U.S. phytosanitary policy is set by politicians – the Secretary of Agriculture, trade officials, and members of the House and Senate. Elected or appointed state officials determine how aggressively trees are protected in their jurisdictions. To fix the problems, those politicians need to hear from those of us who know about the pest risk associated with wood packaging and other imports.
Politics is how our country makes important decisions. And in politics, the squeaky wheel gets the grease.
Election seasons provide opportunities to raise issues. Politicians pay more attention to constituents’ concerns when they are courting our votes.
Further, if new people take up positions in January (whether elected or appointed), they will be more open to learning about issues new to them than were the people who have occupied an office for some time.
These messages need to be repeated periodically. Proctor and Gamble does not make its profits by asking us to buy their toothpaste once a year. We cannot duplicate a major corporation’s advertising budget – but we can speak up!
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 or diseases being spread by shipments of plants. Ask them to urge theUSDA Secretary to take action to curtail introductions of additional tree-killing pests.
Ask your friends and neighbors to join you in communicating these concerns to their Congressional representatives and senators.
If you are a member of an association – a scientific or professional society, an environmental advocacy group, a homeowners’ association – ask your association and fellow members 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.
What should we say?
Our goal should be to hold foreign suppliers responsible for complying with ISPM#15. Here are five pieces of a comprehensive approach. It is best to advocate for all. However, if you feel more comfortable focusing on one or two specific actions, please do so!
1) One approach is to penalize violators. APHIS should:
Fine an importer for each new shipment found to be out of compliance with ISPM#15 in those cases where the foreign supplier of that shipment has a record of repeated violations.
Prohibit imports in packaging made from solid wood (boards, 4 x 4s, etc.) from foreign suppliers that have a record of repeated violations.
Allow continued imports from those same suppliers as long as they are contained in other types of packaging materials, including plastic, metals, fiberboards.
APHIS has the authority to take these action under the “emergency action” provision (Sec. 5.7) of the World Trade Organization Agreement on Sanitary and Phytosanitary Standards. (See a lengthy discussion of the SPS agreement in Chapter III of Fading Forests II, available here.) http://treeimprovement.utk.edu/FadingForests.htm
USDA and CBP should take other steps to help importers comply with ISPM#15.
USDA should also step up efforts to help U.S. importers to determine – and then use – those foreign suppliers of wood packaging and dunnage have good compliance records.
APHIS should join the DHS CBP in providing incentives to importers to join an expanded Customs-Trade Partnership Against Terrorism program (C-TPAT) that would require participants to assume full responsibility for ensuring that their packaging complies with IPPC standards.
The Government should strengthen underlying regulations.
Once a new president is elected, urge him to instruct the Office of Management and Budget to allow APHIS to finalize regulations – proposed more than five years ago! – that would apply ISPM#15 to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)
USDA needs to understand the “approach rate” of pests in wood packaging in order to identify and fix weaknesses in its policies. To reach this understanding, APHIS should authorize Robert Haack to repeat the study documented in Haack et al. (2014). Furthermore, APHIS should collaborate with foreign counterparts to determine the relative importance of possible causes of the persistent pest presence problem – fraud, accidental misapplication of treatments, or other failures of treatment. Once the study has been completed, APHIS and its colleagues should work through the IPPC to fix the problems.
There are also recommendations of the Tree-Smart Trade program at www.tree-smart-trade.org Tree-Smart also has a Twitter account: @treeSMARTtrade
Posted by Faith Campbell
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.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
I first blogged about wood packaging in July 2015 – it was my first blog! I have written 15 times about wood packaging since. To see the series, visit www.nivemnic.us, scroll down below “archives” to “categories”, click on “wood packaging”.
For five years, I have called upon USDA to act. It’s long past time to replace decade-old policies that have failed to prevent introductions. More recently, I have begun calling for revising the international phytosanitary system, too.
As I’ve demonstrated in my blogs – and documented by Aukema et al. 2011 and others—wood-boring beetles have been among the most damaging tree-killing pests introduced to the U.S. Local governments, homeowners, and businesses spend billions of dollars each year to manage dying and dead trees. Landowners bear added costs in reduced property values. The ecosystem impacts are substantial, but still poorly quantified.
