Summary of changes to the Australian Wood Packaging Scheme (AWPCS) - Version 2.1

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1    Introduction

1 Background
There are three main activities involved in the production of approved wood packaging material (including dunnage): treating, manufacturing and marking. These activities can be done by separate entities, or one entity can do several or all of these activities. Under the AWPCS,

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1.5     Definitions
Entity: means any of the following:
a company
a partnership
a person in the capacity of trustee
any other person that is a wood packaging manufacturer and/or treatment provider.

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1.5     Definitions
Treatment date: The date the treatment process, including any curing is completed.

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1.6     Legislative Authority
Note: Compliance with the AWPCS is not to be taken as a guarantee that any particular goods will be granted access to any overseas markets.

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1.10     Exemptions
Note: Articles that are exempt from the ISPM 15 standard are not to carry the ISPM 15 certification mark unless the company applying the ISPM 15 certification mark is certified under the AWPCS.

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1.10    Exemptions

• Veneer peeler core

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2.2     Fumigation with Methyl Bromide
Where fumigation with methyl bromide is the chosen treatment option, all wood packaging material shall be fumigated in accordance with the minimum standard described in Appendix 2 – Requirements for AWPCS Methyl Bromide Fumigation Providers.

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2.2     Fumigation with Methyl Bromide
Table 1. Minimum Methyl Bromide Fumigation Standard 

Temperature	Dosage (g/m3)	Minimum concentration (g/m3) at:
		2hrs	4hrs	12hrs	24hrs
21°C or above	48	36	31	28	24
16°C or above	56	42	36	32	28
10°C or above	64	48	42	36	32

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4.1  Application of the certification mark
Examples
Where various components are integrated into a unit of wood packaging material, the resultant composite unit should be considered as a single unit for marking purposes. On a composite unit of wood packaging material made of both treated wood and processed wood material (where the processed component does not require treatment), it may be appropriate for the mark to appear on the processed wood material components to ensure that the mark is in a visible location and is of a sufficient size. This approach to the application of the ISPM 15 certification mark applies only to composite single units, not to temporary assemblies of wood packaging material.

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4.1     Application of the ISPM 15 certification mark
Examples
• when looking inside a container or anywhere else where pallets are stacked.
• On individual pieces of dunnage it is acceptable for only one mark to be applied.

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Inserted: As treated wood for use as dunnage may not be cut to the final length until loading of a consignment takes place, it is important that exporters ensure that all dunnage used to secure or support a consignment is treated and correctly displays the entire ISPM 15 certification mark.
Note: Small pieces of wood that do not include all the required elements of the ISPM 15 certification mark should not be used for dunnage. It is advised that the ISPM 15 certification mark be applied to pieces of wood intended for use as dunnage along the entire length at very short intervals, (where very small pieces of wood are subsequently cut for use as dunnage, the cuts should be made so that an entire ISPM 15 certification mark is present on each of the individual pieces of dunnage).

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4.2 Security of the certification mark
Note:  Loss of an ISPM 15 certification device is considered a major non-conformity and will result in revocation of the AWPCS.

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4.6 Heat treated and fumigated wood packaging material
4.6.1 The use of fumigated and heat treated wood in the one article is only permitted in the manufacture of newly produced wood packaging material.

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5.5 Auditing of certified facilities
5.5.1 Major and Minor non conformities

Audits that reveal two or more minor nonconformities may result in the certified entity having its certification revoked. Situations involving two or more minor nonconformities will be assessed on a case by case basis prior to revoking certification.

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5.5.2 Major and minor nonconformities
• or more than two minor nonconformities
• one month from the time the corrective action was raised

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5.6 Change in certification under the AWPCS
The certified entity must notify in writing the relevant certification body of changes to the certified entity’s ABN, responsible management personnel or ownership. These major changes may result in cancellation of the certification number and the entity applying for new certification.

Note: It is the responsibility of the certified entity to destroy all ISPM 15 certification marking devises. 

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5.6 Change in certification under the AWPCS
Note: A change to a certified facility’s certification status may also include an extension and or reduction in scope or cancellation or suspension from the AWPCS.

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6. RESPONSIBILITIES OF EACH PARTY
6.1  Australian Quarantine and Inspection Service (AQIS)
AQIS is responsible for:
public relation activities associated with the AWPCS and the ISPM 15 standard.

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6.3  The certification body
The certification body is responsible for:
public relation activities associated with the AWPCS

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7.3.1 Remanufactured wood packaging material
7.3.1  If a unit of wood packaging material has had more than approximately one third of its components replaced, the unit is considered to be remanufactured.

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7.3.1
Re-manufactured wood packaging material must have any previous application of the ISPM 15 certification mark completely removed.  Re-manufactured wood packaging material must be re-treated and the mark must then be applied anew in accordance with the AWPCS. 

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7.2 Remanufactured wood packaging material
Repaired and re-manufactured wood packaging material shall be remarked and all wood shall have been subject to the same treatment (For example, it is not possible to mix components that have been heat treated with components that have been fumigated in the same article of wood packaging material).

If fumigated and heat treated components are to be mixed during the repair and or re-manufacture process, re-treatment of the wood will be necessary.
All other certification marks shall be completely removed.

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9 Production and On-selling of Wood Packaging Kits
The “kits” are sold by participants of the AWPCS.
The wood packaging “kit” does not comprise of additional components.

