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[GreenYes] Wood/ Lumber Based Packaging and exotic pests- danger to forest resources
RE: Crates, pallets and other solid wood packaging

Of Interest to Composters/Arborists/ Wood Reusers and 
Procurement Officers and Specification Writers

This is a little off the typical recycling issue but does have 
bearing of those of us who work on finding reuse and 
recycling markets for lumber products.  This notice does 
not mention or discuss if any pests introduced in pallets 
and other wood packaging could be transmitted by 
mulching or composting.  

Back in 1990 I participated in a packaging
project.  During this project, the types of packaging used in
electronics was studied and discovered the lumber based 
packaging was the highest form of packaging, 
corrugated paper and chipboard coming in second.  I think 
we all know about pallets but may not be as familiar with 
other wood crating which for example is used in shipping 
large computers and electronics.  

If you have technical questions on this issue email to 
Faith Campbell, American Lands Alliance, at 202-547-9120; or
mailto:phytodoer@aol.com <mailto:phytodoer@aol.com> 


Ann Schneider                                            
Originally sent to me by AnnettePuskarich
annette_puskarich@city.palo-alto.ca.us>.


Subject: Packaging and exotic pests- danger to forest resources
 
The dangers of the global marketplace!!!!    
To: Concerned Arborists

From: Faith T. Campbell, Invasive Species Program, American Lands
Alliance

Date: January 26, 2001

Mark Stennes suggested I contact you concerning the need for letters to
the
U.S. Department of Agriculture urging strong safeguards to prevent
introduction of exotic pests that threaten our forests.

The USDA Animal and Plant Health Inspection Service (APHIS) is accepting
comments on a Risk Assessment that analyzes the danger to America's
forest
resources posed by pests that might be introduced on crates, pallets, and
other forms for solid wood packaging.  The deadline for comments is
February
15, 2001.  (The risk assessment can be obtained online from
http://www.aphis.usda.gov <http://www.aphis.usda.gov> .)

As arborists well know, alien or exotic pests have already severely
damaged
America's forests.  The worst of 400 exotic insect species and 24
pathogens
have virtually eliminated from our forests American chestnut, butternut,
and
Fraser fir; continue to kill American elm; and have caused severe
declines
of western white pines, Port-Orford-cedar, eastern dogwood, eastern 
hemlock, and American beech.

As trade expands, so do the opportunities for a hitchhiking pest to reach
the U.S.  Our best defense is effective phytosanitary (plant health) 
safeguards adopted and enforced by APHIS.

Crates, pallets, and other forms of "solid wood packing material" (SWPM)
often transmit damaging pests.  The most famous example of a pest
introduced
via this pathway is the Asian longhorned beetle -- which has the
potential 
to alter North American ecosystems across the continent, especially the
48
million-acre northern forests dominated by maples from New England to
Wisconsin, as well as forests dominated by poplars and aspens.  Efforts
to
exterminate the ALB have meant the destruction of more than 5,000 trees
in
the New York and Chicago metropolitan areas.  According to the risk
assessment, if the Asian longhorned beetle became established in all
cities
containing vulnerable tree species, damage could reach $522 billion
within
30 years.

Other damaging pests that have not yet been introduced, but which easily
could be, include the Sirex wood wasp and its fungus, which could attack
pines anywhere in the "lower 48".  It is known to feed particularly on
California's Monterey pine and the South's widespread loblolly pine. The
European spruce bark beetle Ips typographus could threaten Sitka and
Engelmann spruces.  If the associated fungus Ceratocystis polonica 
were also introduced, the beetle/fungus combination could "be as 
disastrous to North American spruce as the Dutch elm disease was to 
elms."  The European oak bark beetle could exacerbate the damage 
caused by oak wilt fungus.

Since imported crates and pallets go to all parts of the country, the 
danger is everywhere.

Many kinds of products are packaged in wood and APHIS lacks sufficient
personnel to inspect them all.  Since APHIS often does not know whether a
particular shipment contains SWPM, much less the type of wood and 
country of origin, it cannot set priorities for inspection.  Besides,
pests 
often are not found by the inspectors.  If a pest is present but not 
detected, it can travel with the SWPM to the product's final destination
-- 
anywhere in the country.  Then the SWPM is often stored outside --  
providing more opportunities for pests to escape.

Although American Lands believes the risk assessment fully justifies
APHIS'
adopting stronger phytosanitary program to curtail introductions of pests
hitchhiking in wood packaging, we do not yet know what importance the
incoming bush administration will give to reducing the risk from such
bioinvaders.  We anticipate that a comprehensive, vigorous approach will
be
greeted by strong opposition from importers and various trading partners.

Furthermore, environmentalists need to reiterate our opposition to
relying
on fumigation using methyl bromide, which depletes the stratospheric 
ozone layer.  Other, more effective measures are available -- however, 
they do cost more.

I encourage individuals and organizations to send their own letters to
APHIS.

This is the most effective step you can take to help ensure adoption of
strong phytosanitary regulations.  To do so, you should send the original
and 3 copies to Docket No. 98- 057-2, Regulatory Analysis and Development
PPD,
APHIS, Suite 3C03, 4700 Riverdale Road, Unit 118, Riverdale, MD
20737-1238.
You may use my letter as a basis for writing your own.  If you choose to
write your own letter, but would like my help in keeping informed about
developments, please send me an email to that effect.

If you prefer, you are welcome to endorse the letter which I have
written,
which can be found at

http://www.americanlands.org/forestweb/wood_packing_comment_letter.htm
<http://www.americanlands.org/forestweb/wood_packing_comment_letter.htm> 

So far, 39 organizations and 53 individuals have endorsed this letter.

For further information about the wood packaging issue or to endorse the
letter, contact Faith Campbell, American Lands Alliance, at 202-547-9120;
or
mailto:phytodoer@aol.com <mailto:phytodoer@aol.com> .  To be counted as
an
official comment you must state your name and full address.  If you are
signing 
on for an organization, please give the name, address, and telephone
number 
of that organization.

If you provide an email address, I can send you the final letter listing
all
the endorsing individuals and organizations, and keep you informed about
progress on this issue.

Thank you for helping on this important matter.

Paul Dykema
Forestry Manager
717 E. Shiawassee
Lansing, MI 48912
Pdykema@ci.lansing.mi.us
Telephone 517.483.7674
Fax 517.377.0047




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