Facility Certification Program and Compliance … Certification! Program and Compliance Procedures!!...

Facility Certification

Program and

Compliance Procedures

Heat Treatment (HT) and Wood Packaging Materials (WPM)

Northeastern Lumber Manufacturers Association P.O. Box 87A Cumberland Center, ME 04021 Phone: 800.819.6040 Fax: 207.829.4293

email: [email protected]

Table of Contents

Topic Page

About NELMA 1

The International Standard for Wood Packaging (IPPC -‐ ISPM 15) 1

• ISPM 15 Approved Treatments 1

• Bark Restrictions 2

• Items Exempt from the ISPM 15 Standard 2

Facility Certification Process 2

• NELMA Inspection Frequency 2

Facility Certification Categories: 3

1. Heat Treatment 3

2. Wood Packaging 5

3. Re-‐Manufacturing 7

Dunnage 8

Multiple Category/Facilities Certification 10

Stamping Frequency Exceptions 10

Repairing & Reusing IPPC-‐Stamped Wood Packaging 11

Stamp Information 11

Inspection Discrepancies and Agency Action 12

NELMA Disciplinary Action 14

Inspections by ALSC 14

General Information 14

Annex I & II – Stamp Facsimiles 15

Sample Purchases, Usage, & Reman/Dunnage Forms 16-‐17

1

About NELMA

Established in 1933, the Northeastern Lumber Manufacturers Association (NELMA) is a non-‐profit trade association headquartered in Cumberland Center, Maine. The Association is accredited by the American Lumber Standard Committee (ALSC) as a lumber rules writing agency, and as an agency to provide inspection services for lumber, timbers, denisfied fuels (wood pellets), and wood packaging materials (WPM). NELMA was one of the first to become accredited in 2001 for the WPM program and currently provides service to facilities located throughout New England, Mid-‐Atlantic, Great Lakes and Upper Midwest Regions of the U.S.

The International Standard for Wood Packaging -‐ ISPM 15

The International Standard for Phytosanitary Measures (ISPM) – Guidelines for Regulating Wood Packaging Material in International Trade, Publication Number 15 is the official name of the global standard for wood packaging, otherwise known as ISPM 15. This Standard applies to export packaging, such as pallets, skids, crates, boxes, dunnage, etc. manufactured from solid wood components from hardwood or softwood lumber materials. It was developed as a means to reduce the global transport of non-‐native invasive forest pests, known to having been spread through non-‐treated export packaging. Numerous examples exist in the U.S. and around the world of environmental and economic loss associated with the introduction of a non-‐native invasive species to a country, traced back to untreated WPM items.

This Standard was adopted by more than 150 countries at the International Plant Protection Convention (IPPC) in March 2002, with each country allowed to choose their own date for actual implementation and enforcement. More than 75 countries have implemented the Standard, which includes all major U.S. worldwide trading partners.

The WPM inspection program system in place today in the U.S. is a result of a cooperative agreement between the USDA’s Animal and Plant Health Inspection Service (APHIS) and the ALSC to develop and maintain an accreditation program.

ISPM 15 Approved Treatments

The IPPC ISPM 15 Standard currently prescribes two types of acceptable treatments:

• Heat Treatment (HT), and • Fumigation with Methyl Bromide (MB)

To meet the Standard, either of these treatments must be applied to all solid wood materials within a completed shipping unit (crate, box, pallet, skid, etc.), and applies to both hardwood and softwood species of wood.

NELMA does not offer Fumigation Certification. These procedures will cover only Heat Treatment and the use of Heat-‐Treated materials to comply with the IPPC ISPM 15 Standard.

2

Bark Restrictions

Wood packaging materials must be made of debarked wood. However, ISPM 15 does allow any number of visually separate and clearly distinctive small pieces of bark that may remain on a piece, with the following restrictions:

• Less than 3 cm in width (regardless of length), or • If greater than 3 cm in width, the total surface area of an individual piece must be less than 50 cm².

Contact NELMA or ask the NELMA Inspector for our free Bark Measurement Tool.

Important Note: Be aware that some countries, such as Australia, have a no-‐bark policy for wood packaging stricter than this ISPM 15 restriction. Contact NELMA for specific country requirement or refer to NELMA’s IPPC Table of Information by Country, available exclusively to NELMA’s members online at www.nelma.org under the “Reference” tab on the website’s homepage.

