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Page 30 of 47 PalletCentral • September-October 2015 31 Mark Illegibility NWPCA: Hi John, We recently have had several questions regarding how mark illegibility is addressed by ALSC. They wanted more background on the threshold and parameters for what is considered in compliance and out of compliance. ALSC: Thanks Brent. ALSC program requirements regarding legibility and proper labeling are in place for both the lumber being purchased as well as the WPM being produced. The ALSC requirements are identical regarding legibility for HT lumber and WPM marks. These legibility requirements have been in place and have not changed since the inception of the use of HT marks on lumber and the IPPC marks on WPM under the ALSC programs. Section 5.12 of the Lumber Enforcement Regulations concerning HT lumber and Section 5.6.13 of the WPM Enforcement Regulations both state: "Any item containing 10% or more pieces with grade marks deemed to be illegible or incomplete shall be held for remarking." The requirement to properly label the HT lumber purchased by the WPM facility is the responsibility of the producer of the HT lumber. The WPM facility ordering HT lumber with an accredited agency HT mark should not be receiving and should not accept illegibly labeled HT lumber. The WPM facility does have a responsibility to ensure legible and properly labeled heat treated lumber is used in WPM that is ultimately stamped with an agency IPPC mark by the facility. To that end, reviewing incoming HT lumber for legible and properly labeled heat treated marks is a part of the equation. If the WPM purchase order indicates accredited agency marked HT lumber and does not conform to the program requirements, the WPM facility should not accept the HT lumber. If the producer of the HT lumber does not address the issue, the WPM facility may have several options available to it such as working with its agency to address the problem, contacting the agency whose registered trademark is on the HT lumber to inform it of their concerns, use the illegibly labeled lumber in WPM that does not require ISPM 15 marking, produce WPM that will be heat treated by the facility prior to ISPM 15 marking or, ultimately if necessary, a claim can be initiated by the WPM facility if within the stated provisions of the grade rules under which the lumber was produced is met. Lastly, continued unaddressed issues can be brought to ALSC's attention for us to look into. When improperly labeled HT lumber is received and accepted by a WPM facility, several issues are presented in determining acceptability of use. Therefore, with over 5400 WPM facilities using heat treated lumber in all different manners it is important for the program requirements to provide a consistent requirement. As noted above, the labeling requirements have been vetted and in place since inception of the use of HT stamps. Discussions to accept other evidence of heat treatment such as chain of custody, mill or broker certificates, purchase orders, invoices, etc. have also been proposed over the years. Many of these methods were proposed when the WPM program was first initiated and the ALSC overwhelming decided that use of these methods would not permit the piece of paper to be tied to the actual HT lumber and the integrity of the US WPM program could be negatively impacted. Whereas, a HT accredited agency mark on the lumber A properly obliterated HT mark.

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