CQD Journal for the Maritime Environment Industry Volume 4, #2 - May 1998, Copyright 1995 Edward M. Miller Associates, Inc.

Dunnage - International regulatory policies

Dunnage Regulations - U.S. Trends

Quarantine - Resource Protection or Politics

Cargo fumigant depletes the ozone layer

Insect Stowaways

FROM THE EDITOR

Dear Clients and Friends;

For those who are not particularly attuned to shipping verbiage, dunnage is defined as material of various types - often timber or matting - placed among the cargo for separation and hence providing protection from damage.

Chris Swanson
Environmental Affairs

Dunnage - International Regulations:

The shipping industry, like many businesses today, has become more environmentally conscious.  A practical minded shipper wants to use proper environmental procedures when preparing dunnage or cargo.  Where can he go for help?  Are there pollution control agencies such as the International Maritime Organization (IMO) where an owner, broker, agent or charterer can find guidance? 

Although IMO does deal with other maritime related environmental problems, they do not currently have a documented policy on infestation of dunnage.  They are looking closely at ballast water infestation policies for the next MARPOL annex.  Perhaps they will look at other ship borne infestation invasion problems at that time. 

So shippers are faced with wading through each and every country's dunnage policy on their own.  Nations in the world's ports have created widely variable programs relating to infestation in cargo.  With new regulations popping up daily, a general framework for quarantine policy decision making is much desired. 

The problem is, without an international doctrine to guide them, governments create widely varying regulations for cargo quarantines and infestation.  Adherence and strictness of each policy depends a great deal upon the susceptibility to damage as believed by those at risk.  If a country deems easy import requirements are more important than protection of natural resources, then little or no quarantine will be required.  A nation with little hardwood industry remaining, may for example, consider the value of imported goods over the risk of infested dunnage. 

Island nations on the other hand have a great deal to lose.  Australia and New Zealand are good examples of nations that strictly control imports.  Here, domestic economies depend heavily on protecting natural resources.  In a controlled isolated environment such as an island, infestations can rapidly spread, destroying decades of surveillance efforts.  Citizens are understandably wary. 

Kevin Stephens, President of Plimsoll Project Shipping & Logistics, has worked as a licensed customs broker for 25 yrs in Australia.  "Being an island country, and one of the last in the world to be free of many diseases, our import requirements/restrictions in this regard are perceived by many to be very tough, but from our viewpoint they are very necessary."

There is one group making efforts to standardize worldwide legislation on cargo quarantine and dunnage.  The North American Plant and Protection Organization (NAPPO) is a group of U.S, Mexican and Canadian specialists developing acceptable international standards in areas such as import regulations, export certification, compliance procedures and pest surveillance and management (see footnote).  Nappo's Forestry Panel is currently working on draft NAPPO Dunnage Standards with hopes of promoting them by October 1998.

It is expected that the NAPPO Dunnage Standards will strongly encourage worldwide pre-treatment of dunnage by fumigation or other pest control measures.  Their work may convince countries to enact scientifically viable pre-treatment standards into export/import regulations.

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Trends in the United States

In 1995, legislation in the U.S. was enacted requiring the removal of bark from dunnage. Joe Cavey of APHIS PPQ remembers that the original bill included additional measures such as pre-fumigation of pallets, scrap wood and dunnage. Before final passage however, the pre-treatment legislation was removed. Congress felt the associated costs in pre-treatment would make it extremely difficult for most third world nations to comply.
 

NAPPO's Dunnage standards may make Congress take another look. Other countries such as Australia and New Zealand have already adopted similar policies. In 1996, the Nairn Committee Report outlined specific goals and policies relating to import control of pests. Many of these policies have already been enacted into law. The success of such programs at combating exotic specie infestation is a testament to their effectiveness.

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Resource Protection or Politics?

Standards such as NAPPOs Dunnage Standard or the Nairn Committee Report are the type of international doctrine needed to keep consistency throughout the world's ports.  The United Nations' Food and Agricultural Organization support such standardization as well as the World Trade Organization. 

The tough part is how to distinguish between resource protection and politics.  There is a difference between countries legitimately concerned over plant and health protection and those countries that use quarantine restrictions as a barrier to free trade.  International trade supporters such as the World Trade Organization insist that a scientific basis be used to determine appropriate levels of protection for each country.  When a country establishes one quarantine policy for trade partners and another for everyone else, then resource protection is being used as a front to hide trade barriers.

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Best Fumigant Methyl Bromide (MBr) Depletes the Ozone Layer

Environmentally conscious shippers desiring to pre-treat their cargo will likely encounter problems soon.  It appears that the most effective fumigant currently available may soon be banned worldwide.  Although it has been used for years throughout the world, Methyl Bromide (MBr) has been determined to be a substance that depletes the ozone layer.  At the Montreal Protocol of Sept. '97, 110 countries agreed on a new phase out schedule for MBr starting in 1999.  Some countries such as the US are already initiating phase out schedules. 

This presents a particularly nasty problem for shippers.  No viable replacement has been determined for MBr.  Experts are working throughout the world on alternatives such as irradiation.  How soon these alternatives can be available remains to be seen.  Unfortunately, we can expect that such new technology will likely mean higher costs for the shipper.

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Insect Stowaways

Following is a list of major nuisance insects that are believed to have been transported in wood dunnage:

• Japanese beetle
• Asian longhorned beetle (Anoplophora glabripennis) & the family of woodboring beetles
• Asian Gypsy moth
• Silverleaf whitefly
• Cottonwood borer (plectrodera scalator)
• Pine shoot beetle (Tomicus piniperda)
• Mountain pine beetle
• Douglas fir beetle
• Hemlock woolly adelgid
• Sawyer beetle (carrier of the pinewood nematode Bursaphelenchus xylophilus)

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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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This page last updated by Miller Associates: Thursday, June 05, 2003