International efforts – i.e., ISPM#15 – have apparently reduced the rate at which wood-borer pests approach our shores. However, the reduction has not been sufficient to prevent a tripling of the number of non-native wood-borers established in U.S. by 2050 (Leung et al. 2014) — as I have demonstrated over and over.
Also, I have documented again and again the continued presence of wood-borers in incoming wood packaging and resulting introductions (visit the “wood packaging” category in the blog archives).
Part of the blame for inadequate protection from pests might arise from the specific requirements of current international standards (see Nadel et al. 2016 and Krishnankutty et al. 2020b). But I think most of the blame falls on APHIS’ choice to be forgiving, rather than strict, in enforcing its own regulations that implement the international standard.
There is widespread evidence of exporters’ failures to implement international standards. The evidence is clear: we cannot rely on exporters to meet either international standards or importing country’s phytosanitary requirements. The same countries – and even individual exporting businesses! – fail to comply with ISPM#15 year after year (Haack et al. 2014; APHIS interception database). APHIS has not taken effective action to end imports from these scofflaws.
U.S. phytosanitary policy is set by politicians. Politicians pay more attention to constituents’ concerns during election seasons – so NOW is the time to press for changes! I will discuss how to do this in an accompanying second blog.
U.S. imports have decreased significantly in recent years, especially from the two countries with the worst records of non-compliance with ISPM#15 (Mexico and China). But economic collapse is not a long-term strategy for reducing pest risk.
Quantifying Pest Risk for Wood Packaging: We Don’t Know
Here’s my best estimate of the pest risk associated with wood packaging. Remember, though, that key data remain missing.
Haack et al. published a landmark analysis of pest approach rates in 2014, using data from 2009. However, they did not include imports from China, Mexico, or Canada. Given the history of interceptions, it is probable that a recalculation of the approach rate that included China and Mexico would raise the estimate. It is more difficult to provide a more accurate estimate re: Canada, because CBP rarely inspects those shipments. (The U.S. and Canada do not require each other to treat wood packaging.)
As of mid-October 2019, CBP said it received 11 million containers at seaports annually (CBP website). If 75% of those incoming sea-borne containers have wood packaging (per Meissner et al. 2009), that equals 8,250,000 containers. If 0.1% of those containers with wood packaging is infested (per Haack et al. 2014), we are receiving 8,250 infested shipping containers via maritime shipping – even now, when imports have decreased substantially. This is more than 22 infested containers every day.
As of a decade ago, Chinese shipments were only half as likely to be enclosed in wood packaging as are shipments from other exporters. Perhaps this reflects a greater reliance on air shipments – air shipments globally are half as likely as maritime shipments to be encased in packaging made of wood (Meissner et al. 2009). Despite the lower proportion of wood packaging use, shipments from China still rank second (to Mexico) in the number of shipments detected as infested. In part, the data reflect inspection priorities: due to the great damage caused by Asian insects to North American trees and their record of poor compliance, CBP targets shipments from China for more intense scrutiny. Still, the high number of detections reflects continuing non-compliance by Chinese exporters. And remember: first, the U.S. and Canada began requiring treatment of wood packaging from China at the end of 1998 – 21 years ago! And second, APHIS almost never penalizes importers for poor compliance.
Understanding the pest risk from Mexico and Canada is important, because they are our second and third largest trading partners. As of October 2019, the numbers of shipping containers arriving overland (by truck or rail) from these countries annually were 13.7 million (CBP website). No one has estimated the proportion of these containers that contain wood packaging. If it is the same proportion as in maritime shipments, the approach rate would be another 10,275 infested containers per year – or 28 per day.
The total of maritime and land-based shipments that are probably infested (excluding air shipments) – would be 18,525 containers annually or 50 per day.
If I am right that shipments from China and Mexico have a higher pest-infestation rate than the 0.1% global estimate developed by Haack et al. (2014), the pest approach rate is probably higher than the 18,525 containers given above.
