wood packaging – Page 8 – Center for Invasive Species Prevention

Pest threat to West Coast confirmed – authorities should respond to this information by taking protective measures

Numbers of non-native pests in counties of the 49 continental states; Map prepared by Andrew Liebhold, USFS in 2014. More recent introductions are not represented; nor are insects native to some part of North America

Currently, the Northeast and Midwest have the highest number of non-native, tree-killing insect and pathogen species (see map above). However, Pacific coast states have two-thirds the numbers of pest species of the Northeast – and are catching up. Two articles modeling the likelihood of new pest introductions point to the particular vulnerability of the Pacific Coast states – especially California – to pest introductions from Asia.

Koch et al. 2011 (see reference at the end of the blog) utilized various sources of information about volumes of imports likely to be associated with wood-boring pests — stone; raw wood and wood products (including crates & pallets); metals; non-metallic minerals; auto parts; etc. From this, the authors estimated both a nationwide establishment rate of wood-boring forest insect species and the likelihood that such insects might establish at more than 3,000 urban areas in the contiguous U.S. While their estimate was based on 2010 imports, they also projected rates for 2020.

See my blog from March 10 for various scientists’ estimates of the overall, nationwide rate of introduction. Koch et al. estimated the nation-wide introduction rate at between 0.6 and 1.89 forest insects and pathogen species per year for the period 2001–2010 and 0.36 and 1.7 species per year for 2011–2020. In other words, we should expect a new alien forest insect species to become established somewhere in the United States every 2–3 years. If one-tenth of these new introductions turn out to cause significant damage, then we can expect a “significant” new forest pest every 5–6 years.

Pacific coast states – especially California – are at highest risk.

Koch et al. evaluated the introduction risk for 3,126 urban areas across the country. The metropolitan area with the highest risk is Los Angeles–Long Beach–Santa Ana, California. For both 2010 and 2020, the predicted rates for a new pest establishing there is every 4–5 years.

Looking ahead to 2020, the situation worsens for three California metro areas – Los Angeles–Long Beach–Santa Ana; San Diego; and Riverside-San Bernardino. At San Francisco-Oakland, the predicted establishment rates remain steady. Most of the rest of the top 25 urban areas show decreases in establishment rate between 2010 and 2020.

This rising risk to California urban areas is driven by the growth of imports from Asia. For the four California urban areas, the establishment rate of Asian species is projected to increase 6–8% between 2010 and 2020. The Los Angeles–Long Beach–Santa Ana area could potentially expect the establishment of an alien forest insect species originating specifically from Asia alone (not the entire world) every 4–5 years.

[The polyphagous and Kuroshio shot hole borers are examples of recently introduced pests from Asia. Both are described, inter alia, here; a distribution map for PSHB is available here.]

Koch et al. note that the Los Angeles metropolitan area has a dense human population with corresponding high demand for goods and materials, so a substantial proportion of imports clearing the port remains in the areas. Furthermore, widespread planting of non-native plants provides a range of potential hosts that can support invaders that would not otherwise become successfully established.

A second source also indicates a heightened risk to Pacific Coast states. Yemshanof et al. used similar modeling techniques to evaluate the risk of tree pest introductions to Canada … and to the U.S. in the form of transshipped goods. (See my earlier blog.)

The Yemshanof et al. model showed that 8% of all forest pests introduced to the U.S. on imported wood or wood packaging — as estimated by Koch et al. — would come through goods transshipped through Canada. The risk is highest to the Pacific Coast states since they are the most likely to receive Asian goods transiting through Canada.

Note that the phytosanitary agencies in both the U.S. and Canada proposed in 2010 that wood packaging originating in one of the countries and shipped to the other be required to meet the international regulations under ISPM#15. However, APHIS was unable to adopt this regulation under the Obama Administration, and such an action seems even less likely under the Trump Administration. Canada is unlikely to adopt the new rules without a coordinated U.S. action.

Southern California also imports lots of plants – another pathway for pest introductions.

Koch et al. suggest that authorities use these models to prioritize border control efforts (e.g., commodity inspections), post-border surveillance, and rapid-response measures. I see some problems with these suggestions. First, enhanced commodity inspections are not likely to measurably diminish the risk of introduction to the region. Second, rapid-response measures require both increased funds – which are expected to decrease; and political will. I have blogged several times about California’s decisions to not implement official, regulatory responses to recently detected pests.

Instead, people in the region should actively build alliances and press their regional political leaders – governors, mayors, senators, members of Congress – to demand that the U.S. Department of Agriculture and the Congress adopt policies that will strengthen protection for the region’s trees.

New pest detected in California!

California authorities have detected a new woodboring beetle – the olive wood borer (Phloeotribus scarabaeoides). It was detected in an olive tree in a grape vineyard in Riverside County. This is the first detection of the species in the Western Hemisphere. Known or suspected hosts include several trees in the olive family (Oleaceae), including olive trees, privet, ash, and common lilac; as well as oleander (Apocynaceae).

Since this new pest is native to the Mediterranean region, it does not appear to be an example of the risk to California from Asia … The source (Diagnostic Network News; see below) does not speculate on the pathway by which the introduction occurred.

What Can We Do?

Ask your state’s Governor to

Communicate to the USDA Secretary the need to amend policies & regulations

(Coordinate this effort with governors of other states.)

Put forest pest issue on the agenda of National Governors’ Association
Ask your state’s Congressional delegation to pressure USDA Secretary to amend policies and regulations
Communicate concern about these pests to the media — and propose solutions.

Ask your state’s agricultural and forestry agency heads to

Ask their national associations to support proposals to USDA Secretary & Congress. These associations include
- National Association of State Departments of Agriculture (NASDA)
- National Association of State Foresters (NASF) or its Western regional group, the Council of Western State Foresters
Communicate to the media both the agency’s concern about tree pest threats and proposed solutions.

We can also act directly.

Ask mayors and officials of affected towns and counties to
Push proposals at regional or National Conference of Mayors or National Association of Counties
Instruct local forestry staff to seek support of local citizen tree care associations, regional and national associations of arborists, Arbor Day & “Tree City” organizations, Sustainable Urban Forest Coalition, etc.
Reach out to local media with a message that includes descriptions of policy actions intended to protect trees — not just damage caused by the pests
Ask stakeholder organizations of which you are a member to speak up on the issue and support proposed solutions; e.g.,
- Professional/scientific associations
- Wood products industry
- Forest landowners
- Environmental NGOs
- Urban tree advocacy & support organizations

Encourage like-minded colleagues in other states to press the agenda with their state & federal political players, agencies, & media.

