i



### United States Department of Agriculture Anim al and Plant Health Inspection Service February 201 2 Regulatory Impact Analysis and Analysis in

Support of Certification that the Rule will not have a Significant Economic Impact on a Substantial Number of Small Entities Final Rule APHIS - 2007 - 0 1 17 RIN 0579 - AC90 Importation of Chinese wooden handicrafts

Policy & Program Development Policy Analysis & Developmenti



### Summary This rule will allow for the resumption of imports of wooden handicrafts from China, as long as treatment requirements are met. Importation of these products from China was discontinued in April 2005 because of the risk of introduction of invasive wood
- boring insects. The prescribed heat, heat with moisture reduction , and methyl bromide fumigation treatment options contained in the rule will sufficiently mitigate these pest risks. Protection of U .S. forests against the introduction and spread of invasive pests is vital to the economic well
- being of the forestry industries as well as to maintaining the environmental
and aesthetic benefits that the forests provide to the general public. The hundred s of millions of dollars that have been spent to control the spread of the emerald ash bore r and the Asian longhorned beetle exemplify the enormous cost to the United States when invasive pests become established. This rule will help maintain APHI S safegu ards against further incursions of wood
boring pests such as these, while allowing the importation of wooden handicrafts from China to
resume. Wooden handicrafts comprised a very small fraction of wood products imported from China prior to April 2005, and similar levels of importation are expected following promulgation of this rule. Nonetheless, U.S. consumers of wooden handicrafts will benefit from reestablished access to these products from China. Treatment costs, expected to repre sent on average less than 2 percent of the value of the products shipped, will be borne b y firms in China, and an y fraction of those costs that may

be passed on to U.S. buy ers will be negligible. B enefits of the rule are expected to justify

the costs. Under these circumstances, the Administrator of the Animal and Plant Health Inspection Service has determined that this action will not have a significant economic impact on a substantial number of small entities.ii



### Table of Contents Summary
................................ ................................ ................................ .............................. i Introduction
................................ ................................ ................................ ......................... 1 Benefits of the Rule
................................ ................................ ................................ ............ 2 Costs of the Rule
................................ ................................ ................................ ................. 5 Impacts
................................ ................................ ................................ ................................ 8 Potential Impact on Small Entities
................................ ................................ ...................... 9 References
................................ ................................ ................................ ......................... 111



### Introduction This analy sis examines the economic impacts of a rule that will allow resumption of imports of Chinese wooden handicrafts into the United States . The rule will amend the subpart found at 7 CFR 319.40
. Between 2002 and 2005, APHI S issued more than 300 Emergency Action Notifications for these products. A national recall of wooden handicrafts imported from China found articles infested with such high
- risk pests as Callidiellum villosulum (brown f ir longhorn beetle) and Callidiellum rufipenne (Japanese cedar longhorn beetle). Effective April 1, 2005, APHI S responded to this increased pest risk by suspending importation of Chinese
- origin handicraft items made from wooden logs, limbs, branches or tw ig s greater than 1 centimeter in diameter and with intact bark, pending further analy sis of the risks they pose. In September 2005, the Agency

began requiring mandatory treatment of bamboo poles and garden stakes from China as a precautionary

measure due to interceptions of multiple quarantine pests, including Chlorophorus annularis (tiger longhorned beetle) and Niphoma spp. Following these actions, APHI S conducted risk management anal ys es to identify the phy tosanitary measures necessary

to mitigate both i nternal and external arthropod pests of concern for all categories of wooden handicrafts from China. Based on evidence from the pest risk assessment, the Agency has determined that these articles can be safely imported from China, provided certain conditi ons are met. This rule will amend the regulations to allow the importation of wooden handicrafts from China when they have met prescribed phy tosanitary conditions. 1 Phy

tosanitary treatment options will differ depending on the diameter of the regulated ar

ticle.