(I noted in my previous blog that insect species arriving from our neighbors pose a lower risk than the species from Asia or Europe – although the risk is not “0”. I addressed the Mexican woodborers in the previous blog. The risk from Canada could arise from non-native woodborers established in that country but not yet in the U.S. e.g., brown spruce longhorned beetle. Another risk is that shipments from off-shore origins might be transshipped through Canada and escape inspection because they are claimed to have been re-packaged there – as CBP staff have told me.)
The point is, we don’t know how many pests are reaching the U.S. daily. The current approach rate might be significantly higher or lower than Haack and colleagues estimated a decade ago due to
Exclusion of China, Mexico, and Canada from the original study.
Changes in the treatment requirements of ISPM#15.
Another decade of experience – which might have led to better compliance (however, see below).
Despite my urging, APHIS has not agreed to a study to update Haack’s estimate.
It is also true that shipping containers provide shelter for a vast range of hitchhiking organisms in addition to insects in the wood, e.g., other insects’ eggs attached to the sides of the container, snails, weed seeds, even vertebrates.
Enforcement: One Agency Steps Up
When ISPM#15 was adopted, APHIS expected that importers would clean up their supply chains in order to avoid the lost income and costly delays that result from CBP interception of a non-compliant shipment. However, the data clearly show that this disincentive to violate ISPM#15 is insufficient to prompt companies to fix the problem. We need to find a more efficacious approach.
Clearly, enforcement in the form of penalties had been rare before 2017. CBP staff reported that as of January 2017 (before the agency strengthened its own enforcement effort), only about 30 of the nearly 21,000 non-compliant import shipments had received a financial penalty. CBP staff cited two reasons for the low penalty rate: 1) USDA policy requires that an importer be caught five times in a year with non-compliant wood packaging before imposing a fine; and 2) APHIS had not designated wood packaging as a high-risk commodity. After CBP initiated more aggressive enforcement in November 2017, enforcement actions rose by 400% (John Sagle, CBP. pers. comm) – although from a very low starting point!
Data on CBP interceptions in 2019 (Harriger) show decreases in the number of non-compliant shipments from earlier years in all categories: a 19% decrease below the 2010-2018 average of shipments intercepted; a 13% decrease in number of shipments intercepted because the wood packaging lacked the ISPM#15 mark; a decrease of 6% in the number of shipments intercepted that had a quarantine pest. Still, percentages based on absolute numbers don’t tell the whole story. They can be affected by inspection effort and other variables. So while these decreases are encouraging, it is still too early to determine the impact of CBP’s enforcement upgrade.
Unfortunately, there has not yet been the substantive/overall change needed in federal policy. At a minimum, APHIS continues to allow importers five violations per twelve month period.
While the cities that import the most goods – especially from Asia – would seem to be at particular risk, experience shows that pests can be introduced anywhere. This is demonstrated by establishment of the Asian longhorned beetle in semi-rural Clermont County, Ohio and the velvet longhorned beetle in Utah (Krishnankutty, et al. 2020a).
“Treated” Wood Still Transports Pests
According to interception data provided to me by CBP (Harriger), 97% of pest-infested shipments detected over a period of 6 years (FYs 2010 – 2015) bore the stamp indicating they’d been treated in compliance with ISPM#15. These shipments came from all importing countries. Unfortunately, CBP has not provided the necessary breakdown of its data in more recent years to calculate this proportion.
Krishnankutty et al. (2020b) analyzed wood packaging from 42 countries intercepted by CBP over six years (April 2012 – January 2018). They found that 87% of the infested wood packaging included in this study bore the ISPM mark. This is a lower non-compliance rate than that shown by CBP data, but still too high.
European scientists carried out an intensive survey of wood packaging associated with shipments of stone from China to the 28 European Union countries during 2013-2016. They also found that 97.5% of consignments that harbored pests bore the ISPM#15 mark (Eyre et al. 2018). The problem did not decrease over time.