Communicate to the media both your concern about tree pest threats and proposed solutions.

What Specific Actions Should We Suggest be Taken?

I suggest a coordinated package. However, you might feel more comfortable selecting a few to address each time you communicate with a policymaker. Choose those on which you have the most expertise; or that you think will have the greatest impact.

Make specific proposals, not vague ideas (see below for suggestions)
Always include information about how the pests arrive/spread (pathways such as imports of crates & pallets, or woody plants for ornamental horticulture) and what we can do to clean up those pathways (Don’t just describe the “freak of the week”)
Always point out that the burden of pest-related losses and costs falls on ordinary people and their communities. (Aukema et al. 2011 provides backup for this at the national level; try to get information about your state or city.)
We need to restore a sense of crisis to prompt action – but not leave people feeling helpless! We need also to bolster understanding that we have been and can again be successful in combatting tree pests.

Specific actions that will reduce risk that pests pose to our trees:

Importers switch from packaging made from solid wood (e.g., boards and 4”x4”s) to packaging made from other materials, e.g., particle boards, plastic, metal …
Persuade APHIS to initiate a rulemaking to require importers to make the shift. This can be done – although international trade agreements require preparation of a risk assessment that justifies the action because it addresses an identified risk (see my earlier blogs about wood packaging).
Create voluntary certification programs and persuade major importers to join them. One option is to incorporate non-wood packaging into the Department of Homeland Security Bureau of Customs and Border Protection’s (CBP) existing Customs-Trade Partnership Against terrorism (C-TPAT) program.

Tighten enforcement by penalizing shipments in packaging that does not comply with the current regulations
Persuade CBP and/or USDA to end current policy under which no financial penalty is imposed until a specific importer has been caught five times in a single year with non-compliant wood packaging. APHIS has plenty of authority to penalize violators under the Plant Protection Act [U.S.C. §7734 (b) (1)].
Restrict imports of woody plants that are more likely to transport pests that threaten our trees
In 2011, APHIS adopted regulations giving it the power to temporarily prohibit importation of designated high-risk plants until the agency has carried out a risk assessment and implemented stronger phytosanitary measures to address those risks. Plants deserving such additional scrutiny can be declared “not authorized for importation pending pest risk assessment,” or “NAPPRA”. A list of plants posing a heightened risk was proposed nearly 4 years ago, but it has not been finalized – so imports continue. APHIS should revive the NAPPRA process and utilize prompt listing of plants under this authority to minimize the risk that new pests will be introduced.
APHIS should finalize amendments to the “Q-37” regulation (proposed nearly 4 years ago) that would establish APHIS’ authority to require foreign suppliers to implement integrated programs to minimize pest risk. Once this regulation is finalized, APHIS could begin negotiating agreements with individual countries to adopt systems intended to ensure pest-free status of those plant types, species, and origins currently considered to pose a medium to high risk.

Strengthen early detection/rapid response programs by
Providing adequate funds to federal & state detection and rapid response programs. The funds must be available for the length of the eradication program – often a decade or more.
Better coordinate APHIS, USFS, state, & tribal surveillance programs.
Engage tree professionals & citizen scientists more effectively in surveillance programs.

SOURCES

Koch, F.H., D. Yemshanov, M. Colunga-Garcia, R.D. Magarey, W.D. Smith. Potential establishment of alien-invasive forest insect species in the United States: where and how many? Biol Invasions (2011) 13:969–985

Western Plant Diagnostic Network First Detector News. Winter 2017. Volume 10, Number 1.

Yemshanov, D., F.H. Koch, M. Ducey, K. Koehler. 2012. Trade-associated pathways of alien forest insect entries in Canada. Biol Invasions (2012) 14:797–812

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

Posted by Faith Campbell

How many new tree-killing pests can we expect?

Several analyses seek to quantify the risk that new tree-killing pests will be introduced to North America. They use different data sources and assumptions, and reach somewhat different conclusions. But all agree that the risk remains high, and the consequences of such introductions are dire.

I have relied on the Aukema et al. 2010 (see references at the end of the blog) and Haack et al. 2014 studies in past blogs. Aukema et al. 2010 looked at the probable dates of introduction for established insects and pathogens to determine that over 150 years, from 1860 to 2006, damaging forest insect and pathogen species were detected at an average rate of between 0.47 and 0.51 species per year. This translates to one damaging insect or pathogen every 2.1 to 2.4 years. The frequency of detection of high-impact forest pests rose sharply after 1990; beginning that year, detections of high-impact forest pests averaged 1.2 per year, nearly three times the rate of detections in the previous 130 years.

In 2013, 25 million shipping containers entered the U.S. An estimate from more than a decade ago is that wood packaging is used in about half of these containers. Haack et al. (2014) has estimated that 0.1% (1/10^th of 1%) of the wood packaging in more than 12 million shipping containers entering the country each year is infested with quarantine pests. That works out to nearly 13,000 containers harboring pests that probably enter the country each year. That is 35 potential pest arrivals per day.

Leung et al. 2014 concluded that continuing to implement the international standard — ISPM#15 — at the efficacy level described by Haack et al. would result in a tripling of the number of non-native wood-boring insects introduced into the U.S. by 2050.

Koch et al. 2011 have also attempted to determine the current rate of introduction of wood-boring insects. They also sought to evaluate the introduction risk for specific metropolitan areas.

Koch et al. utilized various sources of information about volumes of imports of goods likely to be associated with wood-boring pests (e.g., raw wood and wood products; and stone, metals, non-metalic minerals, auto parts, etc., contained in wooden crates and pallets) to estimate both a nationwide establishment rate of wood-boring forest insect species and the likelihood that such insects might establish at more than 3,000 urban areas in the contiguous US.

