CQD Journal for the Maritime Environment Industry Volume 4, #1 - February 1998, Copyright 1995 Edward M. Miller Associates, Inc.

Dunnage - Environmental Surprises

The Problem

Guardians at the Gate

What Could Happen?

Prudence is Key

From the Editor

Dear Clients and Friends:

Our newsletter is changing.  We've adopted a new name, one we feel better fits the goals of our publication:  CQD - Journal for the Maritime Environment Industry.

Our coverage has always been topics of environmental concern to the maritime industry.  Now our title better reflects that focus.  Here's why.

The letters "CQD" conjure up a number of images;  ones we feel fit our pamphlet's profile.  Mariners may recognize CQD as the early call sign for distress eventually replaced by SOS.  The topics we choose indicate marine environmental distress and prompt action required by the maritime industry and others.

"C.Q.D." is also used in the shipping business in another capacity.  The term indicates "customary quick despatch", a contractual obligation.  We use literary license to transform CQD to "Customary Quick Dispatch."   Dispatch is defined as a written message, particularly an important communication, sent with speed.  Our goal is to inform the maritime industry of marine environmental topics in a prompt and efficient manner.

We hope you continue to enjoy our journal and look forward to future issues.

Chris Swanson
Environmental Affairs


Dunnage:

How often does an agent, broker or shipowner consider dunnage?  In the past it was rare that concerns could arise with the large quantities of spare wood used to pack and protect cargo and ship.  Occasional shortages or disposal problems may have arisen.  Nowadays, the shipping industry is faced with an ever increasing exposure due to environmental liabilities for dunnage.

Seasoned mariners may not believe that a banal subject as scrap wood could expose them to increased risks.  An unaware shipper, caught with infested wood in his dunnage, might therefore be extremely surprised by his hefty demurrage bill.  More and more people are coming to understand that infested dunnage has become one of the top environmental concerns facing the international shipping community.

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The Problem

The marine environmental issue is, once again, invasive species.  Timber and lumber interests are extremely concerned over increasing observances of exotic insects and diseases damaging domestic lumber stands.  In too many cases the avenues of importation are readily traced to ports and to leftover dunnage from discharging vessels.

To protect their forests, governments in the United States, New Zealand, Canada, Australia and elsewhere have enacted strict regulations regarding the types of dunnage allowed.  The more stringent countries require pre-treatment and/or fumigation of all protective wood.  Agents and owners need to be aware of the myriad of port regulations as well as the types of problems they will face if port officials reject their dunnage.

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Guardians at the Gates

In the U.S., the experts who protect against invading species in cargo are the Animal & Plant Health Inspection Service, Plant Protection & Quarantine (Aphis, PPQ).  These are the guys shippers don't want to get a call from.  They're the officials who can quarantine cargo.

Joseph Cavey, a program manager in Aphis, PPQ, explains that too many shippers are not sufficiently aware of the type of wood used in dunnage and pallets that harbors potentially damaging species.  Importers may follow regulations (US7CFR parts 319 & 300) that prohibit wood with bark.  However, adherence to these regulations does not mean a vessel will not be quarantined.  Often problems arise with green or improperly dried wood.

Removing bark will reduce the chance that many exotic organisms will get on-board.  However, deep boring grubs such as the Asian Longhorned beetle dwell in wood layers below the bark.  The only sure way to kill such bugs is kiln drying or fumigation.  Cavey points out that woodborer larvae can survive very well in air dried lumber, up to 2 years in some cases.  Consequently, even with bark removed, "green" looking wood will be inspected and may be held for identification and treatment.

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What Could Happen?

Let's imagine a scenario of how agents and owners get into trouble with improper dunnage.  Our scenario begins with the M/V INFESTATION sailing to the U.S. having loaded, among other items, an assortment of machinery in a busy third world port.

  • Wednesday - M/V INFESTATION arrives in Newport News, VA.  After a day or so handling time-critical perishable cargo from the tween decks, tha agent calls port inspectors to clear the assorted machinery stowed below.
  • Friday afternoon - the port inspector is aware of previous problems with similar cargo from the same load port.  Although bark-free, the inspector is uncomfortable with the green wood dunnage in use.
  • Closer inspection proves his concerns valid;  suspect insects are found and bagged.  Unable to clearly identify the grubs, the inspector does not have jurisdiction to allow the discharge of the machinery wrapped in dunnage without further approvals by PPQ.
  • Suspect specimens are immediately Fed EX'd through the taxonomic service of Aphis to ARS (Agricultural Research Service), the group responsible for exact identification of specimens.  Closed for the weekend, ARS cannot begin identification until Monday morning.
  • 10:30 am Monday - the systematic entomologist at ARS informs PPQ the specimen is a species of Asian Longhorned Beetle, a labeled exotic invader of concern.
  • Armed with the identity of a bug known to attack living trees or harbor diseases, PPQ takes action by quarantining the cargo.  PPQ informs the importer or his agent they must arrange and pay for certified pest control experts to treat the dunnage before allowing release.
  • Tuesday - the pest control specialists arrive and, under PPQ supervision, begin to setup treatment for the cargo.  After sealing openings with tarps the specialists fumigate the cargo with dunnage intact with Methyl Bromide.
  • Late night Tuesday - fumigation is complete.  The cargo must sit for an additional 24 hours to allow the pesticide to work.
  • Mid-day Thursday - PPQ and the Port Inspector finally clear the cargo.  In the end almost one full week has been lost.

This scenario paints a scary but realistic picture in which costs quickly mount.  Additional expenses include fumigation, inspection and a huge loss of time resulting in rapidly charging up demurrage.  A week lost in quarantine is neither unusual nor fanciful, even for cargo that should have been discharged in half a day.

Aphis, PPQ keep a detailed database of their identifications which they use to watch for disturbing trends.  Among other items, PPQ monitors origin of cargo, type of cargo, identity of insects and seasonal tendencies.  They have documented higher frequency of occurrence of invasive woodborers in dunnage protecting cargo such as cable wires, granite, marble, tiles, pipe flanges, and machinery - particularly in cargoes originating from China.  Extra diligence is employed in reviewing manifests and inspecting such suspect cargoes.

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Prudence is Key

Awareness is currently the best course of action.  The most prudent shippers may insist on kiln dried or pre-treated wood.  In cases where dunnage is quarantined, owners may be stuck with infected wood in cargo holds, creating fumigation and disposal headaches.  Diligent owners can have Masters monitor for improper wood during loading.  All should be aware of intentionally deceptive schemes such as exporters hiding bark and soft wood in between slats of clean dunnage.  Irresponsible shippers following such practices should be reported to authorities and to P&I clubs.

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Next Issue

In the next CQD, we will continue our coverage of the dunnage issue:

  • Invasive insect damage - the species involved and the extent of damage they inflict.
  • Regulations throughout the world - New Zealand, Canada, IMO and others.
  • Future trends in the battle against exotic insects - stricter US regulations may be considered;  EPA's ban on Methyl Bromide...will it raise costs?

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CQD Journal for the Maritime Environment Industry is published by E.M. Miller Associates, Inc., Florham Park, NJ.  www.cqdjournal.com    All rights reserved.  Copyright 1999.

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