Items Exempt from the ISPM 15 Standard

Items that may be used in the manufacture of wood packaging materials that are exempt from treatments prescribed by the standard include:

• Wood packaging material made entirely of thin wood (6 mm or less in thickness). • Wood packaging made wholly of processed wood material, such as plywood, particleboard, oriented

strand board, or veneer that has been created using glue, heat, or pressure, or a combination thereof. • Barrels for wine and spirit that have been heated during manufacture. • Gift boxes for wine, cigars and other commodities made from wood that has been processed and/or

manufactured in a way that renders it free of pests. • Sawdust, wood shavings, and wood wool. • Wood components permanently attached to freight vehicles and containers

Preservatively-‐treated (pressure-‐treated) wood does not meet the standard unless the solid wood material had been heat-‐treated and marked HT prior to the pressure-‐treating process.

Facility Certification Process

NELMA’s process of certifying a facility for IPPC ISPM 15 compliance will commence upon receipt of a completed application (contact the NELMA office or print an application online at www.nelma.org). An appointment will then be scheduled for a NELMA Inspector to visit the facility and meet with the facility management and all primary contacts that will be involved with the export wood packaging program. The Inspector will fully discuss the compliance process and make an on-‐site assessment of the operation to determine if the facility can fully meet the requirements set forth by IPPC ISPM 15 and NELMA for certification.

When all conditions for compliance are met, the Inspector will register the facility for certification, obtain a signed agreement for services, train designated facility personnel on all required compliance procedures, set up the NELMA facility records binder, and order the appropriate stamps for the facility.

NELMA Inspection Frequency

A minimum of twelve (12) inspections per calendar year are conducted by a NELMA Inspector at each certified facility, as required by the ALSC Enforcement Regulations. With the exception of the initial certification visit, these will be unannounced inspections.

3

Facility Certification Categories

There are three primary types of certifications available from NELMA regarding the Heat Treatment and Wood Packaging Materials program:

1. Heat Treatment Facility 2. Wood Packaging Materials Facility 3. Re-‐Manufacturer of HT Materials.

A facility may be certified in more than one category, dependent upon their overall operation and variety of solid wood products manufactured for use in export packaging. See “Multiple Category and/or Facility Certification” section for additional information.

Compliance Procedures by Category Type

1. Heat Treatment Facility

Facility Definition:

This is a facility that has a chamber or kiln designed to

a) heat treat solid wood materials to be used in the construction of wood packaging for export, such as lumber, timbers, or components, and/or,

b) heat treat completed wood packaging units such as pallets, skids, and crates.

Temperature and Time Requirements

For Heat Treatment (HT), the ISPM 15 Standard requires that the core of each solid piece used in the manufacturing of wood packaging materials must reach a minimum temperature of 56°C (133°F) for 30 minutes, and verified through a recognized accredited and certified program. However, due to the variables inherent with the HT process and recording equipment, NELMA requires Heat Treatment facilities to reach a minimum core temperature of 60°C (140°F.) for at least 30 minutes at the core of the largest piece to ensure the minimum ISPM 15 requirement has been met.

Heat Chamber Requirements:

Each heat chamber or dry kiln to be certified for Heat Treatment must be designed to provide auxiliary heat and air flow for the purpose of raising the core temperature of solid wood, hardwood or softwood, to a minimum temperature of 140°F or higher for 30 or more consecutive minutes. Initial certification by NELMA is dependent upon the facility’s ability to prove that their chamber and equipment are capable of meeting and exceeding NELMA’s temperature and time requirements. The facility staff must demonstrate their capability of maintaining the equipment, including maintenance of the chamber, its heat supply and air supply, and its devices for reading and recording temperatures. The devices for reading temperature may include a combination of dry and wet bulbs for the monitoring of ambient chamber conditions and thermocouples for the direct reading of wood core temperature, contingent upon approval by NELMA. The facility is responsible for supplying proof of periodic calibration of its temperature monitoring devices and recording equipment.

4

Operating Procedures and Use of Thermocouples

While standard heat treating schedules may be approved by NELMA based on laboratory tested schedules or proven history with the facility, thermocouples with incremental data recording capabilities placed in strategic points in the lumber during the heat treatment process and accompanied by a record of inlet temperature into the chamber ensures that NELMA’s heat treatment requirements are met every time. A minimum use of 3 thermocouple locations within the heat treatment chamber is preferable but dependent upon the size and operational parameters of the heat chamber itself.

Thermocouples for the direct and continuous reading of the core temperature are set into the thickest piece of lumber or timber within the given charge and additional “cold spot” areas of the chamber. A drill bit slightly larger than the thermocouple probe is used to bore a hole to one-‐half the thickness of the largest piece so that the tip of the thermocouple is in the direct center of the thickness of the material. Once the thermocouple is inserted, a non-‐heat conducting substance such as high temperature silicone shall be used to block entrance of any air into the hole and around the inserted thermocouple to eliminate false temperature readings.

