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September-October 2015

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32 PalletCentral • September-October 2015 palletcentral.com provides direct trace back to the producer of the HT lumber should a problem exist. Given the importance of US export trade, and the role WPM plays in that trade, labeling on individual pieces of HT lumber used in WPM has always been determined to be of utmost importance in this regard. Thank you for the opportunity to respond and we hope this helps clarify concerns. Repaired Mark Obliteration Requirements on Companies That Didn't Per form the Repairs NWPCA: John, another question recently received was from a new pallet manufacturer (who does not perform any pallet repair) regarding their responsibilities to obliterate WPM marks on the repaired pallets they receive. ALSC: Since the 2009 revision, ISPM 15 has specifically addressed "repaired WPM" and how existing ISPM 15 marks are to be handled by the National Plant Protection Organization (NPPO) of countries where the WPM is repaired. As you know, the ISPM 15 mark is all that is necessary for the WPM to be used in international trade and as such should be protected as much as possible to protect the integrity of the WPM program. APHIS, the NPPO for the US, has the responsibility of implementing ISPM 15 in the United States. The ALSC has entered into a Memorandum of Understanding with APHIS to implement the ISPM 15 program in this country. As required by ISPM 15, ALSC recognizes repairs of WPM made in accordance with ISPM 15, provided it is done so under a process approved by an accredited ALSC agency, but has consistently required any other repaired WPM to have any existing ISPM 15 quality marks obliterated by program participants, even in situations where the participants do not perform the repair but are aware the WPM has been previously repaired. ISPM 15 is clear that NPPO's should require repaired WPM to be re-treated, destroyed, or otherwise prevented from moving in international trade in circumstances where there is any doubt that all components of a unit of repaired WPM are in accordance with ISPM15. One common example is when the company purchases WPM from a supplier that is known to be a repair operation. In this case, the WPM may have numerous ISPM 15 marks from several legitimate facilities but it is obvious that the WPM has been repaired. The ALSC requirement in this case is that any WPM BUSINESS

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