CISP files multi-species listing petition with US Fish & Wildlife Service – per Lacey Act

 

 

alburnus_alburnus_01_by-dpc

Alburnus alburnus photo by David Perez

Update as of December 7, 2016: the Petition was amended to delete one species red swamp crayfish (Procambarus clarkia), for which we decided it needed more analysis.  We will consider whether to re-propose it for an “injurious species” listing and/or other measures later

Last Friday morning, I delivered a Petition to the Secretary of the Interior’s office the roots of which go back 15 years to 2001. The title: Petition: To Amend 50 CFR §16.13 to List 43 High Risk Fish, Crayfish, and Mollusk Species as Injurious Species under the Lacey Act. (For a copy of the petition, use the “contact us” button on the CISP webpage.) I was really excited to file this on CISP’s behalf because it is the logical expansion of a more proactive approach to preventing introductions of invasive, disease-carrying, or otherwise “injurious” non-native animals that we don’t want running around in the United States. We already have scores of invaders (starlings, red lionfish, Burmese pythons, feral hogs, Asian carps, zebra and quagga mussels, tegus and on and on). We need to start doing multi-species listing proposals in order to change what has been an extremely slow process into one that works at a pace that can actually protect our nation’s resources – and people – from the risks of this age of vast globalized trade in live fish and wildlife.

 

Back in 2001, the National Invasive Species Council adopted its first Management Plan. One element in it was to adopt a science-based screening method aimed at identifying the highest risk non-native animals that we should keep out of the country.  This was to have been completed by about 2006.  I was appointed long ago (so far back I can’t remember the year) to the committee tasked with this responsibility.  The Committee went through fits and starts and sometime in the mid-2000s just crashed into nothingness and stopped meeting.  But, a dedicated U.S. Fish and Wildlife Service (FWS) biologist in the Midwest Region — Mike Hoff — kept at it for years on a shoestring budget and around 2011 he got some real funding and was able to get his animal screening project staffed. Lo and behold, they started developing lists of high-risk species based on robust scientific predictions. I won’t go into the models he used and the peer-review he had to go through. Suffice it to say that process took about 3 more years before Mike Hoff and his colleagues could convince the FWS to actually start publicly posting the results of their screening work. But, starting in 2014 they posted several and in late 2015 they posted them in earnest. Now there are 150 Ecological Risk Screening Summaries (ERSSs) on the bureau’s website.

 

Out of the 150 species, 63 pose a “high” overall risk of invasiveness/injuriousness.  For funding and historical reasons most are aquatic species that could invade in the Great Lakes region, but even so it is a great beginning. The 63 species include 46 fishes, 8 crustaceans, and 9 mollusks. One fish on the website (mrigal, Cirrhinus cirrhosus) appears to be labeled “high risk” in error and one of the mollusks (zebra mussels, genus Dreissena) is already listed under the Lacey Act. Also, Interior already has formally proposed that 11 of the 63 species on the website should be listed as “injurious”. That is, almost exactly one year ago the agency proposed to add 10 of the non-native fish and one crustacean. Thus, those 11 are not included in this new Petition. The FWS needs to take action on them soon.

 

UPDATE: On Sept. 29th the FWS finalized its rule listing all 11 of those species. The regulation and the detailed FWS explanation for it published in the Federal Register set a strong precedent and a useful template for listing the 43 species in the Petition as well.

 

Now this Petition, which I co-wrote with my CISP colleague Phyllis Windle, PhD., should be the USFWS’ next multi-species listing. The 43 “high risk” species proposed in it are listed at the end of this blog. The Petition excludes 7 species with posted ERSSs that were “high: overall,” but were below a high rating for either their history of invasiveness or climate match. As a result, the 43 below represent the highest range of the FWS’s identified high risks. Species like the Devil firefish, virile crayfish and the bleak – just their names makes me not want them here – pose unacceptable risks.

 

While the voluntary program promoted by the FWS on its webpages along with the ERSSs is a commendable hope, a “please do not import” approach cannot be relied upon. Administrations and websites change and some industry outliers won’t follow voluntary measures anyway – some even see them as creating a business opportunity. As I have watched (and supported), Mike Hoff and the FWS invested a significant amount of funds and staff time over the last 10 years to develop this screening process and research and write the scores of posted ERSSs. Other experts were involved in designing the process and providing peer reviews at different stages. It would be a significant waste of taxpayer resources were the FWS not to follow through and take regulatory action for species posing a clearly high risk. None offers an essential benefit that outweighs its harm to the United States. Minimal to zero stakeholder opposition is expected to prohibiting them. So what are we waiting for? The listing Petition needs to get posted in the Federal Register for public comment and action started as soon as possible. This one is virtually a “no brainer”.