Each thermocouple in use during the heat treatment process must meet NELMA’s heat treatment temperature requirement of 140°F for a minimum of 30 minutes. If any thermocouple reading does not meet either the temperature or time requirement, the reason for failure must be identified and corrected, and the entire charge must be re-‐heat treated. However, if the facility utilizes additional duplicate thermocouples (two thermocouples placed in very close proximity of each other in multiple areas of the chamber) re heat-‐treatment may not be required if the failed thermocouple’s duplicate has recorded the required temperature and time.

If the thermocouples are not sealed, OR, if the facility’s heat treatment data is insufficient to ensure proper heat treatment of the material, all lumber components or completed units, such as pallets, skids and crates, within the charge will not be considered heat treated. If the components or completed units have been shipped, the facility will be held responsible for the return of the material to the facility and/or proof of obliteration of any marks on the material that identify it as heat treated.

NELMA will periodically verify a facility’s heat treatment chamber(s) using Association recording devices, measuring the temperature conditions in the chamber and the wood to assure the time and temperature requirements for heat treating are being met. Any variances found as a result of NELMA’s monitoring process will be addressed and corrected by the facility to maintain certification within the NELMA heat treatment program.

Stamping Procedures:

Individual lumber components and full size lumber: These solid wood items shall have the Heat Treatment (HT) Stamp applied at least once on the face or end of each piece after proper heat treating. These products may then be sold to other facilities that produce completed wood packaging for export.

Completed wood packaging units such as pallets, skids, and crates: When these completed items are heat treated by the facility, the IPPC Stamp shall be applied to a minimum of two opposite sides of the WPM. NELMA highly recommends stamping all sides to ensure a full view of stamps by foreign port authorities.

Refer to the Stamping Frequency Exception section on Page 10 for instructions on the HT stamping of small size components. For the stamping of Dunnage material, refer to for specific instructions.

See Annex I on Page 15 for facsimiles of the Heat Treatment (HT) Stamp and IPPC Stamp.

5

Documentation:

The facility will maintain a separate file for each registered kiln that will contain the following:

• A computer printout or chart for each charge that shows a record of the time and temperatures reached during the Heat Treatment cycle.

• The printout or chart must record the date, quantity of lumber or wood packaging units, and size of products.

• A unique number or label identifying the charge, in sequence. • Additional information may be necessary to ensure the facility’s and NELMA’s ability to verify heat

treatment should it be questioned by foreign port authorities.

NELMA Inspection Procedures:

A NELMA inspection, unannounced after a successful initial certification visit, will encompass the following:

A review of all heat treatment records and inventory documentation.

A review of the recording devices and location of the thermocouples within the heat treatment chamber.

When thermocouples are used, a verification of the proper depth and the use of a non-‐heat conductive sealant where inserted into the wood for accurate core temperature recordings.

Verification of the proper use of the facility’s stamp(s) including legibility.

An inspection of the facility’s inventory.

A complete inventory of all NELMA stamps assigned to the facility.

2. Wood Packaging Facility


This is a facility that produces completed pallets, skids, boxes, crates, or custom packaging either for sale or for their own company’s use in exporting goods.

HT Material Purchases:

Facilities that purchase heat treated lumber for use in their production must be certain that the material is invoiced and received at the facility as certified and properly stamped as heat treated. EACH PIECE must be legibly stamped on the face or ends with an “HT” or “KD-‐HT” mark, AND with a mill number, AND the logo or name of an ALSC-‐accredited agency. This information is typically contained within a lumber grade stamp but may also be stamped separate on the face or end of each piece. See Annex II on Page 15, Facsimiles of Stamps Required on Purchased Heat Treated (HT) Lumber, to view examples of the type of grade stamp or HT stamp to expect on each piece

Upon delivery of the lumber to the facility, designated facility personnel must conduct an inspection of the material to ensure the required stamp is present before acceptance into inventory. For material in question, check with NELMA immediately.

An Up-‐to-‐date list of ALSC-‐accredited agencies and their logos is contained within the facility’s NELMA Red Binder, or may be viewed and/or downloaded online at www.alsc.org

6

Stamping Procedures:

For completed wood packaging units, such as pallets, skids, and crates: Completed units manufactured from certified heat treated (HT) and stamped lumber and components will be stamped with the IPPC Stamp and shall be applied to a minimum of two opposite sides of the WPM. NELMA highly recommends stamping all sides to ensure a full view of stamps by foreign port authorities.

Individual pieces used within a box or crate used for internal blocking and bracing: These pieces shall be manufactured from certified HT-‐stamped solid wood material from the facilities inventory. No additional stamp is required on theses individual pieces, as the material is covered by the facility’s IPPC stamp applied to the outside of the finished unit. However, it is acceptable to stamp these individual cut-‐to-‐size bracing and blocking pieces with the IPPC stamp. Important Note: IPPC-‐stamped finished WPM units that are shipped to a customer for export use should never have any solid lumber materials added to them by the customer, unless the customer is also an IPPC ISPM 15 certified facility. NELMA highly recommends that this critical requirement be discussed with the customer prior to shipment to ensure their understanding.

