Imported Wood Regulation

Current pest risk analyses have addressed surface or shallow wood pests.  However, there is concern over a potential deficiency in the current imported wood regulations with regard to railroad ties, temperate hardwood logs, wood chips, bark chips, humus, and similar materials.  Experience with the currently regulated commodities to date indicates that the current regulations do not completely address the potential risks associated with these materials.  Specifically, evidence that  pathogenic fungi and live insects have been imported on railroad ties, that fumigation does not always control deep wood insects or fungi, and recent experiences with Asian longhorned beetle and citrus longhorned beetle demonstrate that insects that bore deep into wood still pose a serious threat.  It was determined by the Oregon Department of Agriculture that live fungi, including pathogenic species, have been found in imported fumigated wood and inside fumigated bark.

NASDA urges USDA-APHIS-PPQ to conduct additional pest risk analyses and revise the wood regulations to mitigate pathways for introduction of potential deep wood pests and diseases through imported wood products.