They estimated the nationwide rate of introduction of wood-boring pests at between 0.6 and 1.89 forest pest species per year for the period 2001–2010. Even the more conservative estimates points to establishment of a new alien forest insect species somewhere in the US every 2–3 years. If one accepts the ‘‘tens rule’’ – that one out of ten new introductions proves to have substantial effects, then one expects establishment of a significant new pest on average every 5 – 6 years. The authors note that the establishment of at least four ecologically and/or economically significant alien forest insects during the past 20–25 years – emerald ash borer, Asian longhorned beetle, Sirex woodwasp, and redbay ambrosia beetle – fits the model’s conclusion. [All of these pests are described in the Gallery of Pests posted here.]

The Aukema et al. estimate for introductions of “high impact” pests during the period after 1990 – 1.2 per year – is in the middle of the Koch et al. estimate for wood-borers, but higher than the Koch et al. estimate for “significant” pests.

Koch et al. estimated a lower rate of introductions between 2010 and 2020 – between 0.36 and 1.7 species per year. The Haack et al. and Leung et al. analyses would seem to contradict this expectation. Also, the findings of Seebens et al. (see my blog from earlier this week) contradicts any expectation that introductions will soon decline as a result of depletion of the pool of possible pests in origin countries.

Koch et al. analyzed data on imports of relevant commodities from all source regions to determine the introduction risk for 3,126 urban areas in the country. The urban area at greatest risk was Los Angeles–Long Beach–Santa Ana, California. The predicted introduction rate for both 2010 and 2020 for this metropolis was establishment of a new alien forest insect species every 4–5 years. The port of New York-Newark came in second, with a predicted establishment rate of one every 8–9 years. Houston ranked third; its predicted establishment rate was one every 13–15 years. All other urban areas were at substantially lower risk – a new introduction every 24 years.

Looking ahead to the decade 2010 to 2020, Koch et al. found that three California metro areas – Los Angeles–Long Beach–Santa Ana; San Diego; and Riverside-San Bernardino – would be exposed to increased establishment rates driven by the growth of imports from Asia.

Risk To Canada

Yemshanof et al. 2011 applied the Koch et al. methodology to evaluate the risk to Canada. Reflecting the lower volume of imports entering Canada compared to the U.S., they found a lower nationwide entry rate for Canada – 0.338 new forest insect species per year vs. the Koch et al. estimate of 1.89 for the U.S. Evaluating individual urban areas, they found the greatest risks to the Greater Toronto and Greater Vancouver areas. Moderate-sized cities near ports, major markets, or U.S.-Canada border crossings – transportation hubs – were also at heightened risks.

Canada as Pest Pathway to U.S.

Yemshanof et al.’s model indicates that 8% of all tree pests entering the U.S. as estimated by Koch et al., come through goods transshipped through Canada. The risk is highest to the Pacific Coast states since they are the most likely to receive Asian goods transiting through Canada. Note that the U.S. and Canada have proposed requiring that wood packaging originating in one of the countries and shipped to the other should be included under the ISPM#15 regulation. However, APHIS was unable to adopt this regulation under the Obama Administration, and such an action seems even less likely under the Trump Administration.

Neither study included plant imports, which are another very important pathway for introduction of tree-killing pests, especially pathogens.

SOURCES

Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the United States. PLoS ONE 9(5): e96611. doi:10.1371/journal.pone.0096611

Koch, F.H., D. Yemshanov, M. Colunga-Garcia, R.D. Magarey, W.D. Smith. 2011. Potential establishment of alien-invasive forest insect species in the United States: where and how many? Biol Invasions (2011) 13:969–985

Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org

Yemshanov, D., F.H. Koch, M. Ducey, K. Koehler. 2012. Trade-associated pathways of alien forest insect entries in Canada. Biol Invasions (2012) 14:797–812

Posted by Faith Campbell

Wood Packaging – Again! 11 years after ISPM#15, problems persist …

ALB pupa; Thomas B. Denholm, New Jersey Department of Agriculture; bugwood.org

As I have noted in earlier fact sheets and blogs, wood packaging (crates, pallets, etc.) has been a major pathway for introductions of highly damaging wood-boring pests since at least the early 1990s. (See Figure 2a in Aukema et al. 2010; reference given at end of blog.)

This rise in introductions followed the rapid increase in use of shipping containers – as described in Levinson’s book The Box (reference below). Levinson notes that shipping capacity increase fourfold during the decade of the 1970s, reaching 10 million tons in 1980. (See also my blog from August 2015 here). A second factor was the U.S. opening trade with China in 1979. Since in those years – before establishment of more sophisticated detection tools – a pest was often present for close to a decade before being detected, it is not surprising that detections of woodboring pests began their rise around 1990.

February 2017 marks 11 years since the international standard (ISPM#15) was put into effect by the United States and 17 years after the U.S. and Canada began requiring China to treat its wood packaging. Nevertheless, numerous shipments containing wood packaging that does not comply with the regulations continue to arrive at our borders – and to bring pests.

A study by scientists and economists (Haack et al. 2014; reference below) analyzed detection data from the U.S. and other countries in order to calculate the reduction in pest risk associated with wood packaging following adoption of ISPM#15. They concluded that one tenth of one percent of the wood packaging entering the U.S. after adoption of ISPM#15 still contained a tree-killing pest. This sounds like a small risk. However, the U.S. imported approximately 25 million shipping containers in 2013 – and presumably similar numbers in more recent years. It has been estimated in the past that wood packaging is used in just over half of these containers. Therefore, even if merely 1/10^th of 1% of the wood packaging in these shipments contained a tree-killing pest, 13,000 containers harboring pests probably enter the country each year. That is 35 potential pest arrivals each day.

Interception records compiled by USDA APHIS and the DHS Bureau of Customs and Border Protection clearly show that wood packaging infested with pests continued to arrive in recent years – including in 2016.

Over a period of seven years – Fiscal Years 2010 through 2016 – CBP detected more than 20,700 shipments with wood packaging that did not comply with ISPM#15. While most of the non-compliances represented wood packaging that lacked the required mark showing treatment per ISPM#15, in nearly 5,000 cases the wood packaging actually harbored a pest in a regulated taxonomic group (see Customs presentation at the Continental Dialogue here).

Customs inspectors at 11 ports (listed at end of blog) have been sending intercepted wood packaging containing insect larvae to APHIS for study. APHIS has also sent to me its record of interceptions for the period FYs 2011 – 2016.