 

The proposed list additions are below. For a copy of the full Petition, use the “contact us” button the the CISP webpage.

 

Mollusks

(A) Bithynia tentaculata (faucet snail).

(B) Corbicula fluminea (Asian clam).

(C) Dreissena rostriformis bugensis (Quagga mussel).

(D) Limnoperna fortune (golden mussel).

(E) Potamopyrgus antipodarum (New Zealand mudsnail).

(F) Sinanodonta woodiana (Chinese pond mussel).

 

Fish

(A) Acanthogobius flavimanus (yellowfin goby).

(B) Alburnus alburnus (bleak).

(C) Alosa pseudoharengus (alewife).

(D) Cichlasoma bimaculatum (black acara).

(E) Coregonus lavaretus (powan).

(F) Ctenopharyngodon idella (grass carp).

(G) Cyprinella lutrensis (red shiner).

(H) Cyprinus carpio (common carp).

(I)  Gymnocephalus cernua (ruffe).

(J)  Hypomesus nipponensis (wakasagi).

(K) Ictalurus furcatus (blue catfish).

(L)  Misgurnus anguillicaudatus (Oriental weatherfish).

(M) Morone americana (white perch).

(N) Neogobius melanostomus (round goby).

(O) Odontesthes bonariensis (Argentinian silverside).

(P) Oreochromis aureus (blue tilapia).

(Q) Oreochromis mossambicus (Mozambique tilapia).

(R) Oreochromis niloticus (Nile tilapia).

(S) Parachromis managuensis (Jaguar guapote).

(T) Poecilia reticulate (guppy).

(U) Pterois miles (Devil firefish).

(V) Pterois volitans (red lionfish).

(W) Pterygoplichthys pardalis (Amazon sailfin catfish).

(X) Pterygoplichthys multiradiatus (Orinoco sailfin catfish).

(Y) Pterygoplichthys disjunctivus (vermiculated sailfin catfish).

(Z) Pylodictis olivaris (flathead catfish).

(AA) Rhodeus ocellatus (rose bitterling).

(BB) Sarotherodon melanotheron (blackchin tilapia).

(CC) Scardinius erythrophthalmus (rudd).

(DD) Tilapia mariae (spotted tilapia).

(EE) Tilapia zillii (redbelly tilapia).

 

Crayfish

(A) Oronectes limosus (spiny-cheek crayfish).

(B) Oronectes propinquus (northern clearwater crayfish).

(C) Oronectes rusticus (rusty crayfish).

(D) Oronectes virilis (virile crayfish).

(E) Pacifastacus leniusculus (signal crayfish).

(F) Procambarus clarkia (red swamp crayfish).

 

Posted by Peter Jenkins

Invasive Earthworms Need Action!

 worm_medAmynthes agrestis; National Park Service photo

 

Earthworms have been largely ignored as a class of invaders. But evidence is accumulating that their numbers and impacts are too significant to ignore.

 

Non-indigenous earthworms began arriving in the Americas with the first European colonists and they are now widespread. One study (see summary of Reynolds and Wetzel 2008 here) found 67 introduced species among the 253 earthworm species in North America (including Mexico, Puerto Rico, Hawaii, and Bermuda).  In Illinois, 20 of the 38 species are introduced. Nuzzo et al. 2009 recorded a total of 11 earthworm species – all nonnative – at 15 forest sites in central New York and northeastern Pennsylvania.

 

Earthworms are good invaders – they reproduce quickly and are easily transported to new places – both carelessly and deliberately for bait, composting, or other uses.

 

As ecosystem engineers, invasive earthworms cause significant impacts to the soil and leaf litter, as well as to plants and animals dependent on those strata.  However, they are little studied and few efforts been made to address their threat.  Wisconsin is the pioneer (see below).

