Mr Roddie Burgess is giving quite interesting answers to the questions asked by Mr Stan Bowes, president of EPAL, and in addition, he is providing a critical view of the risks and of the purpose of the ISPM 15-standard.

Isn‘t the impostion of ISPM 15 an overreaction to a few small nematodes in Portugal?

I can see why, sitting here in Europe as we are, you might think that, but you need to remember that the development of ISPM 15 was in response to calls from all around the world to do something about the increasing numbers of new pest outbreaks many of us have had to deal with. The risks associated with movement of untreated wood has long been recognised and many countries, UK included, have had import requirements in place for many years for logs and sawn wood with consignments covered by phytosanitary certificates and subjected to plant health inspection both pre-export and at the point of import. Wood packaging was largely unregulated and often impossible to inspect - especially dunnage which quite often was left on board the ship or thrown away on the dockside or at the final destination. Any pests present, and there often were some, were really free to escape unchallenged and look for somewhere new to breed. And I would hardly describe the situation in Portugal as „a few small nematodes“. The numbers of pinew in 1999 runs well into the millions. Despite these efforts to stop it, PWN has spread widely across the country from the original outbreak site in Setubal and has just recently been found in Madeira. A single tree was also found infested in Spain in 2008 and there, too, many thousands of pines have had to be destroyed to eradicate it. The knock on effects are also major: environmental impact, loss of wildlife habitat: I could go on.

What are the many dangers of untreated packaging?

Let‘s start with the highest risk end and look at dunnage. At best, this might be totally square-sawn lengths of wood used as blocks or wedges. But at worst, they may be lengths of log, cut from infested trees, with all of the bark present and carrying hundreds of bark beetles or longhorn borers ready to fly. At the lower-risk end, we have pallets made to meet commercial standards, such as EPAL has in place, where the risk of pests being present is very much lower. In the middle, there is a range of other packaging products such as boxes, crates and cable drums which may not have to meet any sort of quality standard and which may be intended to be used once and thrown away. All sorts of pests problems could be hidden away there. Some of these products may, of course, start life off pest-free, and then be repaired somewhere along the way with anything that is handy.

What are, from your point of view, the main advantages of pallets users in a system where all new produced pallets are treated?

By treated, I take it you mean treated to ISPM 15 specifications? That means that all of the production going into circulation is known to be safe from a pest risk point of view. If there is no untreated packaging in the production chain, then there can be no room for mistakes, and customers will also be reassured on that point. You need to remember that if an import is refused entry across a national border because of non-compliant wood packaging, it is generally the shipper or the exporter who will suffer the costs- not the packaging manufacturer, and this could run to thousand of dollars a time. Shippers need to be confident in the packaging they use.

Do you think that the standard will be imposed across State borders in Europe?

It‘s a question of „when“ not „if“. While it is true that the impact of Pine Wood Nematode in Portugal is the main driver for this, it is not the only reason why, for example, I support it. Britain is an island nation and we are still free of many of the pests found on the continent - some of the bark beetles, for example, would have a very significant impact if they gained a foothold in our spruce forests. Our rules have for decades required wood packaging to be either bark-free or kiln-dried before being imported, but most people seem to have forgotten this now, thinking that because ISPM 15 does not apply here yet, there are no rules.

Why do you think there is no alternative to obligatory implementation of the IPPC-Standard*?

ISPM 15 is the only language now used world-wide and, as I just said, if there is no ISPM 15 requirement, many assume there can‘t be any requirement. It simply would not make sense to try to introduce an alternative for EU use only, for example. Most pallets are designed to have a long life and to be used again and again and it simply would not make sense to try to keep separate stocks with some available for use anywhere in the world and some only available for use with for a few customers (who will probably want to re-use them again themselves without hassle).

Are there any cheaper treatments being researched?

Yes, especially with the disappearance of methyl bromide in many parts of the world the heat is on, pardon the pun, to find alternative treatments. Approval may be some time off yet, but I know that there are a number of treatments being looked at, and the UK has for example been collaborating with partners in the USA, Canada and Italy, in preparing a submission on using microwave technology. We lodged that late last year and it does look promising.

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