1 These items include carving s, bas kets, boxes, bird houses , garden and lawn/patio furniture [rustic], potpourri, artificial trees [typically Ficus spp.], trellis tow ers, garden fencing and edging, and other items composed of wood.2

B enefits and costs of the rule are examined in accordance with Executive Order s 12866 and 13563, which direct agencies to assess all costs and benefits of available regulatory alternatives and, if regulation is necessary , to select regulatory approaches that maximize net benefits (including potential economic, environmental, public health and safety e ffects, and equity). Executive Order 13563 emphasizes the importance of quantifying both costs and benefits, of reducing costs, of harmonizing rules, and of promoting flexibility. T he benefits of the rule are expected to justify the costs overall . Possi ble impacts on small entities are considered in accordance with the Regulatory Flexibility

Act. 

### Benefits of the R ule T his rule will remove the prohibition on Chinese wooden handicrafts and allow importation of these products to resume with pest
- risk mitig ations in place
. The benefits of this rule for US consumers derive from the resumption of wooden handicrafts imports from China. The mitigations contained in this rule will allow the importation of these products while still provid ing protection against the introduction of invasive pests
. . Because of the danger of invasive pests, U
. S
. consumers cannot currentl y i mport wooden handicrafts from China. This rule will allow for the resumption of that trade. While APHI S cannot precisel y estimate the volume of trade that occurred in this category before the ban was in place, Customs and Borders Protection (CBP) data implies that it was very small (see discussion in the Impacts section below). Nevertheless, the adoption of this rule will allow this international trade to resume. There is currentl y no invasive
- species danger to U.S. forests from these products because their importation is banned. The rule would allow for the safe resumption of trade in these products. While the mitigations will have associated costs , the economic damage from the spread of these pests could be extensive. U.S. forest products industries are among the Nation’s3

leading manufacturers. 2 They include loggers, sawmills, and manufacturers of wood products including furniture, pulp, paper and paperboard. The industries are estimated to have annual direct economic impacts of about $293 billion, 3 and directly employ more than 1.2 million people. Man y other jobs depend on forest
- related activities, such as hunting, hiking, fishing, and the prod uction and sale of alternative forest products. Forests also play an important role by providing scenic beauty

and wildlife habitat. Protection of U.S. forests against the introduction and spread of invasive pests is vital to the economic well
- being of the forestry industries as well as to maint aining the envir onmental and aesthetic benefits that the forests provide to the general public. The potential destructiveness and economic impact of invasive wood
- boring insects are exemplified by

the A genc y’ s exp erience with the Asian longhorned beetle (ALB) and the emerald ash borer (EAB)

. ALB attack s trees with significant commercial value, killing the host or predispos ing it to destruction by other organisms . Infected areas lose aesthetic and property values , as large infested trees are replaced b y young and less desirable ALB
- resistant trees
. Eradication efforts in New York and Illinois have resulted in the destruction and removal of thousands of trees . T he A gency has spent more than $300 million on eradicati on efforts and tree replacement
. A 2002 study by Nowak et al., based on the New York and Illinois experience s ,

2 Forest product industries are classified in the North American Industry Classification System under the forestry and logging (NAICS subsector 113), wood product manufacturing (NAICS subsector 321), paper manufacturing (NAICS subsector 322), and furniture and related product manufacturing (NAICS subsector 337). 3 Susana Laaksoman
- Craig, George E. Goldman, and William McKillop, Forestry, Forest Industry, and Forest Products Consumption in California, publication 8070, University of California Division of Agriculture and Natural Resources, 2003 ( http://ucanr.org/freepubs/docs/8070.pdf ). The total is extrapolated by dividing the California im pact by California’s proportion of the Nation’s forest land use (=$15.2 billion/0.0519; California share is from http://www.ers.usda.gov/Data/MajorLandUses/). The estimate would be much larger if the indirect impacts of all support industries were included; for California, the total impacts (direct and indirect) w ere e stimated to be $28.5 billion.4

