reference

• UK TIMCON.org
• EU fefpeb.org
• Thank you for your attention