The APHIS interception database contained 2,547 records for insect detections. The insects belonged to more than 20 families. Families with the highest numbers of detections were Cerambycids – 25% of total; Curculionidae – 23% (includes Dendroctonus, Ips, Orthotomicus, Scolytinae, Xyleborus, Euwallacea); Scolytidae – 17% (includes true weevils such as elm bark beetles); Buprestids – 11%; and Bostrichidae – 3%. Not all of the insects in these groups pose a threat to North American plant species.

piece of wood packaging with Cerambycid larva; detected in Oregon

The samples sent by CBP to APHIS are limited largely to the families Cerambycidae (the family containing the Asian longhorned beetle) and Buprestidae (the family containing the emerald ash borer). This dataset contains 1,068 insects, obtained over the period April 2012 through August 2016 from 786 separate interceptions of non-compliant wood packaging. The sample is not from a random set of ports – four of the seven entry points are on the Mexican border, and the proportion was even higher in the early years of the study.

The APHIS interception database reports pests detected in wood packaging from dozens of countries. The countries of origin with the highest numbers of shipments detected to have pests present were Mexico, China, Italy, and Costa Rica. These numbers reflect in part import volumes. The U.S. imports huge volumes of goods from both Mexico and China. (Our second largest trade partner is Canada; the U.S. and Canada have exempted wood packaging moving between the two countries from the requirement that it comply with ISPM#15. Neither country inspects wood packaging from the other country at even the low rate of inspection applied to wood packaging coming from Mexico or overseas.)

The CBP-APHIS database includes pests found in wood packaging from 39 countries, including 212 shipments from Europe; 130 shipments from Asia; and 341 shipments from the Americas – almost exclusively Mexico.

APHIS analysts point out that the pests from Mexico might pose a lower risk since some proportion of them are probably species shared between our two countries. (However, several woodborers from Mexico are killing trees in the U.S. – e.g., goldspotted oak borer, walnut twig beetle, and soapberry borer. These species are described briefly here. These insects were probably introduced to vulnerable parts of the U.S. in firewood rather than wood packaging.)

As always (see the briefs here as well as various articles by Haack and Cavey), imports of heavy objects are associated with wood packaging found to be infested with insects: metal and machine parts, tiles, decorative stone. Imports of fruits and vegetables rank high because of the large number of interceptions in wood packaging from Mexico.

Comparing the estimate by Haack et al. 2014 with the CBP data indicates that Customs is detecting about 6% of all pest-infested shipments. I do not believe that increasing the inspection workforce and effort will result in substantial improvement in this rate.

On average, 26% of infested wood pieces detected by CBP were found in wood that had been treated according to ISPM#15 requirements (if we believe the ISPM#15 stamp on the wood). Does this indicate fraud? Or is the problem accidental misapplication of the treatments? Or are the treatments less effective than hoped? APHIS researchers have found that larvae from wood subject to methyl bromide fumigation were more likely to survive to adulthood than those intercepted in wood that had been heat treated. Does this indicate that methyl bromide fumigation is a less effective treatment?

CBP staff reported that only about 30 import shipments (out of nearly 21,000 shipments found to be in violation of ISPM#15 requirements) have received a financial penalty. CBP staff cite two reasons for the low penalty rate:

USDA policy requires that an importer be caught 5 times in a year with non-compliant wood packaging before authorizing a fine; and
APHIS has not designated SWPM as a high-risk commodity

What Can Be Done to Slow or Eliminate this Pathway?

Our goal should be to hold foreign suppliers responsible for complying with ISPM#15. One approach is to penalize violators. APHIS and Customs might

Prohibit imports in packaging made from solid wood (boards, 4 x 4s, etc.) from foreign suppliers which have a record of repeated violations over the 11 years ISPM#15 has been in effect (17 years for exporters from Hong Kong & mainland China). Officials should allow continued imports from those same suppliers as long as they are contained in packaging made from other types of materials, including plastic, metals, fiberboards …

Fine an importer for each new shipment found to be out of compliance with ISPM#15 in cases when the foreign supplier of that shipment has a record of repeated violations.

There would need to be a severe penalty to deter foreign suppliers from simply changing their names or taking other steps to escape being associated with their violation record.

At the same time, the agencies should work with NGOs and importers to promote creation of an industry certification program that would recognize and reward importers who have voluntarily undertaken actions aimed at voluntarily exceeding ISPM#15 requirements so as to provide a higher level of protection against invasive species that would otherwise potentially be introduced into the United States.

What You Can Do

Tell your member of Congress and Senators that you are worried that our trees are still being put at risk by insects arriving in wood packaging. Ask them to urge the new Secretary of Agriculture (Sonny Perdue, former governor of Georgia) to take the actions outlined above in order to curtail introductions of additional tree-killing pests.

Talk to your friends and neighbors & civic organizations about the threat to our trees. Ask them to join you in communicating these concerns to their Congressional representatives and Senators.

Write letters to the editors of your local newspaper or TV news station.

Use your knowledge about pests threatening trees in your state or locality in your communications!

Ports that have sent specimens to APHIS lab: Seattle, Long Beach, San Diego, Laredo, Hildago, Houston, Miami, Port Everglades, Chicago, Detroit

References

Aukema, J.E., D.G. McCullough, B. Von Holle, A.M. Liebhold, K. Britton, & S.J. Frankel. 2010. Historical Accumulation of Nonindigenous Forest Pests in the Continental United States. Bioscience. December 2010 / Vol. 60 No. 11

Haack, R. A., K. O. Britton, E. G. Brockerhoff, J. F. Cavey, L. J. Garrett, M. Kimberley, F. Lowenstein, A. Nuding, L. J. Olson, J. Turner, and K. N. Vasilaky. 2014. Effectiveness of the international phytosanitary standard ISPM no. 15 on reducing wood borer infestation rates in wood packaging material entering the United States. Plos One 9:e96611.

