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potential. If methyl bromide fumigation is removed from the market, the forest industry will 

 lose the single most effective fumigant in controlling insect pests. We are not aware of any 

 alternative treatments or processing methods that are as effective in controlling pests or 

 economically cost-effective. We urge APHIS to communicate the importance and 

 irreplaceability of methyl bromide for treating wood products to EPA. 



APHIS should also accelerate research efforts into finding effective alternatives to 

 methyl bromide. USDA is in an excellent position to ramp-up a substantial research effort in 

 this area in order to find adequate substitutes. APHIS should also seek an expedited review 

 and approval process for registration of new pesticides from EPA. This will require close 

 coordination with EPA as new research into pesticide efficacy and safety will need to occur 

 on parallel tracks. 



5. AF«S:PA is Concerned that Heat Treatment of Certain Logs May Damage Wood Quality. 



AF&PA is concerned that the requirement to heat treat certain logs to destroy 

 associated plant pests could cause damage to the surface wood, which may be the primary 

 reason a particular species of tree or wood product is imported. The specified temperatures at 

 the center of each treated log of at least 56 degrees centigrade for at least 30 minutes may 

 cause damage to the wood and reduce the value of the logs. It appears that these heat 

 treatment criteria are based on standards set for sawn lumber, not for whole logs. APHIS 

 needs to make sure that temperatures are sufficient to be effective in destroying pests, but not 

 to the point of defeating the underlying objective of importing high quality wood materials. 



