78 



ENTOMOLOGY 



Oregon 



State 



University 



Cordley Hall 204« 



Corvallis. Oregon 



97331-2907 



Tclepbooe 

 S03-737-4733 



January 5, 1994 



MEMO TO: Chief Regulatory Analysis and Development 

 PPD, APmS, USDA 

 Room 804, Federal Building 

 6505 Belcrest Road 

 Hyattsville MD 20782 



FROM: John D. Lattin 



Systematic Entomology Laboratory 

 Department of Entomology 

 Oregon State University 

 Cordley Hall 2046 

 CorvaUis OR 97331-2907 



SUBJECT: Comment on Docket No. 91-074-5, Importation of Monterey Pine 



Logs from Chile and Monterey Pine and Douglas-fir Logs from New 

 Zealand 



I am responding to Docket No. 91-074-5 regarding importation of raw logs from 

 Chile and New Zealand. Althou^ this item deals with only a part of the problem of 

 raw log importation, it was encouraging to note that the agency is developmg 

 comprehensive regulations to control plant pest risks presented by the importation 

 of logs, lumber, and other unmanufactured wood from anywhere in the world into 

 the United States. Such regxilations are long overdue. It was my impression that 

 our efforts to draft mitigation protocol for logs completed at the March 1992 

 meeting in Sacramento, California, would have covered much of this if the needed 

 research had been conducted. Almost two years have passed and nothing has been 

 done. 



While it is commendable to develop these interim regulations to have uniform 

 regulations in place as each situation develops, it seems completely unreasonable to 

 allow any raw logs or green lumber to enter the United States until proper 

 procedures are available and in place before any unprocessed wood is allowed to 

 enter. 



The finding of no significant impact in both the December 1992 proposed Interim 

 Rule and the October 1993 Interim Rule for Monterey Pine and Douglas-fir logs is 

 absolutely incredible. The treatments proposed will usi produce pest-free logs. In 

 spite of your statements to the contrary, fumigation by methyl bromide is not 

 effective on organisms 100 mm or deeper in the wood. The 1991 paper by Cross 

 from New Zealand clearly shows this and the paper is not even referenced in either 

 Environmental Assessment. It is ironic that tbig paper was produced by the 

 scientists in the country fitjm which the logs will come! The heat treatments 

 recommended in the March 1992 meeting in Sacramento are simply brushed aside 

 when in fact it is the only method we have to kill all organisms to the center of the 

 logs. Surface fumigation simply will not do that. 



Since some of the insects that live in the center of the logs are very small, it is 

 unlikely that their exit holes will be detected in a shipment of 10,000 logs being 

 inspected. Heat treatment after the arrival of the raw wood is alrin to closing the 

 bam door after the horses have escaped! Especially so since heat treatment of 

 products may be as long as 60 days after arrival into the country. Heat treatment 

 should be appUed at the point of origin of the logs. 



