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Chief Regulatory Analysis and Development 

 April 19, 1994 

 Page 2 



In reviewing items continued in this Docket, I found that I had 

 addressed virtually every one of them before, the latest version is the 

 January 5, 1994, memo regarding Docket No. 91-074-5. Accordingly, 

 I am attaching a copy of that memo with this one for inclusion in the 

 pubUc record for the present Docket No. 91-074-3. 



I find it curious that the Revised Test Shipment Protocol produced 

 and dated March 26, 1992, and presented to the Forest Service has 

 not only been ignored by APHIS, but modified in ways not even 

 explained. Namely, that (1) all treatments be done at point of orig in 

 not 60 days after arrival in the U.S., (2) fill in missing information on 

 thermed death points on some organisms at point of origin . (3) heat 

 treatment should be 71.1°C (160°F) for 75 minutes (not 56°C for 30 

 minutes as recommended in Docket No. 91-074-3) and that this heat 

 treatment was to be applied at point of origin ! Statements about 

 methyl bromides are also strange—especially so since the publication 

 of Cross of New Zealand (1991) stated that only 100 mm penetration 

 occurred on logs and concluded it was an ineffective way to solve the 

 problem. What about pests deeper that 100 mm? 



There have been repeated inquiries regarding the proper treatment of 

 wood chips and how effective methyl bromide is on such material. 

 One shipper of chips informed me that there was very little diffusion 

 in wood chips because of compaction. Where is the scientific 

 documentation on fumigating wood chips? One individual suggested 

 shipping pulp rather that chips might be effective (Some of this is 

 already happening). 



I would hke to close by citing a very recent example of the 

 consequences of your "Interim Ruling on New Zealand Logs." The 

 shipment came into Coos Bay, Oregon (Gazette-Times, Thursday, 

 March 24, 1994). According to the report, the shipment was radiata 

 pine, about 3.3 million board feet (represented by about 26,000 logs). 

 These logs had been debarked, treated with several fungicides and 

 severed insecticides and fumigated with methyl bromide. The 

 accounts in the paper did not mention that 110 red cedar logs also 

 were included in the shipment and Usted on the manifest. According 

 to the interim regiilations, the radiata logs are to be heat treated 

 within 60 days of arrival. Because of other regulations unfamiliar to 

 me, the red cedar logs were to have been heat treated at point of 

 origin, but had not been so treated prior to their arrival in Coos Bay. 

 They were placed in quarantine at the harbor. 