Cardboard or Plywood/OSB covered wood packaging units: The IPPC Stamp should be applied to both the interior wood framing and on the covering material on a minimum of two opposite sides. NELMA highly recommends stamping all sides to ensure a full view of stamps by foreign port authorities.

Wood Packaging Kits: Under specific circumstances it is permissible to ship a completed wood packaging unit, such as a box or crate, to a customer in kit form. Kit usually means a series of tops, sides, and bottoms, with cut-‐to-‐size bracing if needed. Contact NELMA for details or discuss the specifics with your NELMA Inspector.

Refer to Annex I on Page 15 for an IPPC Stamp facsimile.

For the stamping of Dunnage material, refer to Page 8 for specific instructions.

Documentation:

A Wood Packaging Facility must maintain comprehensive documentation that will confirm only certified heat treated solid wood materials are being used in the manufacture of completed wood packaging units. The following forms and records must be maintained by the facility within the NELMA Red Binder:

• HT-‐Lumber Purchases Form: This NELMA form will be used by designated facility personnel to record each purchase of certified HT-‐stamped lumber and components by the facility. The date of delivery, lumber/component size, and quantity will be added to the form after each purchase. A separate form must be used for each size of solid material purchased.

• Invoices/Bills of Lading: A copy of the invoice and/or bill of lading for each purchase of HT-‐stamped wood material must be included within this file to document the transaction. The invoice or bill must include the term HT or KD-‐HT to confirm the appropriate material was ordered and shipped to the facility.

• WPM Stamped Usage Report: This NELMA form will be used by designated facility personnel to record the actual usage of certified HT-‐stamped lumber from the facility’s inventory to manufacture completed wood packaging units. The information to include: date of manufacture, material sizes used, quantity, and specific facility identification information (job number, order number, customer name, etc.)

These forms for documentation may be viewed and printed from the NELMA website under the “Inspection Program” tab on the homepage and “Wood Packaging Inspection” sub-‐tab.

7

• Alternative to Documenting WPM Stamped Usage: WPM facilities that agree to purchase and inventory only HT-‐stamped wood at their facility AND agree to stamp all completed wood packaging units manufactured by the facility regardless of final destination, domestic U.S. or international, will not be required to maintain a WPM Stamped Usage Report by NELMA. The entire purchases will be considered usage. Arrangements for this alternative may be discussed with the NELMA Inspector.

Inspection Procedures:


An examination of the facility’s on-‐site lumber inventory to verify that certified HT-‐stamped lumber has been purchased.

An inspection of the facility’s inventory of completed wood packaging to examine proper use of the stamp,

including legibility and location on a minimum of two opposite sides.

An inspection of the facility’s inventory of completed wood packaging for bark in excess of the ISPM 15 restriction.

Check HT-‐lumber purchasing and invoice records maintained within the NELMA Red Binder with on-‐site inventory information for verification purposes.

If Usage Reports maintained, a reconciliation of current inventory with purchases, less usage for verification purposes.


3. Re-‐Manufacturer of HT Materials


This is a facility that purchases certified and properly stamped heat treated (HT-‐stamped) lumber and re-‐manufacturers the material into components or specialty-‐sized items for use as wood packaging for export.


Facilities that purchase heat treated lumber for use in re-‐manufacturing must be certain that the material is invoiced and received at the facility as certified and properly stamped as heat treated. EACH PIECE must be legibly stamped on the face or ends with an “HT” or “KD-‐HT” mark, AND with a mill number, AND the logo or name of an ALSC-‐accredited agency. This information is typically contained within a lumber grade stamp but may also be stamped separate on the face or end of each piece. See Annex II on Page 15, Facsimiles of Stamps Required on Purchased Heat Treated (HT) Lumber, to view examples of the type of grade stamp or HT stamp to expect on each piece



8

Stamping:

For components or specialty-‐sized items re-‐manufactured from certified HT-‐stamped lumber, the Heat Treatment (HT) Stamp shall be applied at least once to each piece, except those pieces that contain the original and complete HT or KD HT stamp.

Refer to Annex I on Page 15 for a HT Stamp facsimile.

Refer to the Stamping Frequency Exception section on Page 10 for instructions on the HT stamping of small size components. For the stamping of Dunnage material, refer to Page 8 for specific instructions.