Levinson, M. The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger Princeton University Press 2008

Posted by Faith Campbell

Experts describe forest pests’ impact, call for action

Sixteen scientists and policy analysts (including me) have published a new study reviewing recent work on numbers, pathways and impacts of non-native, tree-killing insects and pathogens. I encourage you to read the article. It provides a concise and compelling overview of the threat to our wildland, rural, and urban forests from non-native insects and diseases and proposes some thought-provoking solutions.

rhododendron infected by sudden oak death; photo by Jennifer Parke, Oregon State University

Meanwhile, here are our conclusions:

Current policies for preventing introductions have reduced the numbers of pests introduced via the various pathways (e.g., wood packaging and horticultural plants – but not sufficiently to counter pests’ rising opportunities for introduction resulting from burgeoning global trade. [Emphasis mine.]

At the current efficacy of implementing the international regulations governing wood packaging [ISPM #15] ( Haack et al., 2014), and given growing trade, Leung et al. 2014 project that by 2050 – just 35 years from now – up to three times as many wood-boring insects may be introduced to the U.S. as are currently here.

(I discussed this high risk in blogs posted at this site on July 15 and August 22, 2015.)

The new paper presents several options for improving prevention. These include: measures to ensure exporters ship “clean” plants and wood packaging; post-entry quarantines to raise the likelihood that pests will be detected; placing all genera of North American woody plants on USDA’s NAPPRA list of genera not currently approved for import and awaiting risk assessment; and improved surveillance and eradication programs. We also note the importance of improving data collection and allowing researchers outside USDA access to those data to support independent evaluation of policy’s effectiveness.

As Aukema et al. demonstrated six years ago, non-native forest insects have accumulated in U.S. forests at a steady rate of about 2.5 per year over the last 150 yrs. While the rate of introduction has not changed, the types of insects introduced have. In the 20^th Century, plant-associated insects dominated the introductions. In recent years wood-boring insects associated with wood packaging materials have dominated. Some of these wood-borers also are highly damaging! (See emerald ash borer, redbay ambrosia beetle/laurel wilt, and polyphagous shot hole borer/Fusarium here). Lack of information precludes a similar analysis for pathogens; although we all know that the 20 or so high-profile pathogens cause great devastation – see descriptions here.

The whole country is at risk; although the highest numbers of tree-killing insects and pathogens are established in the Northeast and Midwest, Pacific Coast states are catching up (and certainly already have their share of devastating insects and pathogens). See the map below. You can check the pests in your state by visiting the interactive map here .

map developed by USFS; published in Aukema et. al 2010.

Our new article notes that these non-native pests are the only disturbance agent that has effectively eliminated entire tree species or genera from U.S. forests in the span of decades. Follow-on effects include alterations of ecosystem functions and huge costs to various stakeholders, especially residents and governments of (sub)urban areas.

These impacts can persist for centuries as a result of altered species composition, which affects multiple trophic levels.

We followed Aukema et al. 2011’s results in estimating the direct annual economic impact of non-native forest insects to be at least: $2 billion in municipal government expenditures, $1.5 billion in lost residential property values, and $1 billion in homeowner expenditures for tree removal and replacement or treatment. These costs and losses contrast with the paltry $216 million estimated in federal government expenditures.

Aukema et al. 2011 noted that these expenses cannot be summed across cost categories because of the potential for double-counting. We note that these figures are probably underestimates for several reasons. They did not include the introduced diseases such as sudden oak death. Nor do they include pests detected recently, such as the polyphagous shot hole borer. Finally, our paper excluded consideration of insects or pathogens native to some part of North America, such as the goldspotted oak borer. (For more information about these organisms, consult the write-ups here.)

As our article notes, the billions of dollars in annual economic damages (and un-quantified ecological impacts) are economic externalities. That is, the importers who benefit from the economic activity do not pay directly for preventing or responding to the associated pest introductions.

The article discusses several policy options that we believe would greatly reduce unacceptable risks. These options include several bold actions:

Require importers to switch from packaging made from wooden boards to packaging made from materials other than solid wood (fiberboards ok). This change is both highly protective and potentially cost-effective. Such a switch would have to be justified under the terms of international trade agreements – but given the high levels of damage caused by wood-boring pests, I don’t think that hurdle is insurmountable.
Greatly strengthen measures aimed at preventing pest introduction on imports of plants. One step would be restricting imports of all genera of “woody” plants native to North America by designating them as “not authorized for importation pending pest risk assessment” (NAPPRA). Another protective step would be to promptly finalize the Q-37 revision proposed by USDA in April 2013 and immediately initiate negotiations with principal foreign suppliers of temperate climate woody vegetation to implement the pest-minimization procedures contained in that revised regulation, as well as in ISPM#36.

Other options discussed are straight-forward and simpler:

Tighten enforcement of existing regulations by ending the practice of allowing an importer to be detected five times in a year with wood packaging that does not comply with regulatory requirements before imposing a penalty. When a new year starts, that importer gets a “clean slate”! Is this how agencies enforce regulations that they are serious about?
Expand efforts to assist trade partners in adopting clean trade measures.
Expand and integrate surveillance programs for new pest outbreaks, and providing timely and adequate funding for emergency eradication efforts.

SOURCES

Aukema, J.E., B. Leung, K. Kovacs, C. Chivers, K. O. Britton, J. Englin, S.J. Frankel, R. G. Haight, T. P. Holmes, A. Liebhold, D.G. McCullough, B. Von Holle.^. 2011. Economic Impacts of Non-Native Forest Insects in the Continental United States PLoS One September 2011 (Volume 6 Issue 9)

Leung, B., M. R. Springborn, J. A. Turner, and E. G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. Frontiers in Ecology and the Environment 12:273-279.

Posted by Faith Campbell

Wood packaging again ???!!!!!! Yes – problems need to be fixed!!

CBP inspector views Cerambycid larvae found in wood packaging that bears ISPM#15 stamp

Do we want triple the current number of wood-boring non-native insects to be established in just 35 years? We all know the damage that some of these insects can do (see summary or longer descriptions; for specific insects).
Over the past 30 years, at least 58 non-native species of wood- or bark-boring insects have been detected in the United States (not quite 2 new insects per year). Most were presumably introduced via imported wood, especially wood packaging (Haack et al.).