 

Ecosystem Engineers: Impacts on Soil, Plants, and Animals

 

Invasive alien earthworms cause enormous damage in forest environments. (I have seen no information about the damage they might cause in other natural systems.)  Earthworms can change soil chemistry, soil structure, and the quantity and quality of the litter layer on the soil surface. Changes include rapid incorporation of leaf litter into the soil, alteration of soil chemistry, changes in soil pH, mixing among soil layers, and increased soil disturbance. Such changes have been shown to harm native plant species – both herbaceous ones on the forest floor as well as the regeneration of woody vegetation, including trees.  See the review just published by Craven et al. 2016 and Hale and Nuzzo references below).

 

Craven et al. (2016) conducted a meta-analysis of 645 observations in earlier publications. They sought to measure the effects of introduced earthworms on plant diversity, cover of plant functional groups, and cover of native and non-native plants. Sites with a higher the diversity of invading earthworms – with associated variety in behaviors (see below) – had greater declines in plant diversity.  Higher earthworm biomass or density did not reduce plant diversity but did change plant community composition:  cover of sedges and grasses and non-native plant species significantly increased, and cover of native plant species (of all functional groups) tended to decrease. The increase in non-native plant cover in areas with higher earthworm biomass is thus an example of ‘invasional meltdown’ as propounded by Simberloff and Von Holle in 1999.

 

Craven et al. 2016 propose several direct and indirect mechanisms by which introduced worms might affect plant species. These include ingestion of seeds or seedlings, burying seeds, and alteration of water or nutrient availability, mycorrhizal associations, and soil structure. European and Asian plant species that co-evolved in the presence of earthworms could better tolerate earthworms’ presence.

 

Important Questions

 

Craven et al. 2016 note that the interaction of the invader-related factors with other site-related conditions such as deer browsing, fire history, forest management, and land-use history require further study to disentangle. Many other questions need to be answered, too.


Although Craven et al. (2016) do not specify the geographic range of the studies analyzed, I believe most were conducted in the northern and northeastern regions of the United States and some parts of Canada. It would be interesting to see if these studies’ findings differed from those carried out in Great Smoky Mountains National Park on the Tennessee-North Carolina border. The latter is an area where – unlike the northern states – earthworms were not wiped out by the most recent glaciation.  (See references by Bruce Snyder and Jeremy Craft, below.)

 

The finding that worm species diversity is associated with decreased plant species diversity seems to indicate that worms’ impacts might vary depending on the behavior of the worm in question – especially whether the worms remain on or near the soil surface and — if not — how deeply they burrow.  Are studies under way to clarify these differences?

 

Furthermore, do the impacts of European worms – the subjects of most of the studies carried out in Minnesota, New York, and Pennsylvania – differ substantially from the impacts of Asian earthworms? Or are any differences explained better by the species’ activity in the soil (e.g., depth of burrows) than their origins?

 

Impacts of earthworms on wildlife are less studied and perhaps less clear.  Several studies have focused on salamanders because of their known dependence on leaf litter. In a study of 10 sites in central New York and northeastern Pennsylvania, Maertz et al. 2009 found that salamander abundance declined exponentially with decreasing volume of leaf litter. They suggested that the salamander declines were a response to declines in the abundance of small arthropods, a stable resource.

A study by Ziemba et al. (2016) in Ohio involved Asian worms (genera Amynthas and Metaphire) rather than the European worms most often included in studies carried out in Minnesota, New York, and Pennsylvania.  These authors found a complex picture: earthworm abundance was negatively associated with juvenile and male salamander abundance, but had no relationship with female abundance.

Craft (2009) found that reduced leaf litter mass in invaded areas of Great Smoky Mountains National Park diminished habitat for both salamanders and salamander prey.

Others have studied millipedes – a largely unappreciated example of biological diversity in the Southern Appalachian Mountains – in Great Smoky Mountains National Park. Snyder and colleagues (2013) found that earthworms in the genus Amynthas altered soils by decreasing the depth of partially decomposed organic horizons and increasing soil aggregation. The result was a significant decrease in millipede abundance and species richness – probably as a result of competition for food.

Results from a study of earthworms’ effects on the Park’s food web by Anita Juen and Daniela Straube, begun in 2010, have not yet been published (pers. comm. from GRSM staff).

Even birds might be affected by worm invasions. One study in Wisconsin found that hermit thrush and ovenbird populations are lower in areas infested by worms. Possible reasons for the decline are that nests (on the ground) are more vulnerable to predation when located in the grasses promoted by worms, and a reduction in invertebrates fed to nestlings.