estimated that the potential national urban impact of ALB c ould reach a loss of 34.9 percent of total canop y cover, with 30.3 percent tree mortality and a value loss of $669 billion. 4 Similarly , the emerald ash borer is a destructive wood
- boring insect that attacks ash trees ( Fraxinus spp., including green ash, white ash, black ash, and several horticultural varieties of ash)
. Th is des tructive pest has alread y killed more than 20 million ash trees since it was discovered in Michigan in the summer of 2002
. 5 T he mortality rate for infested trees is 100 percent
. If EAB spreads from infested areas to the surrounding forests of the northea stern United States, where nursery , landscaping, and timber industries and forest
- based recreation and tourism industries play

vital economic role s , its impact would be severe
. The pest has the potential to destroy entire stands of ash, and any incursion of the pest can result in substantial losses to forest
ecos ys tems, urban trees, and the timber industry . Sydnor et al. estimate total potential losses from this pest in one State ( Ohio ) during one y ear (2006) , including ash landscape losses, tree removal and replacements, to be between $1.8 billion and $7.6 billion. 6 The United States is susceptible to establishment of numerous other pests found in China because the climatic zones of the two countries are similar. The brown fir longhorned beetle, Callidi ellum villosulum, and the Japanese cedar longhorned beetle, Callidiellum rufipenne, which are both related to ALB , are destructive of many tree species found in U.S. forests. Their hosts include cedar, cy

press, pine, redwood, and other conifers. Risks ext end beyond the forestry sector. For example, the host range of the tiger longhorned beetle, Chlorophorus annularis, includes apple, citrus, pear, and plum, commodities

4 David J. Nowak, Daniel E. Crane and John F. Dwyer, “Compensatory Value of Urban Trees in the United States.” Journal of Arboriculture, Vol. 28, (July 2002): 194
- 199. 5 www.ca.uky.edu/AGC/NEWS/2006/Dec/ashborer.htm 6 T. Davis Sydnor, Mathew Bumgardner, and Andrew Todd, “ The potential economic impacts of emerald ash borer (Agrilus planipennis) on Ohio, U.S., communities .” Arboriculture and Urban Forestry, Vol. 33 (January 2007):48
- 54
.5

that earned U.S. producers combined cash receipts of over $6 billion in 2009. This ty p e of pest causes reduced yi elds, reduced commodity value, and the potential loss of both domestic and international markets. The U.S. wood and wood products manufacturing industries yi eld more than $2 85 billion in shipment s annually
. D irect and indirect economic contributions of the industries are substantial in many S tates. For some S tate s, forestry is the largest agricultural industry in terms of jobs and wages and a major source of local economic activity
. Forest product industries in five States, Ca lifornia, 7 Georgia, 8 Florida, 9 North Carolina, 10 and Wisconsin, 11 earned over $ 86 billion and employed more than 410,000 workers between the ye ars 2003 and 2007
. These five States have about 16 percent of the Nation’s forest lands. In addition to products that are made from wood, a wide variety of non
- timber products such as maple s yrup come from U.S. forests. Forest
- related recreation and tourism also make significant contributions to the econom y. This rule will help protect U.S. forests and forest
- depen dent industries from invasive wood
- boring pests, while allowing the resumption of imports of wooden handicrafts from China. 

### Costs of the Rule The cost of meeting the regulatory requirements of this rule will be borne by Chinese manufacturers and exporter s before the products are exported to the United States. The treatment options include heat treatment; heat treatment with moisture reduction ; or, for articles

7 Susana Laaksonan
- Craig, George E. Goldman, and William McKillop, Forestry, Forest Industry, and Forest Products Consumption in California, Publication 8070, University of Cal ifornia Division of agriculture and Natural resources, 2003 (gttp://ucanr.org/freepubs/docs/8070.pdf). 8 Georgia Forestry Commission, State of the Forest: A Report on Georgia Forests 2007 ( http://www.gfagrow.org/PDF/07%20state%20of%20forest.pdf ) 9 Alan W. Hodges, W David Mulkey, Janaki R. Alvalapti, and Douglas R. Carter, Economic Impacts of the Forest Industry in Florida, 2003, Publication #FE538 (http://edis.ifas.edu/FE538) 10 North Carolina Forest Association, Economic Slowdown Impacts Forest Landowners ( http://www.ncforestry.org/WEBPAGES/PRODUCTS/1FORESTPRODUCTS1.pdf ) 11 Center for technology Transfer, Inc,, Wisconsin’s Forest products Industry: Business Climate Status Report 2004. ( http://www.cleantechpartners.org/uploads/images/pdf/BusinessClimateStatusR ptRevised.pdf

