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CASE STUDY of UK Implementation of ISPM 15. JOHN MEAD for UK TIMBER PACKAGING and PALLET CONFEDERATION (TIMCON). TIMCON. UK Trade confederation established in 1957 120 members Manufacture and repair all types of wood packaging Member of European wood packaging Federation (FEFPEB)
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CASE STUDY of UK Implementation of ISPM 15 JOHN MEAD for UK TIMBER PACKAGING and PALLET CONFEDERATION (TIMCON)
TIMCON • UK Trade confederation established in 1957 • 120 members • Manufacture and repair all types of wood packaging • Member of European wood packaging Federation (FEFPEB) • Associate and overseas members enrolled
EUROPEANIMPLEMENTATION • TIMCON undertook presentations after UK pilot programme success from 2001 • UK operational model taken as example to copy by many EU Countries • Principles and practicies adopted widely • Each Country responsible for their own implementation
ADVISORY COUNCILTrade Associations • Timber suppliers • New pallet producers • Case makers • Export packers • Repairers and traders • Inspection • Fumigation Treatment
PILOT CONSULTATION2001 • Consultative committee seen as VITAL for success • UK voluntary marking programme started • Partnership approach • Developed in line with realities of trade • Based on future requirements of ISPM 15
INDUSTRY COMMITMENT • Saw the trading necessity to have treatments available • Encouraged investment in HT chambers • Worked with Forestry Commission to iron out procedures • Regular consultative meetings important
DETAILED ASSESSMENT REQUIREMENTS for UK COMPANIES • Reject process defined • Designated person on each site • Penalties for abuse • Appeals procedure established
COSTS and CHARGES • REGISTRATION Fee £uk 400 (~us$700) • COMPANIES INITIAL ASSESSMENT FEE negotiated with assessing companies • 6 monthly RE-ASSESSMENT FEE as above • COSTS of any APPEAL
PRACTICAL PROMOTION • Conferences for Exporters • Presentations to exporting agents • Emphasis on adoption by importing countries • Articles in exporters trade magazines • Many presentations to packaging manufacturing companies
CURRENT IMPLEMENTATION • 500 REGISTERED SITES • Treatment capacity has exceeded demand growth • External assessment companies and producers work together • Slower acceptance in recycling sector companies
TREATMENTCAPACITY AVAILABLE • 49 COMPANIES WITH CHAMBERS • 8 PROFESSIONAL FUMIGATING COMPANIES • 3 ASSESSSMENT COMPANIES
CALIBRATION OF EQUIPMENT AND PROBES • Technical calibration must be undertaken at start up • Recalibration of sensitive items is needed regularly • Positioning of probes must be consistent to justify treatment correct • Computer recording must link to audit records
Costs • Treatment means higher costs • Treatment is a requirement • Non-competitive effect
TREATED RAW MATERIAL IMPORTS • Certified mills in country of origin • Audit trail required through shipment documents • BLUE STAIN • FUNGUS
CHAIN OF CUSTODY • Use of imported packs must be capable of being audited • Volumes received must reconcile to use • System must demonstrate consistency and transparency • Responsible person is accountable
PROTECTION OF MARKS • Integrity of system vital • A level playing field is the objective • Controls have to keep out false marking to protect investment of registered companies • Encourage the passage of information to the plant health authority • Confidentiality of information source maintained • Penalties must be real
ENFORCEMENT • Audits by appointment • Power to inspect • Power to remove registration
PENALTIES • Warning of concern • Required to re-treat and re-mark • Payment of further assessment costs • Removal of registration for further non-compliance
Repair, remanufacture and recycling • Removal of previous mark and re-treatment and re-marking is required • Reuse without further treatment may be valid in specific known reuse systems
DEMAND by International “User” Corporations • Adopted the KISS principle at the end of their production lines • Too hard to buy and use different pallets • Decisions to “only” buy all pallets treated • Developing steadily an inventory of treated pallets
SUMMARY • Industry Partnership between the “Regulators” and “Regulated” • Companies commitment • Clear and acceptable requirements • Monitoring and controls consistent
Message from PRESIDENT ofEUROPEAN PACKAGING FEDERATION • COMMITMENT OF COMPANIES IS VITAL • WOOD PACKAGING QUALITY is IMPROVED by TREATMENT • REGULAR CONSULTATION WITH the National Plant Protection Organization NEEDED
WEB SITES for reference UK TIMCON.org EU fefpeb.org Thank you for your attention