TE 5.4 WPM Guidance for OCONUS Depots.docx

TECHNICAL EXHIBIT 5.4

DDC Wood Packaging Material Program

A Guide for OCONUS Depots PUBLISHED November 2009

DDC WOOD PACKAGING MATERIAL (WPM) PROGRAM

GUIDE FOR OCONUS DEPOTS

PURPOSE

This guide to the Defense Distribution Center Wood Packaging Material program is published for DLA Defense Distribution Center Depots located outside the Continental United States (OCONUS). The guide is to be used as a quick reference tool that assists in establishing and sustaining a WPM program. This is an abbreviated document for ease of use but is not intended to replace the DOD 4140.01-M-1.

DOD REFERENCE DOCUMENT

DOD 4140.01-M-1 COMPLIANCE FOR DEFENSE PACKAGING - Phytosanitary Requirements for Wood Packaging Material (WPM)

WHY IS THE WPM PROGRAM SO IMPORTANT TO DLA?

The Department of Defense and its Components engaged in packaging of materiel for transnational shipments shall comply with the procedures explained in DOD 4140.01-M-1 in order to gain access to aerial and water ports. If these procedures are not followed, there is a strong risk that the improperly marked and/or untreated material will become frustrated cargo. This will delay customer orders, therefore delaying warfighter readiness.

WHAT IS THE DOD/DLA GOAL?

To treat, test, or phase-out all non-compliant WPM inventory over time and to ensure all WPM is in conformance with International Plant Protection Convention (IPPC) International Standard for Phytosanitary Measures (ISPM 15).

HISTORY OF THE WPM PROGRAM & IPPC (ISPM 15)

The origin of plant protection can be traced to an International Treaty adopted by the United Nations in 1952 which formed the International Plant Protection Convention (IPPC). The IPPC has been establishing and governing international standards regarding plant health for over 50 years. In 2002, based on concerns about invasive species, particularly the Pinewood Nematode, the UN IPPC issued guidelines to regulate packing material. The program began as Non-Manufactured Wood Packing Material (NWPM), grew to Solid Wood Packing Material (SWPM), and then into Wood Packaging Material (WPM). The UN IPPC guidelines are the International Standards for Phytosanitary Measures (ISPM 15), “Guidelines for Regulating Wood Packaging Material in International Trade”.

Currently, over 160 governments adhere to United Nations IPPC guidelines. Specific country requirements can be found by using the following link and selecting the country items are being shipped into:

http://www.aphis.usda.gov/import_export/plants/plant_exports/wpm/country/index.shtml

WHAT IS ISPM 15?

ISPM 15 is the ‘International Standards for Phytosanitary Measures Publication No. 15: Guidelines for Regulating Wood Packaging Material in International Trade’.

WHY WAS ISPM 15 DEVELOPED?

ISPM 15 was developed to address the global spread of timber pests by regulating the movement of timber packing and dunnage in international trade. ISPM 15 describes Phytosanitary measures to reduce the risk of introduction and/or spread of quarantine pests associated with solid timber packing material (includes dunnage).

The current Phytosanitary requirements for WPM have been imposed by the Food and Agriculture Organization (FAO) of the United Nations (UN) to protect forests worldwide against pest infestation. The concern is that non-manufactured WPM may contain pests from the forest where it was grown and may spread pest or destruction outside the originating country.

WHAT CONSTITUTES WPM?

Non-Coniferous (Hardwood) and Coniferous (softwood) packaging material used in supporting, protecting, or carrying a commodity (includes dunnage). Examples of WPM include but are not limited to pallets, skids, pallet collars, containers, crates, boxes, cases, bins, reels, drums, load boards, and dunnage. Wood packaging made of exempt materials but combined with solid wood components must still be treated and marked. WPM does not include processed wood materials and manufactured wood products.

WHAT TYPES OF MATERIAL ARE EXEMPT?

Manufactured (processed) wood products are not affected (for example, plywood, particle board, oriented strand board (OSB) and veneers) thus do not require to be treated and marked.

ROLE OF DDC WPM COORDINATOR

Provides supply support to Distribution Depots and Services on policies and procedures pertaining to DOD 4140.01-M-1. The DDC WPM Coordinator manages the DDC WPM program, reviews monthly reports provided by OCONUS sits.

