68 



Oregon 



State 



University 



Mr. Jack Edmundson 

 April 26, 1994 

 Page 4 



Alternative 6 - Prohibit Unmanufactured Wood 



This is an excellent proposal and reflects the regulations of Europe, New Zealand, 

 and Chile-no raw logs allowed! But, you weaken this alternative by failing to 

 adequately deal with the question of green dunnage-in itself a simple matter, heat 

 treat it. You have used green dunnage as a red herring. You have failed to propose 

 the obvious Alternative 7 - Prohibit Unmanufactured Wood and deal with green 

 dunnage via adequate heat treatment to Idll the potential pest organisms. Further, 

 you state on page 27 that unreasonable restrictions are placed on the importation of 

 articles that have very Uttle potential for introducing plant pests. Indeed, the 

 prohibition of unmanufactured wood (i.e. logs) means that the treatments resulting 

 in manufacturing removes the threat of importing pests to hving trees— pests 

 virtually certain to occur in raw logs as proposed. Why do you suppose Europe will 

 only accept kiln-dried lumber or why New Zealand and Chile prohibit raw log 

 importations? 



G. Description of Available Treatment Methods 



1. Inspection - already considered. 



2. Debarking - a help but certainly does not eliminate pests nor is the 

 debarking ever complete. 



3. Fumigation - New Zealand (Cross, 1991) has already stated why this 

 is not an effective way to treat logs. Incidentally the paper by Cross 

 was published in 1991 not 1992 and has not appeared in any APHIS 

 document until this DEIS, including both "findings of no-significant 

 impact" on New Zezdand and Chilean reports-published well after 



-the Cross papet" appeared. Schedule T-312 was judged inadequate 



by the US Forest Service Science Team-it was used for oak log 

 fumigation and did not give adequate penetration. Your comments 

 on temperature limitations of such fumigation are quite 

 appropriate. 



Heat treatment - the only really effective means of lolling the pest 

 organisms. This has been discussed in my previous two memos. 

 Your recommendations are too low - weU below the 71°C for 45 

 minutes found in the USPS Siberian protocol. It is clear that a Uttle 

 scientific research is required to vahdate some of these numbers 

 over a broader array of woods and conditions. Far too much 

 extrapolation fi'om a few data points has been done. This 

 recommendation for sound information was made over two years 

 ago but virtually no effort has been made to remedy this void. 



Pesticide and preservative treatments— generally for surface 

 treatment only to prevent reinfestations. Your statement about 

 only compounds not registered in the United States reminded me 

 that a shipment of logs arrived here after having been sprayed with 

 several insecticides and fimgiddes - but foreign trade names had 

 been used making it difBcult or impossible for any individual 

 responsible to be certain the proper compounds had been used. 

 Since these logs had not been properly heat treated before arrival 

 (they were western red cedar), they were ordered to be destroyed by 

 burning. The Oregon Department of Environmental Quality would 

 not issue a permit to do so since burning would send these pesticides 

 into the surrounding air. It was considered a health hazard. 



