124 



AF&PA also questions the requirement to shrink-wrap wood articles to prevent them 

 from being reinfested with pests following heat treatment. Our members' experience indicates 

 that the likelihood of reinfection after treatment is extremely low. APHIS should focus on 

 more cost-effective treatments or handling procedures. 



6. AF&PA Requests that the Proposed Rule Include Irradiation in the Universal Importation 

 Option for Logs. 



APHIS should include the option of irradiation technology to sterilize log imports by 

 U.S. wood producers in this proposed rulemaking. AF&PA believes that this existing 

 technology could offer real advantages given the uncertain future for methyl bromide use and 

 concerns over effects of heat treatment on wood quality. 



The forest products industry is generally exploring the potential of irradiation as a 

 treatment option. Preliminary assessments have concluded that the irradiation technique lends 

 itself to both whole log processing and large volume treatment. It also shows promise as 

 being a viable, cost-effective mitigation method when compared to dry kiln or heat treatment. 



Given the uncertainty of the future availability of methyl bromide, irradiation research 

 and the search for substitutes generally should receive priority within APHIS. In conjunction 

 with the timber supply crisis in the Pacific Northwest, the need is even more apparent and 