The possible causes of this problem are long-known. What effort is APHIS making to determine their relative importance? Is it fraud? Is it accidental misapplication of the treatments? Is it that the treatments do not work as well as necessary?
By comparing Haack’s estimate with the CBP data, I estimate that CBP is detecting and halting the importation of 4 – 8% of the shipments that actually contain pest-infested wood. Wu et al. (2020) concurred that the majority of infesting larvae would probably not be intercepted – despite CBP’s best efforts – and would be transported to the cargo’s intended destinations.
Since CBP inspects only about 2% of incoming shipments, this detection rate demonstrates the value of CBP’s program to target likely violators. It deserves praise. But it is obviously too low a “catch” rate to provide an adequate level of protection for our forests. I do not believe that increasing the inspection workforce and effort will result in substantial improvement in this rate. Instead, we need action to curtail imports of wood packaging from countries and exporters with records of non-compliance.
What Federal Agencies Are Doing to Better Prevent Introductions
Other than CBP’s welcome newly rigorous enforcement policy, most actions have focused on educating exporters, importers, shippers, customs brokers, and exporting countries’ phytosanitary agencies.
Since upgrading its enforcement actions, CBP has expanded its long-standing educational efforts. APHIS co-sponsored workshops for agricultural agencies and exporters in Asia and the Americas earlier in the decade.
APHIS also planned to host international symposia on wood packaging issues as part of events recognizing 2020 as the International Year of Plant Health. These symposia have been postponed by travel and other restrictions arising from the coronavirus pandemic.
Posted by Faith Campbell
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.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
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)
Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)
Haack, R. A. 2006. Exotic bark- and wood-boring Coleoptera in the United States: recent establishments and interceptions. Can. J. For. Res. 36: 269–288.
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.
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.
Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020a. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera) in the United States. Annals of the Entomological Society of America, XX(X), 2020, 1–12
Krishnankutty, S., H. Nadel, A.M. Taylor, M.C. Wiemann, Y. Wu, S.W. Lingafelter, S.W. Myers, and A.M. Ray. 2020b. Identification of Tree Genera Used in the Construction of Solid Wood-Packaging Materials That Arrived at U.S. Ports Infested With Live Wood-Boring Insects. Commodity Treatment and Quarantine Entomology
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
Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory
Nadel, H. S. Meyers, J. Molongoski, Y. Wu, S. Lingafelter, A. Ray, S. Krishnankutty, A. Taylor. 2017. Identification of Port Interceptions in Wood Packing Material Cumulative Progress Report, April 2012 – June 2017
Oregon Department of Agriculture, Plant Protection & Conservation Programs. 2019. Annual Report 2019.
USDA APHIS interception database – pers. comm. January 2017.
Wu, Y., S.M. Krishnankutty, K.A. Vieira, B. Wang. 2020. Invasion of Trichoferus campestris (Coleoptera: Cerambycidae) into the United States characterized by high levels of genetic diversity and recurrent intros. Biological Invasions Volume 22, pages1309–1323(2020)
A shipping container being off-loaded in Long Beach
In 2018, China supplied 21.2% of all U.S. imports of goods. Import volumes had been rising rapidly: 427% since China joined WTO in 2001 (17 years!).
However, volumes of U.S. imports from China dropped significantly following imposition of tariffs in the second half of 2019. See a graph published in the Washington Post. U.S. Census Bureau data show U.S. imports from China declined 16% in 2019 compared to 2018 (from $539 billion to $452 billion). The Post graph shows imports from China have begun to rise again in 2020, although they are still far below levels in 2016-2018.
What might this imply for imports of pests?
2019 Imports from China
Heavy goods – are the ones most likely to be packaged in wooden crates or on wooden pallets that can transport pests. These include metal and stone products (including tile); machinery (such as automobile parts and farm equipment); electronics; bulk food shipments; and finished wood articles
Many goods imported from China are heavy so their packaging might facilitate pest invasions. Unfortunately, the various websites combine types of imports in different categories, so it is difficult to compare data from the various years. Worse, while I easily found data for 2019 and 2020, I could not find 2018 data (it must be there somewhere!). Still, six of the top eleven categories in 2019 appear to fall into the “heavy” categories.