 

Expanding Risks

Several non-native earthworm species have been collected (so far) only from greenhouses or other places of indoor cultivation.  But can we be sure that they are not being spread to yards, parks, and other places halfway to natural systems through movement of plants and mulch?

 

Earthworms are extremely difficult to manage once established.

Are these challenges the reasons why few official efforts to control earthworm spread have been adopted? Or is it the animals’ public image – they are widely regarded as “good” critters that enrich the soil and facilitate composting. Or is it that trying to control worms will require enhanced regulation of the nursery and green waste industries?

worms1Amynthes photo; from Wisconsin DNR website

Wisconsin Is the Policy Pioneer

Wisconsin stands out for trying to address the issue! The state’s conservation and phytosanitary officials became alarmed when they detected Amynthas species in the University of Wisconsin Arboretum in 2013.  This is the site of regular plant sales,a likely pathway for spread.  Wisconsin now knows this genus of worms to be present in 21 counties, mainly along urban corridors.  They have not yet been found in the state’s forests.

Wisconsin is acting to protect its forests despite Amynthas worms having been present in the United States for over a century: Snyder, Callaham and Hendrix 2010 say several species of Amynthas were documented in Illinois and Mississippi by the 1890’s.  Some 15 species are recorded as established and widespread across the eastern United States (Reynolds and Wetzel 2004).

 

Wisconsin has classified the Amynthas genus as “restricted” – so their movement is now regulated. The risk of spread appears to be greatest through mulch produced from leaves collected in residential communities. The state held a workshop during which the regulated industry developed best management practices to address that risk. The Wisconsin Department of Natural Resources has posted a web page with information about identifying the worms and the BMPs. (Wisconsin DNR has also been a leader in tackling the firewood pathway.) The Wisconsin Department of Agriculture put the worm issue on the agenda of the National Plant Board in August 2016 and urged other states to take action.

The Wisconsin DNR webpage has

  • ID cards and other information to aid identification, g., photos of worms and the “coffee ground” soil they create;
  • a brochure with the state’s new “best management practices”
  • educate yourself and others to recognize jumping worms;
  • watch for jumping worms and signs of their presence;
  • ARRIVE CLEAN, LEAVE CLEAN – Clean soil and debris from vehicles, equipment and personal gear before moving to and from a work or recreational area;
  • only use, sell, plant, purchase or trade landscape and gardening materials and plants that appear to be free of jumping worms; and
  • only sell, purchase or trade compost that was heated to appropriate temperatures and duration following protocols that reduce pathogens.

What’s Up Where You Are?

What is your state doing to slow the spread of invasive earthworms?

  • Do nursery inspectors look for earthworms when approving plant shipments? Craven et al. 2016 findings re: higher impacts on plants as number of worm species rises demonstrate the importance of slowing spread of new species even into areas that already have some non-native earthworms.
  • Are professional associations of nurserymen and green waste recyclers educating their members about the damage caused by invasive earthworms and steps they can take to minimize worms’ spread to new areas?
  • Are organizations of anglers and gardeners in your state educating their members about the damage caused by invasive earthworms and steps they can take to minimize worms’ spread to new areas?
  • Are ecologists studying earthworm invasion impacts in other parts of the country? In non-forested ecosystems?
  • Are conservation organizations initiating or joining outreach efforts?
  • Can worm-education efforts be joined with h more robust public and private outreach focused on aquatic invaders, invasive plants, or firewood?

 

SOURCES

Bohlen, P.J., S. Scheu, C.M. Hale, M.A. McLean, S. Migge, P.M. Groffman, and D. Parkinson. 2004.  Non-native invasive earthworms as agents of change in northern temperate forests. Front Ecol Environ 2004; 2(8): 427–435

Craft, J.J. 2009. Effects of an invasive earthworm on plethodontid salamanders in Great Smoky Mountans National Park. Thesis prepared at Western Carolina University.

Craven, D., M.P. Thakur, E.K. Cameron, L.E. Frelich, R.B. Ejour, R.B. Blair, B. Blossey, J. Burtis, A. Choi, A. Davalos, T.J. Fahey, N.A. Fisichelli, K. Gibson, I.T. Handa, K. Hopfensperger, S.R. Loss, V. Nuzzo, J.C. Maerz, T. Sackett, B.C. Scharenbroch, S.M. Smith, M. Vellend, L.G. Umek, and N. Eisenhauer. 2016.The unseen invaders: intro earthworms as drivers of change in plant communities in No Am forests (a meta-analysis). Global Change Biology (2016), doi: 10.1111/gcb.13446 available here.