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1.6.1 Heat treatment dosage
throughout the entire profile of the wood

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Appendix 2: Lists REQUIREMENTS FOR AWPCS METHYL BROMIDE FUMIGATION PROVIDERS

1.6.1 General
These requirements may be additional to those required generally for fumigators conducting Methyl Bromide in Australia, such as safety procedures, notifications, training and licensing.

2.1 Note: It is recommended that measures be taken to reduce or eliminate emissions of methyl bromide to the atmosphere where technically and economically feasible. 

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2.5 Prior to Fumigation
Individual planks, rounds or articles shall have at least one physical dimension which is less than 200mm thick.

bark is removed as per section 4.5

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2.5.1 Prior to Fumigation
all raw wood or wood packaging shall removed

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2.6 Temperature and fumigation dosage rates

2.6.1
Use of methyl bromide should be undertaken taking into account the CPM Recommendation Replacement or reduction of the use of methyl bromide as a phytosanitary measure (2008). NPPOs are encouraged to promote the use of alternative treatments approved in this standard. ¹

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¹ In addition, contracting parties to the IPPC may also have obligations under the Montreal Protocol on Substances that deplete the Ozone Layer.

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The wood packaging material must be fumigated with methyl bromide in accordance with a schedule that achieves the minimum concentration-time product² (CT) over 24 hours at the temperature and final residual concentration specified in Table 1. This CT must be achieved throughout the wood, including at its core, although the concentrations would be measured in the ambient atmosphere. Monitoring of gas concentrations must be carried out at a minimum at 2, 4, 12 and 24 hours (in the case of longer exposure times and weaker concentrations, additional measurement should be recorded at the end of fumigation).

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Table 1: Minimum CT over 24 hours for wood packaging material fumigated with methyl bromide  

Temperature	CT (g∙h/m3) over 24 h	Minimum final concentration (g/m3) after 24 h
21 °C or above	650	24
16 °C or above	800	28
10 °C or above	900	32

One example of a treatment schedule that achieves the minimum required CT for wood packaging material treated with methyl bromide (initial doses may need to be higher in conditions of high absorption or leakage) is shown in Table 2.

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2.6.4 When temperatures are below 10°C some form of artificial heating shall be used.

2.6.7 For fumigations carried out overnight

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²  The CT product utilized for methyl bromide treatment in this standard is the sum of the product of the concentration (g/m3) and time (h) over the duration of the treatment.

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2.6.5  Example: The minimum expected temperature for that day is 9°C. The fumigation
treatment provider would use artificial heating to raise the temperate to a minimum of 10°C. Then conduct the fumigation at the minimum concentration which would be 36 g/m³ for 12 continuous hours.

2.6.6  For fumigations carried out overnight, the operator shall determine the average minimum ambient temperature expected for the duration of the treatment.

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2.9      Sheet fumigation
2.9.3 Prior to commencement of any treatment the treatment provider shall ensure:

• a gastight seal exists between the sheets and the floor
• corners where ropes, cords or sampling lines emerge from between or under the sheets are tightly sealed
• loose sheets on corners of stacks are secured
• sheets are positioned to avoid any sharp corners or objects that might damage the sheets
• sheets are arranged so that there is at least 50 cm of sheeting extending beyond the limit of the seal
• chains or timber are not to be used for sealing sheets to the floor.

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2.9 Sheet fumigation
2.9.3 Prior to commencement of any treatment the operator shall ensure:

• a good seal exists between the sheets and the floor
• corners where ropes, cords or sampling lines emerge from between or under the sheets are tightly sealed
• loose sheets on corners of stacks are secured
• sheets are positioned to avoid any sharp corners or objects that might damage the sheets
• sheets are arranged so that there is at least 50 cm of sheeting extending beyond the limit of the seal
• sandsnakes, not chains or timber, are used for sealing sheets to the floor.

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2.14 Measuring and monitoring of fumigant levels
2.14.1 Option 1 – Pressure testing and correct dosage application

No monitoring is required after fumigation has commenced provided:
• the enclosure is pressure tested
• the pressure decay values verify that the container or chamber can be pressurised to 250 Pa
• the correct dosage of fumigant is introduced into the chamber.

Note: The above option is not suitable for sheet fumigation.

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2.15.3 Sheet fumigation

All fumigation sheets shall be:
• free from any defects
• have a permeability of less than 0.02 grams per day per square metre.

2.15.2 Documented evidence of the sheet permeability such as a manufacturer’s
declaration shall be available for all sheets purchased after certification under the AWPCS.

 Prior to commencement of any treatment the treatment provider shall ensure:

• a gastight seal exists between the sheets and the floor
• corners where ropes, cords or sampling lines emerge from between or under the sheets are tightly sealed
• loose sheets on corners of stacks are secured
• sheets are positioned to avoid any sharp corners or objects that might damage the sheets
• sheets are arranged so that there is at least 50 cm of sheeting extending beyond the limit of the seal
• chains or timber are not to be used for sealing sheets to the floor.

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2.16 Treatment certificates
2.16.2
ABN of fumigation provider

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5.5 Minor nonconformities
5.5.1 not exceeding one month from notification.

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5.7 Re-instatement of facilities
On re-certification, when the certification mark/number has changed, the certification body shall provide AQIS with a copy of the company’s new ISPM 15 certification mark as soon as possible following re-certification.

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Appendix 6: Lists and descriptions of major and minor nonconformities
MINOR NONCONFORMITY
Generally more than two minor nonconformities = a major non conformity (situation will be assessed on a case by case basis).