100 



7 



sent to other experts (sometimes in other countries) for identification. 



Recently, we have ieamcd that wc cannot rely on morphology (structural 

 appearance) to concctJy identify the organism in many cases. Sometimes we 

 must ase the new DNA technology. All of these steps could easily take six 

 months. Arc the logs, etc. held until APHIS has the results, or are the logs 

 released for manufacture? In my experience, they arc released. 



(4) The primary treatment that APHIS is relying upon is fumigation with methyl 

 bromide. There are several problems with methyl bromide; it is dangerous to 

 use; the EPA plans to ban it entirely within 4-6 years, a fact apparently 

 disregarded by APHIS; its use is adversely alTected by cool temperatures and 

 moisture in green logs; confirmation of proper treatment is difficult; and the 

 recommended treatment schedule does not insure penetration to the center of 

 logs where some of the disease agents can reside. 



(5) The heat treatment, 133 °F for 30 minutes, proposed by APHIS will not kill all 

 disease agents in a log. The people with expertise in this area have 

 recommended to APHIS a treatment that requires about 153 °F al the center of 

 the logs for 60-75 minutes. I had thought that APHIS had accepted the latter 

 treatment. I do not know why the changes unless APHIS has decided that 

 nematodes are the target, and the fimgi are not. 



(6) Lumber, especially larger dimension timbers, could easily harbor disease 

 agents. To exclude it from the fumigation requirements as APHIS has 

 proposed could be very unwise. 