Documentation:

A Re-‐manufacturing Facility must maintain comprehensive documentation that will confirm that only certified heat-‐treated solid wood materials were used in the re-‐manufacturing process. The following forms and records must be maintained by the facility within the NELMA Red Binder:

• Reman/Dunnage Log Sheet: This NELMA form will be used by designated facility personnel to record specific information on components manufactured from certified HT-‐stamped lumber. The information will include the original grade stamp information (name of inspection agency and mill number), size and quantity of lumber, and the final size and quantity of components re-‐stamped with the facility’s HT stamp.

• Invoices/Bills of Lading. A copy of the invoice and/or bill of lading for each purchase of HT-‐stamped wood material must be included within this file to document the transaction. The invoice or bill must include the term HT or KD-‐HT to confirm the appropriate material was ordered and shipped to the facility.

Inspection Procedures:


An examination of the facility’s on-‐site lumber inventory to verify that certified HT-‐stamped lumber has been purchased.

An inspection of the facility’s remanufactured products to examine proper use of the stamp, including legibility.

Verification of the facility’s purchasing records, including invoices, and examination of the facility’s Reman/Dunnage Log Sheet to ensure that certified HT-‐stamped lumber has been specified, purchased, and used.


Dunnage

Product Definition:

Dunnage is defined specifically as individual solid lumber material that will be used in securing wood packaging units (boxes, crates, pallets, skids, etc.) within a shipping container for transit via truck, ship, or air. These items may or may not continue on with the shipment beyond the port of entry.

9

Important Note: Blocking and bracing of goods inside a certified IPPC-‐stamped box or crate is NOT considered Dunnage. These pieces cut from certified heat treated wood material used internally within a wood packaging unit would be covered by the IPPC stamp placed on the exterior of the completed unit.

Dunnage Usage:

Dunnage material may be used at a variety of facilities within the export wood packaging community:

• at a wood packaging facility that also loads export shipping containers on-‐site • at a freight forwarding company that loads export shipping containers on-‐site, or • at a seaport and /or airport cargo facility where the final loading of shipping containers takes place.


Facilities that purchase heat-‐treated lumber for use in producing Dunnage must be certain that the material is invoiced and received at the facility as certified and properly stamped as heat treated. EACH PIECE must be legibly stamped on the face or ends with an “HT” or “KD-‐HT” mark, AND with a mill number, AND the logo or name of an ALSC-‐accredited agency. This information is typically contained within a lumber grade stamp but may also be stamped separate on the face or end of each piece. See Annex II on Page 15, Facsimiles of Stamps Required on Purchased Heat Treated (HT) Lumber, to view examples of the type of grade stamp or HT stamp to expect on each piece


Stamping:

The Dunnage stamp is very similar to the IPPC stamp as it contains the same information, with the addition of the word “DUNNAGE”, or “DUN” on the right-‐hand side outside of the stamp, printed vertically. This designation reflects its specific usage for external blocking and bracing of containers or wood packaging shipments. Refer to Annex I Page 15 for an IPPC DUNNAGE Stamp facsimile. Specific criteria apply to the stamping and usage of Dunnage, dependent upon the facility and where it will be produced or used: • A certified wood packaging facility or heat treatment facility that stamps heat-‐treated lumber as Dunnage

for sale to customers that load shipping containers has 2 options: o For cut-‐to-‐order customers, the IPPC Dunnage stamp must be applied legibly at least once on

the piece, typically the face. o For customers that order full length IPPC Dunnage stamped lumber, the lumber shall be

stamped the full length of each piece with the IPPC Dunnage stamp at a minimum of every 2 feet. This ensures that when it is cut to size by the customer, at least one stamp facsimile will be present on each piece of the Dunnage.

• At a certified wood packaging facility, freight forwarder, or seaport/airport cargo location that loads shipping containers at their site and Dunnage material is needed to secure or separate the cargo, certified heat-‐treated lumber stamped HT or KD HT may be cut to desired sizes and each piece stamped with the IPPC Dunnage stamp at least once, typically the face.


10

Documentation:

A facility certified to utilize the IPPC DUNNAGE stamp must maintain comprehensive documentation that will confirm only certified heat-‐treated lumber stamped HT or KD HT was used. The following forms and records must be maintained by the facility:

• Reman/Dunnage Log Sheet: This NELMA form will be used by designated facility personnel to record specific information on components manufactured from certified heat-‐treated lumber stamped HT or KD HT and stamped with the IPPC DUNNAGE stamp. The information will include the original grade stamp information (name of inspection agency and mill number), size and quantity of lumber, and the final size and quantity of components re-‐stamped with the facility’s DUNNAGE stamp.

Refer to Page 17 for a sample copy of the Reman/Dunnage Log Sheet.