Yes, the U.S. has implemented the International Standard for Phytosanitary Management (ISPM)#15. Nevertheless, USFS researcher Bob Haack estimates that 13,000 shipping containers per year – or 35 per day – transport tree-killing pests to the U.S. This is the basis for an estimate that by 2050 – just 35 years from now – the number of wood-boring pests introduced to the country will triple above current levels.
We don’t need to rely only on extrapolations to know that APHIS’ implementation of ISPM#15 is not protecting our trees. As noted in my blog of 11 September, inspectors at the ports continue to find insects in wood packaging – even wood packaging marked as having been treated according to the requirements of the standard. Nearly half of the wood packaging entering the country that does not comply with the treatment requirements comes from Mexico. U.S. and Mexican forests are separated by deserts – allowing insects to evolve there to which our trees are vulnerable (see my blog from 11 September and descriptions of goldspotted oak borer, soapberry borer, and walnut twig beetle and its accompanying fungus here).
An on-going study seeks to identify insect larvae found in wood packaging; it is a cooperative effort of USDA APHIS’ laboratory at Otis, Massachusetts, and Customs and Border Protection staff at eight ports. Since 2012, these ports have sent 848 cerambycid and buprestid beetle larvae to Otis for identification. The APHIS scientists have succeeded in identifying 292 larvae, or only 34%. They constituted 39 species and 29 genera.

At least 44 of these insects were from China; they included 6 Asian longhorned beetles. Remember, the U.S. first adopted regulations requiring China to treat its wood packaging at the end of 1998 – nearly 17 years ago!!! Another 20 insects were from Russia – which has been required to treat its wood packaging since early 2006 – nearly 10 years ago.
As noted in the documents linked to above, and in earlier blogs (15 July, 22 and 31 August, 11 September), wood-boring pests collectively have been the most costly of the types of tree-killing pests introduced. One study estimated that they cost local governments and homeowners $2.4 billion each year to manage dying and dead trees. The homeowners lose another $830 million in residential property values.

What the Government Has Done

While USDA APHIS has cracked down on U.S. producers of wood packaging who cheat and is promoting workshops to educate our trade partners on wood packaging treatment requirements, the government should do more to protect our forests.

What More Can be Done

• At present, U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced more strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with regulatory requirements.

• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .

• USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.

• USDA leadership should move forward and the President’s Office of Management and Budget should approve final regulations – proposed by APHIS 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)

Sources (my apologies – I apparently cannot attach to specific points in the blog):

Aukema, J.E., B. Leung, K. Kovacs, C. Chivers, K. O. Britton, J. Englin, S.J. Frankel, R. G. Haight, T. P. Holmes, A. Liebhold, D.G. McCullough, B. Von Holle.. 2011. Economic Impacts of Non-Native Forest Insects in the Continental United States PLoS One September 2011 (Volume 6 Issue 9)

Posted by Faith Campbell

Wood Packaging – Customs Efforts & Recent Detections

As noted in my blog of July 15, damaging pests continue to enter the country in wood packaging. The most comprehensive study indicates that tree-killing pests are found in an estimated 13,000 containers entering the country each year – or 35 per day.
These pests are present despite requirements adopted 9 or more years ago that wood packaging be treated.

Types of cargo packaged in wood are inspected by agricultural specialists within the Bureau of Customs and Border Protection , a division of the Department of Homeland Security. CBP agricultural specialists work at 167 sea, air and land ports of entry. See an article about CBP efforts to curb introductions of tree-killing pests posted at http://www.cbp.gov/frontline/2014/12/frontline-december-forest-prime-evil.

CBP agriculture specialists in Laredo, Texas, examine a wooden pallet for signs of insect infestation. [Note presence of an apparent ISPM stamp on the side of the pallet] Photo by Rick Pauza

According to the CBP in the above article, the types of commodities imported that have the highest rates of SWPM-related pest interceptions are metal and stone products (including tile), machinery (such as automobile parts and farm equipment), electronics, bulk food shipments and finished wood articles.
These imports have a long-standing record of pest presence – as described in Chapter 4 of my lengthy report on tree-killing pests.

According to the CBP , 48% of the wood packaging entering the country that does not comply with the treatment requirements comes from Mexico. Mexican maquiladoras are factories that import material and equipment duty-free, then assemble a wide range of products – auto parts, apparel, electronics, furniture, and appliances. Mexico’s 3,000 maquiladoras account for half of Mexico’s exports.
China has the second worst record.
Of course, we import lots of stuff from both countries! However, the China situation is particularly disturbing because the U.S. has required that wood packaging from China be treated since the beginning of 1999 – 16 years!
The ports receiving highest numbers of shipments with non-compliant wood packaging materials have consistently been those along the U.S.-Mexico border, especially in Texas: Laredo, Pharr, more recently Brownsville & Houston. Other ports receiving high volumes of non-compliant wood packaging include Blaine, Washington; Long Beach, California; and Romulus, Michigan.

USDA APHIS and CBP have cooperated in a program under which insect larvae found in wood packaging are identified as to species. In recent years, they have studied larvae detected in wood packaging from eight ports – Long Beach, Seattle; 2 ports in Florida; and three cities on the Texas-Mexico border. (Remember, there are 167 ports of entry across the country, so this sample represented 5% of all ports.) Found at these ports were an unreported total of insects, including 116 individuals in the same family as Asian longhorned beetle (Cerambycids). Forty-three were from China (including 5 ALB), 20 from Russia, and seven from Mexico (Philip Berger, APHIS, at the annual meeting of the Continental Dialogue on Non-Native Forest Insects and Diseases, November 2014)

Most familiar – and frightening! – examples of pests introduced via wood packaging include Asian longhorned beetle, emerald ash borer, redbay ambrosia beetle and its accompanying fungus, and possibly polyphagous shot hole borer and its accompanying fungus – all described here.

The prospect of receiving additional insects from Asia scares everyone. What if a new pest is as bad as the four we already have? The emerald ash borer has already caused the removal of an estimated 50 million trees and continues to spread to ash trees – and now white fringe trees – throughout America east of the Great Plains. Laurel wilt disease (transmitted by the redbay ambrosia beetle) is rapidly eradicating redbay trees in the southeast, including in Everglades National Park – one of the icons of the American conservation movement. The Asian longhorned beetle has already caused removal of more than 124,000 trees from our cities, suburbs, and nearby woodlands – at a cost to federal taxpayers of more than $500 million. If it escapes eradication programs, it threatens trees in 10% of America’s forests. The polyphagous shot hole borer threatens numerous tree species that, collectively, make up more than half the trees planted in urbanareas in Southern California.

