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MEMO TO: Chief Regulatory Analysis and Development 

 January 5, 1994 

 Page 3 



Besides the usual reviews of the problems of visual inspections (how do you visually 

 inspect a shipment of 10,000 logs? - you don't), emphasis was placed upon 

 furoigation, especially by methyl bromide, and here again, the inadequacy of the 

 APHIS recommendations regarding methyl bromide penetrations into green wood - 

 the application cited being on oak to attempt to control wilt. Penetration was 

 minimal. The 1991 publication by Cross, a New Zealand scientist, clearly outlined 

 the inadequacy of methyl bromide fumigation on green logs since penetration was 

 only achieved to a depth of 100 mm. He stated that it was nal an acceptable 

 effective treatment for their own logs. It is more that a little curious that this New 

 Zealand publication has not even been mentioned in aox of the APHIS pubUcations 

 even though they have known of its existence for several years. Similarly, the 

 document produced at the Sacramento meeting has not been mentioned either. 



Heat treatment of logs received considerable attention at the Sacramento meeting 

 and again, the inadequacy of available information was clearly stated and 

 recommendations made to obtain the necessary knowledge. Further, it was clearly 

 stated that such heat treatments be applied at the point of origin of the logs - not at 

 the port of arrival or later. While it was recognized that not all shippers could 

 accomplish the proper heat treatments at present, no shipments were even 

 considered until they could do so - not ship the logs and do it here. This is a 

 procedure that simply guarantees arrival of pests not removed by the inadequate 

 regulations here proposed, regulations that, in some miraculous fashion, were 

 deemed to result in tiie "Finding Of No Significant Impact" - such a conclusion is 

 absolutely ludicrous. One of the existing policies of APHIS, stated in the Office of 

 Technology Asessment 1993 publication entitled "Harmful Non-Indigenous Species 

 in the United States" is quoted on page 114 "... and its (APHIS) general operations 

 under the presumption that unanalyzed imports will be admitted unless risks are 

 proven..." is precisely the source of the problem here. The conclusions reached are 

 at odds with the facts. It is time to change this out-moded concept. 



dmw 