Multiple Category & Location Certification A facility may be certified by NELMA in more than one certification category as listed above. For example, a facility that produces completed packaging units as a Wood Packaging Facility may also be certified as a Re-‐Manufacturer of Heat Treated Materials. Another example is a Heat Treatment facility that heat treats lumber and/or completed export packaging units such as pallets, crates, or boxes that require the IPPC stamp. This facility would be certified as a Heat Treatment facility and a Wood Packaging Facility. Companies with multiple facilities that heat treat, manufacture, or re-‐manufacture wood packaging materials must have each site certified. Each location will maintain its individual records within a separate NELMA Red Binder and be listed by NELMA as a separate facility for inspection purposes.

Stamping Frequency Exception

The ALSC Enforcement Regulations provide for an exception to the HT-‐stamping of each and every piece of certified material that has undergone heat treatment or has been re-‐manufactured from certified heat-‐treated lumber stamped HT or KD HT. When the size of the pieces are:

• 30 inches or less in length, OR • 1/2 inch nominal or less in thickness, OR • 2 inches nominal or less in width,

The following HT-‐stamping criteria must be met:

• The HT stamp shall be applied by stamping not less than 25% of the pieces in the unit, AND • The units that are partially stamped shall be bundled and a stencil of the facility’s HT stamp applied to the

outside of the package.

11

Repairing & Reusing IPPC-‐Stamped Wood Packaging

Damaged IPPC-‐stamped wood packaging units (pallets, skids, boxes, crates, etc.) that are repaired for reuse as IPPC compliant wood packaging must undergo the following conditions:

• Existing IPPC marks must be obliterated from the unit • The unit must undergo re-‐heat treatment or fumigation by an ALSC-‐certified facility, and re-‐stamped with

the facility’s IPPC stamp.

A repair by only replacing individual boards on the wood packaging unit with certified heat-‐treated material is NOT ACCEPTABLE to the U.S. Standard and may not be used as IPPC compliant packaging

Exception: In the case of a box or crate that is constructed of completed components such as a top, sides, and a bottom, an IPPC compliant repair may be made to the unit when the entire top, side, or bottom is fully replaced on the original unit in its entirety with one constructed of certified heat-‐treated material. Only the replaced completed component would be stamped with the certified facility’s IPPC stamp signifying ownership of that part of the unit. The remaining IPPC marks from the original manufacturer would remain on the unit.

All IPPC-‐stamped wood packaging units that are repaired for domestic use by a facility must have the original IPPC stamps obliterated. This measure ensures the integrity of the global IPPC program by reducing the possibility of non-‐compliant wood packaging entering the marketplace, mistakenly or otherwise, being represented to customers as IPPC-‐stamped good-‐to-‐go wood packaging.

Previously used and properly IPPC-‐stamped wood packaging units received by a facility may be re-‐used for export shipments only if absolutely no repair or alterations take place with the unit.

Stamp Information

Stamping Ordering and Ownership:

• All stamps, stencils, and stamping equipment for use by the facility must be ordered through the NELMA office to ensure quality, consistency, and overall stamp inventory control. The initial stamp and stamping supplies will be ordered by the NELMA Inspector as a final step in the facility certification process. NELMA will invoice the facility for the cost of the stamps, supplies, and shipping and handling charges following receipt of the order.

• All stamps, stencils, and stamping equipment remain the property of the Association as detailed in the NELMA “Agreement to Provide Service”, signed by the Facility upon certification AND are licensed for use by the facility as long as they remain certified by NELMA.

• Stamps showing signs of wear should be replaced promptly! Replacement or additional stamps may be ordered at any time either by contacting the NELMA office (800-‐819-‐6040) or through a NELMA Inspector.

• Worn stamps to be replaced shall be saved for retrieval by the NELMA inspector. A plastic NELMA bag is provided to each facility for storage of worn stamps to be retrieved. NEVER DISCARD WORN STAMPS!

Stamp Security:

12

• Upon receiving NELMA-‐issued stamps, the facility takes full responsibility for the security of all stamps available for use by its designated personnel at all times. A NELMA-‐approved detailed process and procedures plan will be developed by the facility in regards to day-‐to-‐day stamp accountability of all stamps, in consultation with the NELMA Inspector.

• The facility management will notify NELMA immediately when a NELMA stamp becomes lost.

• Stamps shall not to be altered in any way by facility personnel. Note: See important information regarding the consequences of altering stamps under the “Inspection Discrepancies and Agency Action” section within this document.

• Stamps shall only be used at the specific wood packing facility location to whom they were officially issued and are not to leave the premises. Note: See important information regarding the consequences of removal of stamps under the “Inspection Discrepancies and Agency Action” section within this document.

Stamp Legibility & Recommended Cleaning Procedures:

Proper ink quality and quantity, careful application, and periodic cleaning are the keys to stamp legibility. The Rubber Stamps should always be used with NELMA-‐approved ink and should be cleaned frequently to ensure a clear stamp impression with each application. Here’s how:

• Rubber Stamps and Mylar Stencils should be cleaned frequently with warm water and mild soap product, such as dish soap, and applied with a soft bristled brush such as a toothbrush.

• If the ink has been allowed to build up on the stamps – isopropyl alcohol may be used as a cleaner, applied with a soft toothbrush. Rubber stamps should never be soaked in alcohol as this will cause the glue holding the stamp to the mount to deteriorate as well as causing distortion of the stamp itself.

• If spray paint is used on Mylar Stencils, use paint thinner to remove the built-‐up paint.

Stamp Branding:

In addition to permanent-‐ink stamps, a facility may also “brand” an exact replica of an official stamp onto their certified wood packaging materials. The facility must consult with NELMA prior to mock-‐up and production of the brand and final approval must be obtained from the Association before it may be utilized on export packaging units.

Inspection Discrepancies and NELMA Disciplinary Actions

Inspection Discrepancies The inspector’s findings during each visit will be discussed with the designated personnel. All discrepancies must be considered serious in nature and immediate correction must be taken by the facility to maintain certification. Examples of inspection discrepancies include the following:

• Use of Non-‐HT Material: The use of non-‐heat treated wood material in the production of IPPC-‐stamped export packaging units or in re-‐manufactured materials is a serious infraction. NELMA will require the facility to recall all wood packaging items that contain the non-‐HT material and provide NELMA with complete verification of their corrective actions.

13

• Illegible Stamps: The appropriate stamp required for WPM items must be legible and clearly visible. Materials that contain illegible stamps will be held at the facility until immediate corrective measures are completed and verified by the NELMA Inspector.

• Improper Use of Stamp: As noted above, the rules for WPM stamp usage are quite clear and definitive. Stamping WPM items with the wrong stamp or, not stamping the items at a minimum on opposite sides, are examples of serious discrepancies. These items will be held at the facility until immediate corrective measures are completed and verified by the NELMA Inspector.

• Altering Stamps or Removal from Designated Facility: These actions by a facility are serious infractions that will result in immediate action by NELMA.

• Corrective Action Requested by NELMA Inspector from Previous Inspection Not Completed OR Items Held for Corrective Action No Longer at Facility for Re-‐Inspection: Either of these findings will result in the facility placed on immediate WARNING.

• Purchases/Usage Forms Not Maintained: This is a serious discrepancy that impairs the inspector’s ability to verify compliance by the WPM facility.

• Incomplete or Missing Heat Treatment Records: This is a serious discrepancy that impairs the inspector’s ability to verify compliance of the Heat Treatment process.

• Records Unavailable for Review: All documents maintained at a facility pertaining to the NELMA Facility Certification and Compliance procedures must be accessible at all times to the NELMA Inspector during each unannounced inspection. A facility shall designate sufficient “back-‐up” personnel with access to the information should the primary contact be unavailable. The Inspector’s inability to review a facility’s records during each inspection is a serious compromise to the compliance and verification process.

• Inaccessible Facility: The NELMA Inspector will only visit facilities within the standard work week during the hours of operation provided to NELMA by the facility. The integrity of the IPPC ISPM 15 program depends upon regular inspections to ensure total compliance with the standard. The inability to access a facility on consecutive visits by a NELMA Inspector could result in either a WARNING or SUSPENSION OF SERVICES. It is the responsibility of the facility to notify NELMA, as soon as possible, of any changes in hours of operation.

• Lost / Misplaced Stamps: Certain and immediate action by facility management is required when any stamp or stencil is lost or misplaced, as follows:

o If a stamp is found missing by the NELMA Inspector during a regular inspection visit, the facility must perform an immediate search of the premises for the stamp. If the stamp remains missing after this initial search, facility management must inform the NELMA Office via email ([email protected]) or by phone (800-‐819-‐6040) within 5 business days stating the results of their continued search and investigative findings. Dependent upon the circumstances, NELMA may choose to allow the facility to reorder stamps with existing facility number, force replacement of all stamps with a new unique facility number, place the facility on WARNING, or a full SUSPENSION OF SERVICES.

14

o If a stamp is found missing by the facility and notifies the NELMA Office immediately, facility management must inform the NELMA Office via email ([email protected]) or by phone (207-‐829-‐6901) within 5 business days stating the results of their search and investigative findings. Dependent upon the circumstances, NELMA may choose to allow the facility to reorder stamps with existing facility number, force replacement of all stamps with a new unique facility number, place the facility on WARNING, or a full SUSPENSION OF SERVICES.

Note: A copy of all previous inspections will be maintained by the NELMA Inspector within the NELMA Red Binder for review and reference by facility personnel.

NELMA Disciplinary Actions

Inspection findings that report ongoing serious discrepancies at a certified facility will result in NELMA issuing either a WARNING or SUSPENSION OF SERVICE. These conditions will result in notification to ALSC and the inability by the facility to obtain supervisory services from any ALSC-‐accredited agency for:

• 60 days with a WARNING, and • 180 days with a SUSPENSION OF SERVICE Discovery of blatant misuse of the NELMA stamps or severe lack of cooperation with NELMA and its Inspectors will result in IMMEDIATE SUSPENSION OF SERVICE. NELMA may reinstate inspection services only after the facility management and designated personnel fully demonstrate the ability and willingness to maintain the requirements of NELMA’s Heat Treatment and Wood Packaging Materials Certification Program.

Inspections by ALSC

In addition to NELMA’s inspection, all NELMA certified wood packaging facilities will also receive inspection visits on a random and infrequent basis by the Inspection staff of ALSC, as noted in the NELMA “agreement”. These inspections will also be unannounced and are conducted to ensure that NELMA, as an accredited agency of ALSC, is performing the required inspection procedures prescribed by IPPC ISPM 15 and ALSC. ALSC will notify the NELMA Office upon completion of their inspections, including their request to facility personnel to hold, on-‐site, any non-‐conforming wood packaging material items in need of corrective action. These ALSC-‐held items MUST remain at the facility for NELMA’s Inspector to review and release, based upon the corrective action taken by facility personnel following ALSC’s Inspection. If the held items are shipped prior to NELMA’s inspection, the facility will be placed on immediate WARNING.

General Information

For recordkeeping purposes, NELMA requires certified facilities to maintain copies of all required documentation for a full 5-‐year period prior to the current year, on a calendar-‐year basis.

15

Annex I Facsimiles of Stamps Available for Use by Certified NELMA Facilities

Heat Treated (HT) Lumber Stamp

IPPC HT Stamp Dunnage HT Stamp

Use ONLY on Heat Treated Lumber or Remanufactured

Lumber Components

Use ONLY on Completed Wood Packaging

Material Units (Pallets, Skids, Boxes, Crates, etc.)

Use ONLY on Heat Treated Lumber to be used as Dunnage

Material

Required stamp information:

• Method of Treatment (HT=Heat Treatment),

• Unique number assigned to the facility by the agency (000 in this example),

• Registered logo of NELMA. (NELMA “sawblade” logo or “NELMA”).


• International symbol for wood packaging (IPPC logo),

• Country of origin of WPM manufacturer (US),

• Unique number assigned to the facility by the agency (000 in this example that follows 09),

• Method of treatment (HT=Heat Treatment), and

• Registered logo of NELMA.


• International symbol for wood packaging (IPPC logo),

• Country of origin of WPM manufacturer (US),

• Unique number assigned to the facility by the agency (000 in this example that follows 09),

• Method of treatment (HT=Heat Treatment),

• Registered logo of NELMA, and • The word “DUNNAGE” or “DUN”

Annex II Facsimiles of Stamps Required on Purchased Heat Treated (HT) Lumber

Sample Heat Treatment (HT) Stamp Sample Lumber Grade Stamp


• Method of Treatment (HT=Heat Treatment), • Unique number assigned to the facility by an ALSC-‐

accredited agency (000 in this example), and • Registered logo of an ALSC-‐accredited inspection agency

(NELMA in this example – See ALSC List for all agencies).

Required information within a grade stamp for use in WPM:

• Heat Treatment notated in Stamp (KD-‐HT= Kiln Dried and Heat Treated)),

• Unique number assigned to the facility by an ALSC-‐accredited agency (000 in this example), and

• Registered logo of an ALSC-‐accredited inspection agency (NELMA in this example – See ALSC List for all agencies).

OR

17

Contact NELMA

Contact NELMA Further details regarding the NELMA Heat Treatment (HT) and Wood Packaging Materials (WPM) Certification Program, please contact us at any time:

Phone: (800) 819-‐6040 Fax: (207) 829-‐4293

Email: [email protected]

Extensive information is also available on our website, www.nelma.org, under the “Inspection Program” tab, “Wood Packaging Inspection” subtab. This includes access to the latest list of countries that have implemented the ISPM 15 standard and their specific requirements.

Northeastern Lumber Manufacturers Association P.O. Box 87A Cumberland Center, ME 04021

rev. 03/12

Facility Certification Program and Compliance … Certification! Program and Compliance Procedures!!...

Documents

Transcript of Facility Certification Program and Compliance … Certification! Program and Compliance Procedures!!...