While no one denies the threat from insects native to Asia, we should not be complacent about insects from Mexico. Although we are neighbors, our forests are separated by deserts – allowing insects to evolve there to which our trees are vulnerable. Three wood-boring beetles native to Mexico and possibly some U.S. border states are already causing havoc to U.S. trees – goldspotted oak borer, soapberry borer, and walnut twig beetle and its accompanying fungus (all described here). The first two were introduced to vulnerable forests through movement of firewood, not wood packaging. The third – the walnut twig beetle – might be native to California, although thousand cankers disease is killing native California walnuts throughout the state so something is different than it used to be.

goldspotted oak borer

When Customs officials detect wood packaging that does not comply with ISPM #15 (“noncompliance” means one of three things: the wood does not bear the ISPM #15 stamp; or the stamp appears to be fraudulent; or signs of pests are detected), that wood must be re-exported immediately, usually with the associated commodity. If any insects present pose an immediate risk of introduction, e.g., if adults are emerging, the shipment might need to be fumigated before re-export.
Re-exported shipments – and any treatments – cause importers to lose income and face costly delays. Still, the continuing presence of non-compliant wood packaging indicates that these inconveniences are insufficient to prompt importers to take all precautions possible to ensure that packaging used by their suppliers and brokers comply with the requirements.

Why don’t importers use alternative packaging made from plastic, steel, or composites that would not harbor tree-killing insects? Plastic pallets also weigh much less than wooden ones, so transport costs are reduced. Customs has pointed out the advantages. … Still, packaging material made from wood is comparatively plentiful, cheap, easy to repair, biodegradable. So it continues to dominate the market.
What steps can be taken by the U.S. government and importers to minimize the presence of insects in packaging?
• U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with the regulations.
• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .
• USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.
• The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)
• Importer’ contracts with suppliers routinely specify penalties for delivery delays; the contracts should be amended to add penalties for noncompliant wood packaging.
• A decade ago, USDA APHIS funded research which developed an ingenious method for detecting mobile pests inside a container. It was an LED light attached to a sticky trap. Placed inside a container, the light attracted snails, insects and possibly other living organisms. The whole mechanism was attached to a mailing container that could be pre-addressed for sending to a lab that could identify the pests. Why was this tool never implemented?

Posted by Faith Campbell

Wood-borers in Wood Packaging: How Did We Get to This Crisis?

shipping container being unloaded at Long Beach

The rising numbers of tree-killing wood-boring insects introduced to the U.S. (see blogs from July 15 and August 3 & fact sheet and sources linked there) are a result of ballooning of trade volumes and use of wood packaging.

This irruption of trade was made possible by adoption of the shipping container to transport a wide range of goods.Moving from place to place are not just finished products but also components that originated in one country and that are to be assembled in another country.

How the shipping container revolutionized trade and manufacturing is detailed by Marc Levinson in his book, The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger (Princeton University Press 2008). The transformation affected not only trade between countries, but also within countries, with some regional economies growing while others faltered.

Dr. Levinson recognizes that he has not addressed environmental damage caused by massive movement of cargo. While Dr. Levinson does not explain which damage he is thinking about, I doubt that he includes introductions of non-native wood-boring pests.

(I don’t know enough about the ballast water pathway to understand the impact of containerized shipping on introductions of aquatic invaders, but it seems likely to be an important factor through three factors: directing trade to new port areas; the ships’ huge size; and taking on of ballast water for those segments of a voyage carrying fewer filled cargo containers. On the other hand, Dr. Levinson says that a balance of cargo moving both ways on a trade route is an important factor in determining which ports thrive.)

Before containers, port costs represented the highest proportion of transport costs. Those costs are no longer an important consideration in determining manufacturing and transport choices. Nor is distance as important as before. What is most important are ports that can move large volumes of goods efficiently. The manufacturer or retailer at the top of the chain finds the most economical place for each step in the manufacturing and assembly process without regard to its location.

The containerization revolution was rapid. Containers were first used in international trade in 1966; within three years, nearly one-third of Japanese exports to the U.S. were containerized, half of those to Australia. In the decade after containers were first used in international trade, the volume of international trade in manufactured goods grew more than twice as fast as the volume of global manufacturing production, 2.5 times as fast as global economic output. Large numbers of specialized container ships were built, at ever-increasing sizes. The largest container ship in 1969 could carry 1,210 20-ft containers. By the early 2000s, ships being built to carry 10,000 20-foot containers; or 5,000 40-foot containers.

When Dr. Levinson wrote his book in 2005, the equivalent of 300 million 20-foot containers were crossing the world’s oceans each year.

The container revolution interacted with “just-in-time” manufacturing, which required rapid and reliable transport. Large companies signed written contracts with suppliers and shippers which included penalties for delays.

In the U.S., Long Beach quickly became the principal port because it (as well as Oakland and Seattle) had excellent rail connections to the interior. By 1987, one-third of containers from Asia destined for the East Coast landed at Long Beach and crossed the U.S. by rail. Perhaps counter to our expectation, only one-third of containers entering southern California in 1998 contained consumer goods. Most of the rest contained intermediate or partially processed goods as part of the new international supply and manufacturing chain.

Containers at Long Beach

On the East coast, Charleston SC and Savannah similarly grew because of transport connections – this time, primarily highways.

So, global trade is huge and growing; and the shipping container moves immense quantities of goods from one ecosystem to another and provide shelter for a vast range of hitchhiking living organisms (in addition to insects in the wood, there can be other insects’ eggs attached to the sides of the container, snails, weed seeds, even vertebrates – a raccoon once staggered out of a shipping container that had crossed the Atlantic from the U.S. to France!).

We need to imagine, test, and apply a variety of tools to suppress the numbers of living organisms traveling in shipping containers.

For example,
• if importer-supplier contracts specify penalties for delivery delays, we should ask why don’t importers amend the contracts to add penalties for non-compliant wood packaging?
• Might the Bureau of Customs and Border Protection incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program.
• A decade ago, USDA APHIS funded research which developed an ingenious method for detecting mobile pests inside a container. It was an LED light attached to a sticky trap. Placed inside a container, the light attracted snails, insects and possibly other living organisms. The whole mechanism was attached to a mailing container that could be pre-addressed for sending to a lab that could identify the pests. Why was this tool never implemented?