ROLE OF DEPOT WPM SITE CUSTODIAN (WPM POC)

The depot WPM Site Custodian is the point of contact with DDC for any issues related to the WPM program. A good line of two way communication between the DDC WPM coordinator and the site WPM POC is necessary.

The Main functions of the depot WPM POC follow in the next couple paragraphs.

Maintain WPM data for audit purposes, which includes maintaining records of all compliant lumber received and used. Oversee the fabrication of new WPM or repair of WPM with new lumber and application of the Certification Mark.

Maintain records of individuals who passed the DoD WPM training on the DoD WPM Web Site. Maintain documents pertaining to the number of ISPM 15 certification marking devices in the custody of the location. Responsible for the calibration of moisture meters.

Maintain records of corrective actions taken in response to reported WPM audit failures or discrepancies developed against the site by an audit, shipping, or receiving activity.

SITE AUDITS

At any time the DDC or DoD WPM Enforcement Committee may conduct an audit on a depot. The Enforcement Committee includes: members of the Defense Packaging Policy Group, the Deputy Under Secretary of Defense, Supply Chain Integration Office and members from the United States Department of Agriculture.

MONTHLY REPORTING OF IPPC

Activities fabricating new WPM or repairing WPM with new heat treated certified lumber and applying ISPM 15 certification mark (IPPC Stamp) will track and provide monthly reports to DDC Coordinator. The following will be included in the monthly reports and will also be maintained at the activity level for verification during on site audits:

Lumber receipts - including the receipt or requisition number, mill code, lumber NSN or identification number, lumber thickness, lumber width, lumber length, quantity received, and date of receipt.

Lumber used - including the cut and fabrication work order number or other approved document number, lumber NSN or identification number, lumber thickness, lumber width, lumber length, number boards of each size used, and date of fabrication. This information will be maintained at the activity level for verification during on-site audits.

Lumber usage report identifies the lumber on hand at the beginning of the month, lumber received, lumber used, and final inventory of lumber on hand at the end of the month.

WPM TRAINING FOR EMPLOYEES

All personnel handling, using, managing, or auditing WPM are required to take an on-line training course every two years. The expected outcome of the training is that DoD Components will actively promote, implement, monitor, and measure procedures explained in the training to ensure the elimination of “pests” in WPM. Upon completion of the training, employee will be “WPM Certified.”

WPM Site Custodian must maintain copy of employee training certificate records for two years.

The training takes approximately one hour to complete and can be found at:

https://tarp.navicp.navy.mil/WPM/WPM_training.nsf

ALL LUMBER & WPM PURCHASED MUST BE ISPM 15 COMPLIANT

All lumber and WPM procured must be within the ISPM 15 guidelines for shipments to any country or for packaging material stored at Defense depots.

Compliant lumber is marked HT (heat treated) or KD/HT (Kiln Dried and Heat Treated) or MB (methyl bromide).

Compliant WPM (pallets, skids, boxes, etc.) must be stamped with the ISPM 15 (IPPC Stamp). HT/KD/MB is proper for lumber, but is not an acceptable marking on WPM.

RECEIVING NEW PROCUREMENT (NOT ON PALLETS)

Depots shall monitor all incoming Wood Packaging Material (WPM) for the International Plant Protection Convention (IPPC) mark. This section is specific to receiving new procurement at a Distribution Center when the materiel being received is not on a pallet.

Figure 1 is a sample of the IPPC mark. This is a sample provided by Timber Products who is one of ALSC’s auditing agencies used within the United States. Note that IPPC stamp format is changing. Both old and new formats are below. Other approved stamps may be found at:

http://www.alsc.org/greenbook%20collection/WPM_Facsimile.pdf

OLD STAMP TRADE MARK IS STILL ACCEPTABLE

Figure 1

NEW STAMP TRADE MARK

Figure 2

If during receipt inspection of New Procurement items entering a DLA Distribution Center, it is found that Wood Packaging Material (other than pallets), does not have the IPPC markings, perform the following steps:

1. Determine the cost to remediate. Decide if the cost is under the threshold or over the threshold. Thresholds are in Table 1.