Hendrix, P.F. 2010. Spatial variability of an invasive earthworm (Amynthas agrestis) population and potential impacts on soil characteristics and millipedes in the Great Smoky Mountains National Park, USA. Biological Invasions DOI 10.1007/s10530-010-9826-4

Maertz, J.C., V. Nuzzo, B. Blossey.  2009. Declines in Woodland Salamander Abundance Associated with Non-Native Earthworm and Plant Invasions. Conservation Biology Volume 23, Issue 4 August 2009  Pages 975–981

Nuzzo, V.A., J.C. Maerz, B. Blossey. 2009. Earthworm Invasion as the Driving Force Behind Plant Invasion and Community Change in Northeastern North American Forests. Conservation Biology Volume 23, Number 4, 966-974.

Simberloff, D.  and Von Holle, B. 1999. Positive interactions of nonindigenous species: invasional meltdown? Biological invasions 1, 21-32

Snyder, B.A., M.A. Callaham, C.N. Lowe, P.F. Hendrix. 2013. Earthworm invasion in North America: food resource competition affects native millipede survival and invasive earthworm reproduction. Soil Biology and Biochemistry 57, 212-216

Ziemba JL, Hickerson C-AM, Anthony CD. 2016. Invasive Asian Earthworms Negatively Impact Keystone Terrestrial Salamanders. PLoS ONE 11(5): e0151591. doi:10.1371/journal.pone.0151591

 

See also:

Global picture: https://www.newscientist.com/article/mg19325931-600-war-of-the-worms/

Great Lakes Wormwatch website: http://www.nrri.umn.edu/worms/research/publications.html  

Illinois Natural History Survey webpage: http://wwn.inhs.illinois.edu/~mjwetzel/IllinoisEarthworms.html

Wisconsin  DNR http://dnr.wi.gov/topic/invasives/fact/jumpingWorm/index.html

Information on western Canada:

http://bcinvasives.ca/news-events/recent-highlights/earthworm-invasion-calling-all-citizen-scientists/

http://ibis.geog.ubc.ca/biodiversity/efauna/EarthwormsofBritishColumbia.html

Native Earthworms of British Columbia Forests: http://www.cfs.nrcan.gc.ca/pubwarehouse/pdfs/5102.pdf

 

Posted by Faith Campbell

Dr. Sarah Reichard 1957-2016

We  mourn the sudden and unexpected death of Sarah Reichard, Professor in the School of Forest Resources at the University of Washington and Director of the UW Botanical Garden. For more than 25 years, Sarah was a leading researcher on invasive plants. She studied their traits; sought to predict  their invasive ability; searched for ways to detect new invaders early; and examined the effects of plant invaders on native ecosystems. She also engaged the nursery industry, botanical gardens, and other horticultural groups in addressing invasive plant threats. She brought an open style, compassion, deep thoughtfulness — and yet a burning desire for righteous change — to all this work.

Sarah established her expertise early and was long a recognized expert.She published widely — in academic journals, gardening magazines, and policy papers.  Most recently, she authored the well-received book, The Conscientious Gardener: Cultivating a Garden Ethic. Also, Sarah was a key organizer and participant in meetings — both international and national — that addressed invasive species. Many of us in the conservation community relied upon her work and advice to guide invasive plant policy.

We join her husband, her colleagues at the University of Washington, and invasive plant experts around the world in mourning Sarah’s untimely death. Our world is a poorer place without her bright and generous spirit.

 

Faith Campbell

Phyllis Windle

Peter Jenkins

 

 

Let’s Work Together to Curtail Threat to Our Forests from Non-Native Pests

Dear Forest Pest Mavens,

I believe you agree with me that non-native insects, pathogens, earthworms … and other organisms! … pose significant threats to North America’s tree species and the complex ecosystems of which they are such important components.

I hope you also agree that our society’s efforts to counter this threat fall far short of what is needed.

  • Official phytosanitary policies are not as strong as needed to prevent introduction and spread of these tree-killing pests.
  • Worse, those policies are not always enforced assertively – as I documented in my blog about a shipment of auto parts posted on 9 August.
  • The Congress does not provide sufficient funds and other resources to support active detection and response programs – either early in an invasion or later.
  • Businesses that import or trade in goods or packaging that can transport pests are not held responsible for taking actions aimed at reducing the likelihood of such transport or supporting recovery efforts. Opposing free trade has become a hot button election issue but one of its worst impacts — wholesale movement of pests — is never mentioned.