Also, China is the third largest supplier of agricultural imports, primarily processed fruits and vegetables, including juices (together, about $1.5 billion), snack foods ($222 million), spices ($167) million, and fresh vegetables ($160 million).
Trade from Hong Kong is reported separately, but it is not a significant amount – $6.3 billion in 2018; and is declining. Electrical machinery is the largest category, at $980 million.
2020 Imports from China
Import volumes declined substantially during the first five months of 2020, compared to the same period in 2019:
Cell phones & related equipment fell 18.53%
Computers fell 4.86%
Miscellaneous textile rose 300%
Motor vehicle parts fell 26%
Seats excluding medical and dental fell 32.5%
The principal sea ports receiving goods from China during the period January – May 2020 were
Los Angeles $35.27 billion – fell 31.9%
Long Beach $10.61 billion – fell 22%
Newark $9.21 billion – fell 28%
Savannah $8.38 billion
Oakland $4.94 billion
Houston $4.29 billion
Pest Implications
These reduced volume of imports would seem to promise a reduced pest risk. Other factors point in the same direction.
Mode of transport is also significant, that is, air freight versus sea or land transport. In the first five months of 2020, https://ustr.gov/countries-regions/china-mongolia-taiwan/peoples-republic-china a quarter of U.S. imports from China, or $36 billion, entered through just four airports: Chicago’s O’Hare, Los Angeles, Anchorage, and JFK in New York. It is also encouraging that the volumes shipped by air apparently rose. The data show that at O’Hare imports rose 8.4%; at Los Angeles they rose 22%. The website does not provide data for Anchorage or New York. This could be a temporary fluke, for example, if importers were trying to acquire supplies quickly, before new tariffs took effect.
A larger proportion of goods shipped by air might result in a lower approach rate for wood-boring insects, since airborne goods are probably less likely to be packaged in wood. More than a decade ago, Meissner et al. (2009) found that only a third of air shipments (from all countries) were packaged in wood, compared to three-quarters of maritime shipments. I wonder if this is the reason that they found that shipments from China were only half as likely to be enclosed in wood packaging as were shipments from other exporting countries.
Even if China is cutting its imports in quantity, significant problems with quality persist. China consistently ranks second (to Mexico) in the number of shipments containing wood packaging that does not comply with international and U.S. regulations. Over the period 2011-2016, shipments from China constituted 11% of shipments detected by the Bureau of Customs and Border Protection as non-compliant (APHIS database / pers. comm).
So the pest risk persists. Remember that in 1986 – about the time the Asian longhorned beetle and the emerald ash borer were introduced from China – the U.S. imported only $3.8 billion worth of goods from that country. Of course, the U.S. did not require treatment of wood packaging from China until January 1999. My previous blogs have frequently documented the continuing presence of pests in wood packaging from China. To see the series, visit www.nivemnic.us, scroll down below archives to “categories”, click on “wood packaging”.
goldspotted oak borer
Because Mexico has an even worse record of compliance with wood packaging regulations than does China, it is good news that U.S. imports from there fell even more precipitously (see graph here). Pests that might be introduced in wood from Mexico generally pose less of a risk, but the risk is not zero! Three woodborers from Mexico – goldspotted oak borer, soapberry borer, and walnut twig beetle – have proved lethal to naïve species growing in the U.S. Each is described here.
Conclusion
Although the presumably temporary collapse of global trade might provide a respite from pest introductions, it is not a long-term strategy. Furthermore, resulting decreases in user fees will reduce the CBP’s inspection staff. I call again for revision of the international phytosanitary system to focus on preventing the movement of plant pests. The designation of 2020 as the International Year of Plant Health means now is the appropriate time to initiate such action.
Posted by Faith Campbell
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.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
SOURCES
Haack, R.A., F. Herard, and J. Sun, and J.J. Turgeon. 2010. Managing Invasive populations of Asian longhorned beetle and citrus longhorned beetle: a worldwide perspective. Annual Review of Entomology 55: 521-546.
Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory
