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Plants> Plant Protection Policy Directives > Forestry 

Review

This directive shall be reviewed every 2 years or unless otherwise needed. The next review date for this directive is anticipated for November 30, 2007. The contact for this directive is Joanne Rousson. For further information or clarification, please contact the CFIA Forestry Section.

Endorsement

Approved by:

Amendment Record

Amendments to this directive shall be dated and distributed as outlined in the distribution below.

Distribution

1. Directive mail list (Regions, PHRA, USDA)
2. Provincial Government, Industry (via Regions)
3. National Industry Organizations (determined by Author)
4. CWPCP Listserv
5. CWPCP Working Group
6. Internet

Introduction

Wood packaging is essential for trade and the movement and protection of cargo and containerized goods. Wood packaging can accompany any article and represents a large group of products such as pallets, dunnage, boxes, crating, packaging blocks, drums, cases, load boards, pallet collars, and skids. Historically, these products were commonly produced from non-manufactured wood which lacked sufficient processing or treatment to remove or eradicate pests present in the wood.

Canadian pest interception records have demonstrated that a large variety of pests can be transported with wood packaging and in many circumstances the pests have been able to survive. The Canadian pest risk assessment (PRA) for the import of wood packaging has scientifically identified wood packaging as a significant pathway for the movement of quarantine insects and diseases of plants and trees.

Despite the development of a variety of import requirements for wood packaging, pests continue to move throughout the world on wood packaging. It is believed that the introduction of several invasive quarantine pests, for example, Asian Long-horned Beetle, Brown Spruce Longhorn Beetle, Emerald Ash Borer and the Pine Shoot Beetle, into North America is related directly to the movement of wood packaging from other areas of the world. As global trade continues, every importing country is at risk from the introduction of wood pests.

In March of 2002, the International Plant Protection Convention (IPPC) adopted a wood packaging standard; Guidelines for Regulating Wood Packaging in International Trade, (ISPM No. 15). This standard recognizes the plant health risks associated with wood packaging and outlines approved phytosanitary measures. To target the plant health risk associated with wood packaging, the standard recommends that all wood packaging should be treated. To facilitate trade, treated wood packaging must be marked in a manner to identify the approved treatment and to provide traceability to the country of origin and the producing facility.

The CWPCP is a certification system that allows Canadian wood packaging facilities and treatment facilities to build wood packaging products that meet the provisions of ISPM No. 15. The final product will be marked with a Canadian wood packaging certification mark. This mark will be unique to each Registered Facility.

The CWPCP and The Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07) provide the specifications for the treatment and manufacturing of wood packaging material in accordance with the requirements of ISPM No. 15. The CWPCP uses a quality systems approach designed to allow traceability of treated wood packaging material certified under this program to the actual treatment record, treatment facility, and the wood packaging facility.

Wood packaging produced under the specifications of this standard by CFIA registered facilities also meets the conditions of delivery of the program recognized by the European Union (EU) as a derogation from the Phytosanitary Certificate requirements of Council Directive 2000/29/EC in respect of heat-treated wood of conifers originating from Canada to prevent the introduction of the Pinewood Nematode (Bursaphelenchus xylophilus) via wood packaging material. Although the use of the earlier “NO-BUG” stamp is discontinued under this revised policy and is replaced by the certification mark, as specified in Appendix 1, the “No-Bug” stamp on softwood packaging material will continue to be recognized by the EC until December 31st. 2007 for packaging material manufactured prior to February 28th. 2005.

The list of countries having indicated, through official World Trade Organization Notification that they have approved the standards with the ISPM No. 15, Guideline for the Regulating Wood Packaging Materials in International Trade, March 2002. can be viewed at http://www.ippc.int/IPP/En/default.htm.

Note 1 : Certain countries may have specific phytosanitary import requirements in addition to those specified in this document. Please consult the specific import requirements of the foreign country to verify if there are additional requirements.

Scope

This directive is intended for the use by Canadian wood packaging facilities, custom brokers, freight forwarders, export product producers, CFIA inspection staff and any CFIA Service Provider. It sets forth the necessary requirements and inspection procedures for the certification of wood packaging used in the transport of consignments for export.

References

• Glossary of Phytosanitary Terms, Publication No. 5, FAO, October 2002. http://www.ippc.int/IPP/En/default.jsp
• ISO Guide 8402, Quality Systems Terminology.
• ISPM No. 15, Guidelines for regulating wood packaging in international trade, FAO, March 2002 http://www.ippc.int/IPP/En/default.jsp
• CFIA (PI-07), The Technical Heat Treatment Guidelines and Operating Conditions Manual
• QSM no. 02, “The Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP)”
• QSM no. 03, The Quality System Requirements for the Service Provider approved under the CWPCP

Definitions, Abbreviations and Acronyms

1.0 General Requirements

1.1 Legislative Authority

The Plant Protection Act, s.c. 1990, c.22
The Plant Protection Regulations, SOR/95-212
Canadian Food Inspection Agency Act (1997, c. 6)
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part 1 (05/13/2000)
Agriculture and Agri-Food Administrative Monetary Penalties Act, (1995, c. 40)
Agriculture and Agri-Food Administrative Monetary Penalties Regulations, (SOR/2000-187)

1.2 Fees

When a wood packaging facility applies to participate in the CWPCP, the facility must pay the Service Provider for registration and inspection services. The facility must also remit to the CFIA, a registration payment of $400.00 by separate cheque payable to the Receiver General of Canada, as of October 1^st. 2005 or on application following this date, and on October 1^st. of each year thereafter, for participation in the program, for audit and administrative services.

1.3 Regulated Pests

Wood packaging is a pathway for the movement of a number of serious pests to trees and shrubs. A list of regulated pests has been developed within the ISPM No. 15 and is provided in Appendix 2.

1.4 Regulated Commodities

Regulated commodities include all non-manufactured wood packaging and loose wood dunnage constructed from coniferous (softwood) and non-coniferous (hardwood) wood or combinations thereof to be exported from Canada to countries, other than the continental United States (US), that have adopted ISPM No. 15 standards. This also includes wood crating, packaging blocks, drums, cases, load boards, pallet collars, and skids which can be present in almost any exported consignment, including consignments which would not normally be the target of phytosanitary.

1.5 Commodities Exempt

Wood packaging or loose wood dunnage produced wholly (100%) from manufactured wood are not subject to the requirements of this policy. Plywood, particle board, oriented strand board or veneer that were created using glue, heat and pressure or a combination thereof would be examples of such products.

Wood packaging material made from sawdust, wood wool, shavings and raw-wood cut into thin pieces (less 6 mm. in thickness) is also exempt. Some countries may have additional phytosanitary requirements for the import of manufactured wood. Please contact a local office of the CFIA for more specific information on a country’s import requirements.

2.0 Specific Requirements

2.1 Approved Treatment Options

Presently, heat treatment and methyl bromide fumigation have been accepted internationally as approved measures under ISPM No. 15 as approved measures in mitigating pest risks associated with wood packaging. Canada is a signatory of The Montreal Protocol on Substances that Deplete the Ozone Layer (1985) agreeing to the reduction and eventual phase-out of ozone depleting substances. Methyl bromide, an ozone depleting substance, has been undergoing phase-out since 1995. For this reason, methyl bromide fumigation will not be considered for approval under this program. Additional measures are being considered for approval under ISPM No. 15. (Refer to Annex III of ISPM No. 15 for treatments being considered.)

2.1.1 Heat Treatment (HT)

Under ISPM No. 15 requirements, wood used for the construction of export wood packaging material or the export wood packaging material itself must be heated in accordance with a specific time-temperature schedule that achieves a minimum wood core temperature of 56ºC for a minimum of 30 minutes.

The heat treatment must occur at a facility approved by the CFIA and operating under the Canadian Heat Treated Wood Products Certification Program (CHTWPCP), D-03-02, or the Canadian Wood Packaging Certification Program (CWPCP), D-01-05.

The official list of all CFIA approved heat treatment facilities is maintained on the CFIA Forestry Section web site at http://www.inspection.gc.ca/english/plaveg/for/cwpc/treatface.shtml

2.1.2 Pesticide Treatment

Methyl bromide fumigation will not be considered for registration under this program. Where it is determined that this treatment option is the only viable option to meet the phytosanitary requirements of the importing country and where heat treatment is not practical to implement, a phytosanitary certificate may be issued. Facilities or operators wishing to obtain phytosanitary certification must contact the CFIA inspection office. (A list of CFIA inspection office can be found at www.inspection.gc.ca ).

2.1.3 Other Treatment Options Under Consideration

Several other treatment options are being evaluated by the international scientific community (Annex III of ISPM No. 15). When new treatment options are endorsed for use by the IPPC or by importing countries, the CFIA will add these options to the program.

Kiln-drying (KD), chemical pressure impregnation (CPI), thermal water bath or other treatments may be considered HT treatments to the extent that these treatments meet HT specifications as stated above.

3.0 Recognized Certification Marks

3.1 ISPM 15 Wood Packaging Recognized Mark

Once a wood packaging facility has been registered by the CFIA, a unique facility registration number will be assigned to the facility by the CFIA. This number acknowledges that the facility meets the official phytosanitary criteria for registration and will become part of their wood packaging mark recognized under ISPM No. 15. (Appendix 1).

The wood packaging certification mark must be legible, permanent and placed in a visible location on a minimum of two opposite sides of the article being certified. The wood packaging certification mark should be black. The ink colours of red or orange must not be used.

The wood packaging certification mark may be stamped, labelled or branded to the wood packaging. Tags or other non-permanent applications of the mark are not permitted.

The wood packaging certification mark is non-transferable and ultimately provides traceability to the facility and the location where the treatment occurred. One facility registration number will be issued to each facility location.

The mark must include the information outlined in Appendix 1 of this directive. There are specific coding designation for material which either been heat treated,or if the material in question is dunnage.

A list of countries having implemented ISPM No. 15 can be found http://www.inspection.gc.ca/english/plaveg/for/cwpc/ispmnimp15e.shtml.

4.0 Registration under the CWPCP

Wood packaging manufacturing facilities, wood packaging facilities treating lumber for the manufacturing of their own wood packaging material, or heat treating the actual wood packaging material (ie. Crates, pallets, boxes, etc.) to meet the ISPM No. 15 standards, may apply for registration under the CWPCP. Facilities other than wood packaging facilities treating lumber for another facility, for the purpose of meeting the ISPM no. 15 standards, will be required to register under the CHTWPCP.

4.1 Eligible Applicants

Eligible applicants include those Canadian facilities handling wood products intended for the treatment or manufacturing of wood packaging material, ultimately destined for export to countries having specific phytosanitary certification requirements.

An applicant must be:

• Canadian citizen or permanent resident;

• a person authorized under the laws of Canada to reside in Canada for a period of six months or more and who will have possession, care or control of the thing to be treated or manufactured, distributed or

• in the case of a corporation with a place of business in Canada, the applicant must be an agent or officer of the corporation who resides in Canada, and

• the facility to be registered must be located in Canada.

Note 2: Facilities already registered under the CWPCP may operate under the specifications of this revised policy directive without re-application for participation. A revised Quality Manual outlining the modifications required under this revised policy directive must be submitted to a Service Provider within six months following the selection of the necessary Service Provider. The facility will be registered under the CWPCP upon CFIA’s approval of the quality manual.

4.2 Application for Participation

An application form must be completed in full, and signed by an eligible applicant. By signing the application form, the applicant agrees to comply with the terms and conditions of The Canadian Wood Packaging Certification Program (CWPCP).

Note 3: A copy of the application form can be obtained from the CFIA website at http://www.inspection.gc.ca/english/plaveg/for/cwpc/appcerte.shtml or a CFIA Service Provider. The completed form shall be submitted to a CFIA Service Provider.

Note 4: The name of the Service Provider and a list of participants registered under the CWPCP as wood packaging facilities can be found at http://www.inspection.gc.ca/english/plaveg/for/fore.shtml.

4.3 Submission of a Quality Manual

A Registered Facility must operate under a quality system that ensures consistent compliance with the phytosanitary requirements (heat treatment as specified above, records pertaining to treatment, documentation in support of certification and other related activities). The facility must document the procedures to be followed in the system to meet the conditions of the CWPCP. This documentation is the facility’s Quality Manual and must be approved for use by a CFIA Service Provider and the CFIA.

Note 5: For guidelines on developing Quality Manual refer to “The Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP)”, (QSM-02).

5.0 Heat Treatment Requirements

Facilities may achieve the phytosanitary standard for treatment specified in section 2.1.1 through a number of processing methods. The CFIA, Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07) has been developed to provide additional mandatory information to heat treatment facilities regarding the heat treatment chamber operating condition, and further define the technical requirements to participate under the export certification program. This manual is maintained on the CFIA Forestry web site at: www.inspection.gc.ca/english/plaveg/for/fore.shtml.

In addition, facilities may achieve the phytosanitary standard for treatment specified in section 2.1.1 through a processing method which has been approved by a Recognized Heat Treatment Evaluator and identified in the Quality Manual.

5.1 Identification of Treated Wood Products for the domestic market intended for the manufacturing of wood packaging material for export

Heat treated wood products moving in the domestic market, which is ultimately intended for the manufacturing of wood packaging material for export markets, other than the U.S. (requiring to be heat treated to a minimum wood core temperature of 56ºC for a minimum of 30 minutes) must have been heat treated by a facility registered under the CWPCP or the CHTWPCP, and must:

a) Display a CHTWPCP recognized certification mark as described in 2.3.1.3 on each wood bundle, bundle tag or on the bundle wrapper, or

b) Display the CLSAB accredited mark on each piece of lumber consisting of the grading agency logo, the facility registration number and the HT or KD-HT mark, which is recognized by the CFIA and appearing on the CFIA website, or

c) Be identified in a manner prescribed in the facility’s Quality Manual and accompanied by a Heat Treatment Certificate.

Note 6: Facilities may obtain a copy of a blank copy of the Heat Treatment Certificates on the CFIA website at: www.inspection.gc.ca. An example of a Heat Treatment certificate can be found in Appendix 3.

The Quality Manual must specify the sources of wood being supplied to the facility. Treated wood used in the construction of certified wood packaging material must be marked to ensure traceability and must have been treated by a facility registered under the CHTWPCP or the CWPCP.

Treated wood material may be sourced from a shipper or broker not registered under the CHTWPCP or the CWPCP providing it is marked and secured to ensure that it can be traced to a registered treatment facility. The marking and the method to ensure traceability of the wood material must be outlined in the Quality Manual of the manufacturing facility.

In cases where treated wood is re-manufactured by a third party before arriving at the wood packaging facility the facility will be required to register under the CWPCP. A Quality Manual will be required to comply to the requirements of this program.

Heat treated wood originating from the US, which is to be used by a Registered Facility for the construction of certified export wood packaging material, must be marked in accordance to the official USDA Animal Plant Health Inspection Service wood packaging program.

The registered facility must specify in its Quality Manual a process for verifying that separation between treated and non-treated wood is consistently maintained and that the system of wood segregation is clearly known by facility employees. The segregation may include a physical barrier between lots, identification marks on lots or a distance separation between lots.

The wood packaging manufacturing facility performing the actual heat treatment must assure that the wood product has been heat treated to a minimum wood core temperature of 56ºC for a minimum of 30 minutes as outlined in section 5.0.

5.2 Treatment Records

Each facility shall maintain records that verify that each treatment has met the technical specifications outlined in the CWPCP. The facility shall indicate in the Quality Manual the type of information to be maintained. Records are to be kept by the facility for a minimum of 2 years after treatment.

6.0 Re-Used Wood Packaging Material

All wood packaging that bears the official wood packaging certification mark from Canada or another country and has been constructed under the specifications of ISPM No. 15, which has not been repaired or reconstructed with new wood components, may be re-exported from Canada.

It is the obligation of the Canadian exporter to ensure that wood packaging material to be re-exported meets the import requirements of ISPM No. 15 and/or the importing country.

7.0 Repair and Re-manufacturing of Previously Certified Wood Packaging Material

All repaired and re-manufactured wood packaging material intended for export must be re-treated and re-certified under an approved program after repair or reconstruction. The final wood packaging product must be re-marked by the approved wood packaging facility or by the registered treatment facility. All other wood packaging certification marks must be obliterated or removed.

8.0 Export Certification

All wood packaging material certified under the CWPCP must bear the internationally recognized mark as outlined in Appendix 1.

Registered Facilities will not be permitted to display their wood packaging certification mark on any products that require assembly in a foreign country.

Countries may have different phytosanitary import requirements for heat treated wood product intended for use in the manufacturing of wood packaging material. Where countries require Phytosanitary Certificates to accompany shipments of heat treated wood product intended for use in the manufacturing of wood packaging material, a registered facility must provide to CFIA, a copy of the Heat Treatment Certificate(s) issued for the shipment or must be able to demonstrate that the wood products have been heat treated in accordance to the phytosanitary standard as described in this policy directive. CFIA may request additional supporting information such as charge/kiln records or may inspect the forest product for the presence of quarantine pests.

The American Lumber Standards Committee (Incorporated) (ALSC) is recognized as the certification authority in the US. Lumber entering the US. wood packaging certification process, must meet the prescriptions of the ALSC domestic production standards. This applies both to softwoods and hardwoods. Canadian ALSC accredited agencies can provide certifications options which meet this criteria.

8.1 Wood Dunnage- Export Certification

All wood dunnage exported should be treated by a registered facility as prescribed in this policy and identified by a wood packaging certification mark containing the letter “D” which designates dunnage as specified in Appendix 1. Each individual piece of dunnage material must display the required mark.

8.2 Export certification for wood packaging material not manufactured under the CWPCP

There may be situations where a Phytosanitary Certificate is requested by exporters who are not registered under this program. In such instances, the exporters must comply to specific elements of this policy directive, and must be able to demonstrate that the wood products have been heat treated in accordance to the phytosanitary standard as described in this policy directive. The exporter must document the procedures to be followed in the system in a Quality Manual to meet the conditions of the CWPCP. Elements to be included in the Quality Manual will be identified in the “The Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP)”, (QSM-02).

9.0 Non-Compliance

Export shipments containing wood packaging material must meet the requirements of the importing country. The interception of non-compliant wood packaging by a foreign government, may result in enforcement action by the foreign government. Non-compliant material will likely lead to delays in product delivery, treatment or disposal of non-compliant wood packaging including related costs.

Failure to meet the phytosanitary import requirements of a foreign importing country is also a violation of Canadian law, specifically, the Plant Protection Regulations, and may lead to enforcement actions by the CFIA and suspension or cancellation from this program.

10.0 Recognition of the Service Provider

Subject to the Treasury Board Secretariat Policy on Alternative Service Delivery, as amended from time to time, CFIA may recognize an organization, company or person for the purposes of carrying out inspections related to verifying the conformity of registered facilities within the requirements of this policy directive. Those recognized are referred to as a Service Provider.

Upon acceptance by the CFIA of a satisfactory application, and upon any approvals required under the Alternative Service Delivery Policy set out above, the Service Provider shall sign an agreement with the CFIA.

11.0 Responsibilities of the Service Provider

The Service Provider must adhere to the requirements outlined in the service contract with CFIA, the Quality System Requirements for the Service Provider Approved under the CWPCP-(QSM 03), and this policy directive. The Service Provider shall have in force a documented quality system. The quality system must provide for adequately trained staff, reports of inspection, frequency of inspection, etc. The CFIA Service Provider should make its services available to facilities wishing to register under this program. The Service Provider must have a specific arrangement with registered facilities who have negotiated to contract with it, to permit the delivery of activities, audits, etc. as required to fulfil its role under this policy directive.

The CFIA Service Provider will conduct inspections in the manner and rate set out in QSM-02 “The Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP)”,to verify that registered facilities are consistently meeting the requirements of the CWPCP.

The Service Provider is responsible for providing reports to the CFIA as outlined in QSM 03 and is responsible for ensuring that its inspection reports properly and accurately reflect its findings. The Service Provider will immediately notify the CFIA, whenever it finds a registered facility operating in such a manner as to compromise the integrity of the CWPCP.

Subject to the reporting to the CFIA, the Service Provider is required to maintain the confidentiality of all registered facilities. The Service Provider will cooperate with to the CFIA when conducting audits of facilities or for other activities necessary in determining the compliance of facilities registered in this program.

The Service Provider will advise the CFIA if a registered facility ceases to operate under agreement with the Service Provider or has withdrawn from the CWPCP.

12.0 Responsibilities of the CFIA

CFIA is ultimately responsible for registration, suspension or cancellation of registration of any facility registered in the CWPCP. Upon verification that the facility is capable of successfully meeting the requirements of this directive, the CFIA shall:

• issue to the wood packaging facility or treatment facility a specific facility registration number
• approve the use of the facility’s wood packaging certification mark by adding the facility’s name to the official CFIA list of approved wood packaging facilities.
• in cooperation with the Service Provider conduct an evaluation audit of all new registered wood packaging facilities or treatment facilities during the program’s initial year of administration
• conduct verification audits of the facilities as established in QSM-02,“The Quality System Requirements for Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP)”.
• conduct verification audits on the Service Provider as outlined in (QSM 03), “The Quality System Requirement for the Service Provider Approved under the CWPCP”.

The CFIA reserves the right to conduct audits, at anytime during regular business hours, of registered facilities and the Service Provider operating under the CWPCP.

13.0 Appendices

Appendix 1: ISPM 15 Wood Packaging Recognized Mark
Appendix 2: List of Pests Targeted by the Approved Measures
Appendix 3: Heat Treatment Certificate 2002-V2

Appendix 1

Wood Packaging Certification Mark

The marks shown below shall certify that the wood packaging and loose wood dunnage material or articles which bears these marks have been subjected to approved measures.

The mark must include:

• IPPC recognized symbol
• XX: represents the two letter ISO country code, CA for Canada
• 00000: is a series of numbers issued by the CFIA which identifies the Registered Facility
• YY: is the treatment abbreviation
  – HT is the code for heat treatment to a minimum of 56ºC for a minimum of 30 minutes.
  – D is the designation for dunnage; D-HT

NPPOs’ of the importing countries may at their discretion request control numbers or other information used for identifying specific lots provided it is not confusing, misleading, or deceptive.

The Wood Packaging Certification Mark may only be applied by wood packaging producers or treatment facilities approved by the CFIA and operating under the CWPCP or the CHTWPCP.

The mark must be:

• legible
• permanent and not transferable
• placed in a visible location and on at least 2 opposite sides of the article being certified
• for dunnage material, the mark must be visible on each individual piece

The mark should be black in color. The colors RED and ORANGE MUST NOT be used.

Appendix 2

List of Pests Targeted by the Approved Measures

Members of the following pest groups known to be associated with wood and normally are eliminated by Heat Treatment (HT) (Section 2.1.1) when used in accordance with the specifications identified within the policy.

Appendix 3

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