May-June 2016

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10 PalletCentral • May-June 2016 INSIDE NWPCA Capitol Hill Corner By Patrick Atagi, NWPCA Vice President, Advocacy & External Affairs I t's been a busy month for NWPCA on several fronts. We're happy to report that outreach to strategic entities, per the NWPCA strategic plan, has been paying off. While we focus on Capitol Hill and our work with Members of Congress, we also spend a lot of time working with the federal agencies including the U.S. Department of Agriculture (USDA), Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA) and the Small Business Administration (SBA). Brazil Confirms ISPM15 Acceptance NWPCA reached out to USDA-APHIS for additional clarification on Brazil's implementation of ISPM15 in regard to the recent changes to Brazil's Normative Instruction 32/2015 (NOM 32) for wood packaging material (WPM). NWPCA has been receiving reports from suppliers and companies, like Pandora, that there are problems and concerns regarding shipping wooden pallets to Brazil. To prevent vendors from changing to other types of pallets, NWPCA intervened in the situation. USDA confirmed with Brazil's Ministry of Agriculture, Livestock, and Food Supply (MAPA) that: "The phytosanitary/treatment certificate is optional. MAPA will accept either the International Standard for Phytosanitary Measures (ISPM) No.15 mark or the phytosanitary/treatment certificate. USDA-APHIS may issue a certificate if needed, when the WPM is treated but not marked." APHIS also provided clarity that they will only issue a phytosanitary/treatment certificate if the WPM is the product being shipped. The letter from USDA APHIS-PPQ can be found on NWPCA's ISPM15 information page from the "Industry Resources" tab at NWPCA Signs-on to National Association of Manufacturers' Letter The U.S. Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS) issued a draft "Importation of Wood Packaging Material from Canada" (Docket No. APHIS- 20100019 (RIN0579-AD28, known as the Proposed Rule). This rule, if implemented, would amend import regulations under the Plant Protection Act by removing the current exemption that allows North American wood packaging material, such as wood pallets, to enter the U.S. from Canada under a general permit. The proposed rule would have a significant detrimental impact on bilateral trade, while diverting enforcement resources away from areas of the North American border that serve as the main entry points for these pests. None of the pests identified in a 2009 pest risk analysis (PRA) are indigenous to Canada or the U.S., but are invasive species of Asian and/or European origin. Removal of the North American exemption on wooden pallets passing between the U.S. and Canada would not effectively address such pests. Instead, U.S. enforcement resources should be focused on the perimeter of North America, and not the U.S.-Canada border, to prevent the entry of pests that do not originate on the continent. NWPCA signed-on to the final coalition letter to USDA-APHIS based on technical and policy reasons or lack of empirical data to support USDA-APHIS' move and free trade policy. The NAM sought input from NWPCA for technical counsel on the letter. If you are interested in a copy of the letter, please drop a note to Patrick Atagi at PC NWPCA's "The Advocate" If you are an NWPCA member, be sure you are subscribed to "The Advocate" – NWPCA's monthly bulletin focused on our advocacy efforts aimed to keep you informed on the activity in Washington, DC and federal agencies. You may manage your subscription by checking the "advocacy" box from any email communication sent from NWPCA, and you do not have to be logged in to manage your email subscriptions. If you are not receiving any emails from NWPCA, check your SPAM folder and "approve" as a safe-sender, and then add the email senders to your approved senders list. If you still encounter issues receiving email, contact your IT department or Internet Service Provider to officially "whitelist" NWPCA.

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