As I noted in my earlier blog, a key reason we see these weaknesses is because those who want stronger programs have not had an effective voice in educating federal policy-makers – the USDA secretary, senators, and members of Congress – about the damage caused by introduced tree-killing pests and the governmental actions needed to counter those impacts.

The election provides both a deadline and an opportunity.

The deadline: we should try to finalize some APHIS-proposed actions before this Administration leaves office. Outgoing officials often feel freer to take bold actions at this time.

The opportunities:

  • New officials who take office in January might be open to addressing “new” issues. We must begin efforts now to get our “asks” on their agenda.  Specifically, we should approach the  senators who will question appointees to USDA Secretary and Under Secretary positions during their confirmation processes.  We should urge them to ask candidates  how they would address plant pests and to make firm, specific commitments to do so
  • Also, Congress is beginning to consider provisions to include in the next Farm Bill (due to be passed by 2019).

Several coalitions work to raise the political profile of non-native, tree-killing pests, i.e., the Coalition Against Forest Pests; Sustainable Urban Forestry Coalition; Reduce Risk from Invasive Species Coalition; Continental Dialogue on Non-Native Forest Insects and Diseases.   Many of the nation-wide forest-related organizations are members of one or more of these coalitions and I work hard for many of them. They are absolutely essential. . .

However, such “big tent” coalitions are unlikely to press for  truly bold solutions, especially if new policies  involve serious costs to economic interests or industries that are part of their membership. There is nothing nefarious in this; it is the way coalitions operate. In the case of forests pest issues, though, the absence of more forceful and nimble groups leaves a policy vacuum that no one currently  fills.

Furthermore, these coalitions don’t offer an opportunity to concerned individuals and smaller organizations to learn about phytosanitary threats or provide them with opportunities to influence policy.

In the past, I have tried to provide this information through my one-way emails and blog postings.  I would like now to upgrade these communications and to provide you with a way to interact with me and others, as well as to form joint positions.  The goal is to re-balance the politics of phytosanitary policy – so that our political leaders understand and support both adoption and enforcement of strong, effective phytosanitary measures.

I suggest that we form a new, loose “coalition of the willing” who are ready to speak up and seek ways to stay abreast of developments and opportunities and to coordinate their actions with those of like-minded people.  I suggest a loose structure –

  • I undertake to set up an email network that everyone could use. It would:
    • communicate information about pest threats and opportunities to engage;
    • communications could be initiated by anyone in the group (either through a “reply all” function or my promise to re-send any email sent to me — with the request that I do so);
    • encourage people to work together – with my assistance – to form joint positions;
    • provide lists of key contacts for specific issues — perhaps with specific talking points, letter templates, etc., to help in reaching out;
  • There would be no cost to participants;
  • Participants could take part anonymously if they wish – either generally or on specific issues;
  • If there is sufficient interest or need, we could form a steering committee to streamline and help guide the work;
  • Our goal would be communications that are straight-forward and clear — to each other and to policymakers — while avoiding gratuitous insults or insinuations.

Examples of issues on which I believe a new group could productively engage (and which the “big tent” coalitions likely will avoid) are:

  • Helping APHIS finalize its proposal to require that wood packaging coming from Canada conform to ISPM#15 standards (see blog posted on 9 August). We need to press the USDA leadership to approve the proposal; then press the Office of Management and Budget to approve it.
  • Press USDA to take two steps to improve enforcement of ISPM#15:
    • End the policy of not fining importers for non-compliant wood packaging until they have five (!) non-compliances within a single year.
    • Declare wood packaging to be a high-risk import and thus subject to mandatory inspection by Customs
  • Press Customs and Border Protection to include wood packaging compliance under its Customs-Trade Partnership Against Terrorism (C-TPAT) program.
  • Seek agreement on a strategy to encourage importers to shift to packaging made from materials other than solid wood boards. Proposals range from new regulatory requirements to C-TPAT to green certification-type voluntary programs.

I welcome suggestions for other topics we might explore!

Please let me know that you would like to join this coalition.  Please  feel free to forward this message and to invite others to join in.

[use the “contact” button on the www.cisp.us website]

Faith