THRESHOLD TABLE

Table 1

2. If cost to remediate is Under the Threshold:

a) Materiel should not be put in Condition Code “L”, but should remain in original c/c.

b) Send informational Supply Discrepancy Report (SDR) to ICP, with Action Code ‘1B - Materiel Being Retained’, Discrepancy Code ‘P215’, and include estimated cost to remediate in Comments field: Depot will remediate WPM. Cost is $ --- (Fill in cost estimate.) The service RICs for SDR’s can be found at the attached website:

https://ddcnet.ddc.dla.mil/LogisticsOperations/sdr_mailing_addresses.asp

c) Remediate the WPM. Available options are to build new WPM with heat treated wood or to remediate WPM through Heat Chamber if available.

d) IPPC markings shall be applied in a visible location on at least two sides of the wood packaging product. All dunnage used in configuring and/or securing the load shall also have IPPC marking applied to opposite surfaces of each piece.

3. If Cost to Remediate is Over the Threshold

a) Materiel shall be suspended in Condition Code ‘L’

b) Send Supply Discrepancy Report (SDR) to ICP, with Action Code ‘1A’ – Disposition Instructions Requested, and Discrepancy Code ‘P215’. Cost is $ ------ (Fill in cost to estimate)

c) Await disposition from the ICP to remediate WPM.

d) If disposition is to remediate the WPM, available options are to build new WPM with heat treated wood or to remediate WPM through Heat Chamber if available.

e) IPPC markings shall be applied in a visible location on at least two sides of the wood packaging product. All dunnage used in configuring and/or securing the load shall also have IPPC marking applied to opposite surfaces of each piece.

f) Assign original Condition Code to materiel when remediation is complete.

g) If your depot receives multiple truck loads of non-compliant WPM on one contract order/NSN, immediately contact your depot WPM POC. The depot POC will immediately contact the DDC WPM Coordinator, who will work with the ICP to prevent further non-compliant shipments.

4. Reimbursement for Remediation by the Depot:

1) When in-checking materiel in PPP&M, use of the appropriate Item Manager JON/ION is necessary for billing accuracy. Examples of Item Managers: B16, FLZ, N32, S9_ and SMS.

RECEIVING NEW PROCUREMENT (PALLETS)

Informational only SDR should be completed no matter what the total cost of remediation. The following Pallet remediation Cost Chart can be used to compute the cost of remediation when swapping pallets.

PALLET REMEDIATION COST CHART

Table 2

1. Materiel should not be put in Condition Code “L”, but should remain in original Condition Code

2. Send informational Supply Discrepancy Report (SDR) to ICP, with Action Code ‘1B’ - Materiel Being Retained, Discrepancy Code ‘P215’, and include estimated cost to remediate in Comments field. Cost is $ ---- (Fill in cost estimate.)

3. Remediate the WPM. Available options are to swap pallets to WPM compliant pallets (having IPPC mark), to remediate WPM through Heat Chamber if available, or to build new WPM with heat treated wood.

4. IPPC markings shall be applied to the stringer or block on diagonally opposite sides and ends of WPM and be contrasting and clearly visible. All dunnage used in configuring and/or securing the load shall also have IPPC marking applied to opposite surfaces of each piece.

5. If your depot receives multiple truck loads of non-compliant WPM on one contract order/NSN, immediately contact your depot WPM POC. The depot POC will immediately contact the DDC WPM Coordinator, who will work with the ICP to prevent further non-compliant shipments.

6. Reimbursement for pallet replacement (swapping) falls under Net Landed Cost (NLC) regardless of the replacement cost.

RECEIVING CUSTOMER RETURNS/RETROGRADE

Customer returns/retrograde items received in a Serviceable Condition Code, packaged in or on non-compliant WPM (no IPPC markings), will be REMEDIATED UPON RECEIPT and stamped with the IPPC mark, even if already stamped with the DOD Pest Free stamp.

Customer returns/retrograde received in an Unserviceable Condition Code (E, F, G, H, or S), will be processed as normal without remediation.

SDRs will not be submitted for customer returns/retrograde items.

RETURNS FROM MAINTENANCE

Returns from maintenance received in a Serviceable Condition Code, packaged in or on non-compliant WPM (no IPPC markings), will be REMEDIATED UPON RECEIPT and stamped with the IPPC mark.

Returns from maintenance received in an Unserviceable Condition Code (E, F, G, H, or S) will be processed as normal without remediation.

REDISTRIBUTION ORDERS (RDOs) /STOCK TRANSFER ORDERS (STOs) Redistribution Orders (RDOs)/Stock Transfer Orders (STOs) do not require remediation unless destined to OCONUS sites.

