Combating Non-compliant Dunnage from Maritime Cargo at US Ports
Monday, March 9, 2020
During a vessel discharge last summer, a Customs and Border Protection (CBP) inspector and the U. S. Department of Agriculture (USDA) identified a restricted insect in a piece of wood dunnage from a vessel at the port. The vessel owner was instructed to reload all the dunnage back on the vessel and take it to a location outside the United States. In order to comply with this re-export directive, the vessel had to sail to a South American country that would accept the dunnage, costing the vessel time and $300,000 for this diversion.
Shippers often deal with expensive re-exportation requirements because of the standards set forth in the International Standards for Phytosanitary Measures No.15 (ISPM 15). Under ISPM 15, the contaminated wood – and sometimes the cargo it protects – must depart U.S. waters and be taken to a port that can accept it, fumigate, dispose of the infested wood, and, when necessary, repackage the cargo to return to its original destination. One carrier reported spending $2 million buying dunnage each year and another $1 million to dispose of it.
ISPM 15 regulations were instituted globally to help eliminate the spread of pests and diseases impacting a country’s ecosystem via wood packaging materials (WPM) used in international trade. This applies to any timber-based packaging such as pallets, boxes, crates, dunnage or drums when shipping products internationally.
Pests in WPM include wood-boring pests, such as the emerald ash borer, Asian longhorn beetle, and wood wasp, that can destroy billions of dollars’ worth of U.S. trees and forestland. The USDA estimates that removal and remediation of damage by the emerald ash borer alone has cost at least $10 billion since the pest was first discovered in the United States in the early 2000s. From 1997 to 2006, the USDA’s Animal and Plant Health Inspection Service (APHIS) and the states of New York, Illinois and New Jersey and local government agencies have spent more than $800 million on measures to eradicate the Asian longhorn beetle. As of 2015, APHIS and the states of New York, Massachusetts and Ohio are also fighting Asian longhorn beetle infestations.
Combating Infested Dunnage
Infestation prevention rather than cure is always the optimum goal. To this end, some shippers use reusable plastics, rubber, or metal pallets rather than timber-based dunnage. When WPM is the best dunnage for cargo, shippers seek a quality, reliable packaging firm to keep their dunnage free from pest infestation problems. The timber-based dunnage will have an ISMP 15-compliant treatment mark – sometimes known as the “wheat stamp” – applied to the wood. This assures the shipper that all WPM dunnage has been heat-treated or fumigated according to ISMP 15 rules and certified as compliant dunnage for international cargo.
As indicated previously, even stamped, compliant dunnage has sometimes revealed an invasive pest when inspected at the port of call, triggering re-exportation measures and even the potential for fines. In 2016, USDA’s Animal and Plant Health Inspection approved incineration as a disposal option for non-compliant dunnage from maritime cargo at U.S. ports of entry, if there was access to an APHIS-approved incineration facility. This option allows shippers a solution that is more economical and faster.
The incineration facility must have a compliance agreement with APHIS to destroy and dispose of non-compliant dunnage. Transportation companies, shipping lines, and port authorities must have a compliance agreement with CBP to safeguard, manipulate, or transport non-compliant dunnage.
In the Houston port region, R Warehousing & Port Services Inc., a Richardson Company, recently announced an approved incineration site at their location on Clinton Drive in Galena Park. (For further reading, the announcement is published in the Member Updates section of this magazine.)
Houston Wood Packaging and Dunnage Coalition
The Houston Wood Packaging and Dunnage Coalition was informally established in April 2019, comprised of approximately 50 companies and organizations that are a cross section of stakeholders representing the major companies involved in the international supply chain for imported steel products and project cargos.
The driving force of the Coalition has been to interact with CBP, the USDA, and independent companies to develop workable solutions to combat the importation of non-compliant wood packaging and dunnage used in maritime transportation and trade. Since forming last April, significant headway has been made in their interactions with CBP and USDA. A focused effort is underway to broaden the exchange of information and implement best practices to improve the inspection of the wood packaging and dunnage material at the load port so that any noncompliant material can be intercepted before it ships.
For information about the Houston Wood Packaging and Dunnage Coalition, contact Rich Brazzale, Lake Shore Associates LLC, firstname.lastname@example.org.