We can’t stop the trade, but we can be much more aggressive in adopting measures to minimize pest introductions.

Posted by Faith Campbell

Non-Native Pest Threat to Forests of the West Coast

As we Americans import more stuff, the risk of new pest introductions rises, too. Many tree-killing insects arrive as larvae living in crates, pallets, and other forms of wood packaging. While the USDA requires that incoming wood packaging be treated to prevent pests, this regulation has not prevented pests from entering the country on wood packaging.

A study has found that perhaps 35 shipping containers harboring tree-killing pests reach our ports each day (Haack et al. 2014). At this rate, in just 35 years, America might suffer invasion by more than 100 new wood-boring species. This would result in a tripling of borers introduced to U.S. (Leung et al. 2014).

Already, wood-boring beetles have been among the most damaging tree-killing pests introduced to the U.S. Our environment certainly doesn’t need invasions by three times as many new wood-borers!

West-coast ports receive lots of incoming shipping containers. Long Beach alone receives about half of the nearly 25 million shipping containers arriving at the U.S. each year. So it is alarming that high-risk insects, including the Asian longhorned beetle (ALB), continue to be found in wood packaging (Berger 2014).

Imported goods that are heavy are more likely to be packaged in wood and that thus pose the greatest pest risk. The highest risk commodities are
• machinery (including electronics) and metals;
• tile and decorative stone (such as marble or granite counter tops) (Harriger 2014).
The west coast ports of Seattle, Los Angeles/Long Beach, and San Francisco all rank in the top 15 out of 3,500 (1/2 of 1%) cities nation-wide for imports of tile and decorative stone, machinery and metals (Colunga-Garcia et al. 2009).

Not only do west coast cities import high volumes of risky goods; a significant proportion of the trees growing in those cities are vulnerable to these pests. Seattle’s three to four million trees belong to more than 300 species – although a mere seven genera constitute two-thirds of the trees (Ciecko et al. 2012). It has been estimated that just four non-native pests (ALB, gypsy moth, emerald ash borer, and “Dutch” elm disease) could cause $3.5 billion in damages. The ALB alone threatens 39.5% of all trees lining the city’s streets (City of Seattle 2013).

San Francisco has an estimated 669,000 trees; 12% are at risk to the ALB (Nowak et al. 2007). Apparently no one has yet estimated the numbers of trees at risk to sudden oak death (SOD), goldspotted oak borer (GSOB), or polypagous shot hole borer (PSHB).

It is essential that USDA APHIS act more aggressively to prevent additional introductions of pests via wood packaging. (For a longer discussion of the wood packaging pathway, visit my previous blog posted on July 15th). In brief:
• APHIS & the Bureau of Customs and Border protection should penalize all importers whose wood packaging does not comply with decade-old regulatory requirements.
• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program
• APHIS should re-consider the advantages of requiring importers to switch to packaging made from materials other than wooden boards.
• The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the international standard’s treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)

SOURCES
Berger, P. Executive Director, PPQ Science and Technology, Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014

Ciecko, L., K. Tenneson, J. Dilley, K. Wolf. 2012. Seattle’s Forest Ecosystem Values: Analysis of the Structure, Function, and Economic Benefits; August 2012; GREEN CITIES RESEARCH ALLIANCE; City of Seattle Urban Forest Stewardship Plan 2013.

City of Seattle Urban Forest Stewardship Plan 2013.

Colunga-Garcia, M., R.A. Haack, and A.O. Adelaja. 2009. Freight Transportation and the Potential for Invasions of Exotic Insects in Urban and Periurban Forests of the US. J. Econ. Entomol. 102(1): 237-246 (2009); and raw data for the study provided by the authors.

Haack, R.A., F. Herard, J. Sun, J.J. Burgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetle and Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46.

Harriger, K. 2014. Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014

Nowak, D.J., R.E. Hoehn III, D.E. Crane, J.C. Stevens, J. T. Walton. 2007. Assessing Urban Forest Effects and Values: San Francisco’s Urban Forest. USDA Forest Service. Northern Research Station. Resource Bulletin NRS-8.

posted by F.T. Campbell

Government Should Act Now! to Shut Wood Packaging Pathway

Revise Decade-Old Policies that Do Not Prevent Introductions

Despite regulations adopted 9 or more years ago, tree-killing insects continue to enter the U.S. in wood packaging. Aggressive enforcement is needed now to prevent further huge ecological and economic losses.

Disasters already introduced via this pathway

As Americans import more stuff, the risk rises that larvae of tree-killing insects will be enter the country hiding in wooden crates, pallets, etc. – called “solid wood packaging” or SWPM. For more information on this threat, the agencies responsible, and actions taken or proposed, visit here.

Damaging pests still found in SWPM

USDA APHIS (for more information about APHIS, read “Invasives 101” at www.cisp.us) required treatment of wood packaging from China 15 years ago, and treatment of wood packaging from other trade partners 9 years ago! Yet, a small proportion of incoming wood packaging still carries tree-killing pests. As many as 13,000 shipping containers harboring tree-killing pests probably enter the country each year – or 35 each day. [i] The Asian longhorned (illustrated below) is among the pests still detected in wood packaging from China. [ii]

Cities that import the most goods from Asia are at particular risk – New York, Chicago, Los Angeles and Long Beach. Others are also at risk: Washington, D.C.; Virginia Beach; Jacksonville. [To see a more complete list, visit here]

What the Government Has Done

While USDA APHIS has cracked down on U.S. producers of wood packaging who cheat and is promoting workshops to educate our trade partners on wood packaging treatment requirements (see write-up on www.CISP.us referenced above), the government should do more to protect our forests.

What More Can be Done

At present, U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with regulatory requirements.
The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .
USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.
The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)

[i] Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the United States. PLoS ONE 9(5): e96611. doi:10.1371/journal.pone.0096611

[ii] Haack, R.A., F. Herard, J. Sun, J.J. Turgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetleand Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46; these authors report six separate introductions; after the article was published, a seventh was detected in Clermont County, Ohio; and a new outbreak was detected near Toronto, Ontario. Also, Philip Berger, Executive Director PPQ Science and Technology, Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014