DoD PEST FREE CERTIFICATION MARKING The DoD “Pest Free” mark is accepted by USDA’s Animal and Plant Health Inspection Service (APHIS) and U.S. Customs and Border Patrol (CBP) for imports into Continental United States (CONUS) of retrograde material packaged in WPM. This certification is only to be used for imports into CONUS and when a DDC OCONUS depot is shipping to an IPPC non-participating country.

DoD “Pest Free” Certification marking. Certification and application on the DoD “Pest Free” certification marking is authorized if material successfully passes the established moisture and visual inspection standards. The DoD “Pest Free” certification mark shall display the letters “DoD” the words “Certified Pest Free” and the DoDAAC of the packaging or shipping activity. No extraneous markings are authorized. The size of the stamp should be 2 x 4 inches. The color of the marking ink will be black

DOD PEST FREE STAMP SAMPLE

DoD, W25GIU

) USA DoD

Figure 3

SHIPMENTS TO NON-PARTICIPATING COUNTRIES MAY USE MOISTURE METER TESTING AND DOD PEST FREE STAMP WPM Shipments destined to Non-participating countries (countries that have not adopted ISPM 15) can be processed using DoD Pest Free compliance procedures, which include Moisture Meter testing and use of the DoD Pest Free stamp. A list of Participating countries can be found at:

http://www.aphis.usda.gov/import_export/plants/plant_exports/wpm/country/index.shtml This list will change as countries adopt the IPPC requirements, and must be periodically checked. Countries not found on the list are considered non-participating, and shipments to those countries may be certified using the DoD Pest Free procedure.

Moisture meter testing

1. Determine the moisture content of the wood by using a moisture meter. There are two types of electric moisture meters, pin-type or non pin-type.

2. Moisture meters can be purchased from several manufacturers, along with calibration availability. It is each depot’s responsibility to purchase Moisture Meters.

3. For pin-type moisture meters, pin or needle like electrodes are driven into the wood. The electric resistance or conductance between the pins (electrodes) is measured and converted to moisture content reading.

4. For non-pin-type moisture meters, electric meter uses a sensor plate that does not physically penetrate the wood. The sensor plate is held in intimate contact with the wood surface and an electric field is projected into the wood. An electrical property such as the dielectric constant of power loss factor is measured and converted to a moisture meter reading.

5. WPM Moisture meter reading content must be less than 20%, verifying there is no evidence of insect infestation.

6. Conduct a visual inspection for bore holes greater than 3mm and bark-free.

7. If WPM passes the test, DoD Pest Free stamp shall be applied. (Figure 3)

8. If WPM fails the test, it must be remediated and IPPC stamp applied.

DoD, ) DOD PEST FREE STAMP SAMPLE

USA DoD

W25GIU

Figure 3 IMPORTANT: DDC sites must maintain a log when using the DoD self-certification procedures and DoD Pest Free stamps to mark WPM. The monthly report will include moisture meter testing results of WPM that was certified. Monthly reports will be forwarded to DDC WPM Coordinator.

MONTHLY REPORTING OF DOD PEST FREE MARKINGS

Distribution Centers using the DoD “Pest Free” certification will maintain records of certified material by documenting the following information: requisition or transportation control number, item national stock number, moisture reading, visually inspected for boreholes larger then 3mm in diameter and bark free (Yes/No), quantity and type of WPM (e.g. box) marked, inspector’s signature verifying WPM meets DoD requirements and WPM is properly marked, and the date of certification. This information will be reported monthly to DDC Coordinator using approved spreadsheet and maintained at the activity level for verification during on-site audits.

SHIPPING

Shipments shall be treated differently, dependent on whether the final destination is a participating or a non-participating country. Shipments to participating countries require ISPM 15 compliance; shipments to non-participating countries may be shipped using the DoD Pest Free certification process compliance. Participating countries are countries who have adopted ISPM 15 guidelines. A listing of those countries can be found at:

http://www.aphis.usda.gov/import_export/plants/plant_exports/wpm/country/index.shtml This list will change and should be periodically checked.

Shipments to ISPM 15 participating countries

1. Shipments on or in WPM, and destined to ISPM 15 Participating countries must be marked with the IPPC stamp (Figure 1 or 2) to indicate the WPM is compliant to ISPM 15. If the WPM is non-compliant, it must be remediated and stamped before shipping.

