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(5) It is released from wood slowly so that ship workers, longshoremen, and wood- 

 industiy workers in the U.S. may be exposed to excessive amounts during off-loading and 

 milling. 



Absurdity #5: Certification of compliance of all regulations required by the importation 

 permits will be left up to the brokers or exporters of the logs and timber, not to APHIS or other 

 government inspectors. This self-regulation is called for in spite of the fact that (1) the timber 

 industry in Siberia is known to be controlled by a "Mafia" of corrupt businessmen; (2) thcic have 

 already been illegal shipments into the U.S. of unpermitted wood articles from New Zealand and 

 Chile; (3) timber shipments from Siberia are frequently sent to the wrong destinations; and (4) 

 American mills arc already known not be complying with existing rules. In the former Soviet 

 republics, black markets, government corruption, and a timber-industry Mafia make any tracking 

 of wood articles impossible. And the only penalty to importers for breaking the rules is loss of 

 import permits for one year, a mere slap on the wrist. 



Absurdity #6: Although certification of compliance of the rules has been left up to the 

 exporters and timber industry, APHIS and state personnel arc expected to monitor the shipments 

 once they are in the U.S. However, governmental inspectors are too few to oversee large 

 numbers of quarantined logs through all steps between ship docking and final heat treatment In 

 Oregon, for example, only one APHIS inspector has been assigned to monitor compliance in 17 

 limiber mills spread over half the state. 



Absurdity #7: The Proposed Rules require tiiat all waste materials be sterilized before 

 discarding, but log importation is an inhercntiy dirty process. Waste is generated at docksidc 

 during unloading, at trucks during loading and unloading, and during milling, Although under 

 quarantine, these procedures give ample opportunities for sawdust, bark and wood chips to 

 esca|>e into the environment Even small bits of sawdust may harbor microscopic pathogenic 

 organisms. In many cases, it is simply not economical for the timber industiy to change from its 

 nonnal procedures and adhere to new sterile techniques. 



Absurdity #8: The State of California and timber exporting countries such as Chile and New 

 Zealand have higher standards of plant protection and pest exclusion than those proposed by 

 APHIS for the United States. In fact, American logs would not be allowed to enter Chile. 

 Recently, imported logs approved by APHIS for entry into the United States and shipment 

 through valuable forests of northern California were stopped by an inspector from the California 

 Department of Food and Agriculture, who found numerous extremely serious pests in the 