2. Available options are to build new WPM with heat treated wood or to remediate WPM through Heat Chamber if available.

3. Pallet remediation also includes the option to ‘swap’ out the non-compliant pallet for one that is compliant and bears the IPPC mark.

4. IPPC markings shall be applied in a visible location on at least two sides of the wood packaging product. If pallet or skid, IPPC markings shall be applied to the stringer or block on diagonally opposite sides and ends of WPM and be contrasting and clearly visible. All dunnage used in configuring and/or securing the load shall also have IPPC marking applied to opposite surface of each piece.

Shipments to non-participating countries Shipments on or in WPM, and destined to non-participating countries shall be certified as compliant using the DoD ‘Pest Free’ compliance process if the WPM is not already stamped as IPPC compliant or DoD Pest Free. If the WPM is not stamped, perform the following steps:

1. Conduct moisture meter test on wood

2. Conduct a visual inspection for bore holes greater than 3 mm and bark-free

3. If WPM passes test, apply DoD Pest Free stamp (Figure 3)

4. If WPM fails test, do one of the following before applying IPPC stamp:

- Build new WPM with heat treated wood

- Remediate through heat chamber if available

- Swap pallet to WPM compliant pallet (having IPPC marking)

5. Depots shipping through a Containerization Consolidation Point (CCP) or Theater Consolidation and Shipping Point (TCSP) shall ensure the WPM is compliant before movement to the CCP or TCSP. (Depot may need to review SURC or DoDAAC to determine destination.)

6. An ISPM 15 compliant shipment may be sent to non-participating countries in lieu of DoD Pest Free compliance, but a DoD Pest Free shipment may not be sent to Participating countries.

7. IPPC markings shall be applied in a visible location on at least two sides of the wood packaging product. If pallet or skid IPPC markings shall be applied to the stringer or block on diagonally opposite sides and ends of WPM and be contrasting and clearly visible. All dunnage used in configuring and/or securing the load shall also have IPPC marking applied to opposite surface of each piece.

IPPC STAMP

OLD STAMP TRADE MARK STILL ACCEPTABLE

Figure 1

NEW IPPC STAMP TRADE MARK

Figure 2

DOD PEST FREE STAMP

DoD, W25G1U USA DoD

Figure 3 Reimbursement: Remediation at time of shipment is reimbursed through Net Landed Cost.

INTERNATIONAL STANDARD FOR PHYTOSANITARY MEASURE (ISPM 15 CERTIFICATION MARKING

International Standard for Phytosanitary Measure (ISPM) 15 Certification Marking. DOD Components that are self-certified are authorized to use ISPM 15 certification mark on all WPM that fully complies with ISPM 15 guidelines. The ISPM 15 certification marking shall display the letters “US in bold, the packaging activity’s Department of Defense Activity Address Code (DoDAAC), and either “HT” denoting WPM or ‘MB” denoting WPM “fumigated” with Methyl Bromide. The marking “TRADEMARK” represents the logo of the U.S. service that can be displayed under the DoDAAC. The marking ‘DUNNAGE” is used strictly for dunnage, otherwise is left blank.

OCONUS SITES REQUIRED TO UTILIZE IPPC STAMPS FOR COUNTRIES THAT ADOPTED ISPM 15

Site workers who fabricate new or repair WPM with new compliant lumber will apply IPPC markings. IPPC markings shall be applied in a visible location on at least two sides of the wood packaging product. All dunnage used in configuring and or securing the load shall also have IPPC marking applied to opposite surfaces of each piece.

1. Provided are sample pictures of IPPC markings for DDC OCONUS sites that are required to use for OCONUS countries that have adopted ISPM 15.

GERMANY-DDDE- SWE300 KUWAIT-DDKS-SW3109

KOREA-DDDK-SW3105 SIGONELLA, ITALY-DDSI-SW3170

YOKOSUKA- DDYJ-SW3142 GUAM-DDGU-SW3147

2. Provided are sample pictures of DoD PEST FREE stamps for DDC OCONUS sites.

GERMANY

KUWAIT

KOREA

SIGONELLA

YOKOSUKA

GUAM

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USA

DoD, SW3142 image14.emf image1.emf