).6

with a diameter of less than 6 inches, fumigation with methyl bromide ( treatment schedule T404
- d)
. Reportedly , heat treatment with moisture reduction tends to be somewhat more expensive than other treatment options . The cost of meth ylbromide fumigation may be as high per treatment , but fumigation does not have the considerable capital expenditur e associated with installing a heat treatment sy stem. The cost for fumigation services depends on a number of factors including distance from the nearest service center, volume, frequency and services requested. Heating costs also vary by t ype of wood. Heat treatment procedures may employ steam, hot water, kilns, exposure to microwave energy , or an y other method that raises the temperature of the center of each treated regulated article to at least 60 o C (1 4 0o F) for at lea s t 60 minutes. Cost estimates are given for meth ylbromide fumigation, heat treatment, and heat treatment with moisture reduction in table 1 . Because the temperature and the duration of treatment required b y this rule are greater than the International Standard for Phy tosanitary Measures (I SPM 15) requirements, the heat treatment costs could be slightly higher than those reported below.7

Table 1
. Comparison of Treatment Costs
Treatment Method Documented Costs

(Dollars per 1,000 board feet) Documented Costs Adjusted to 2010 Dollars ( Dollars per 1,000 board feet) Adjusted Cost s per 40
- foot Container Unit (Dollars per Container) Softwood Hardwood Softwood Hardwood Softwood Hardwood Heat Treatment (HT) 8 5
- 15 5 10 0
- 20 0 1 18
- 215 139
- 280 299
- 544 ( 422 ) 352
- 708

(5 3 0 ) Steam treatment (ST) 3 5
- 6 0 41
- 77 49
- 83 57
- 107 124
- 210 ( 167 ) 144
- 271

( 2 08 ) HT with moisture reduction - - - - - - - - 42 3
- 75 5 (5 89 ) 49 6
- 9 7 9

(7 3 8 ) Methyl Bromide 17 7
- 50 6 21 8
- 6 23 21 8
- 6 23 (4 21 ) Note: The first two columns for HT and ST are lumber treatment costs in 1996 ; methyl bromide treatment cost s are for fumigating a 40
- foot equivalent unit in 2001. Inflation adjustments to 2010 are made using the consumer price index. The numbers in parentheses are the corresponding averages. Source: Chaille Brindley, Fumi gation 101: The Other Treatment Alternative ( http://www.palletenterprise.com/pests/fumigation101.asp ); U.S. EPA, Heat treatments to Control Pests on Imported Tim ber, Methyl Bromide Alte rnative Case Study, Part of EPA 430
- R
- 96
- 021, 10 Case Studies, Volume 2 December 1996 ( http://mbao.org/heatlog2.html ) ; CPI index. ( http://www.bls.gov/cpi/cpid1105.pdf ); conversion of the cost per 1,000 bd ft to 4 0
- foot equivalent unit (FEU) assumes 8 tons or 7.26 MT per 1,000 board feet (http://www.arnatural.org/News/Timber_Report/Converting_Weight_Board_Feet.pdf). FEU maximum capacity rang es between 20.4 MT and 26.7 MT. How ever, actual loads are far lower than the maximum weight s, either because of limits e nforced by governments to protect roads and bridges and/or to allow space for equipment handling products in and out of the container. In general , the actual load is 85 and 90 percent of the maximum capacity. We use 18. 4 MT (=0.9*20.4 MT). http://www.alken
- murry.com/OceanContainer.pdf ; http://www.fas.usda.gov/ffpd/export_Guidebook/appndix9.pdf. In round figures (and 2010 dollars), we estimate that the cost of f umigation services range s between $2 20 and $6 2 0 per 40
- foot equivalent unit. 12 The cost of steam heat treatment per 40
- foot container ranges between $12 0 and $21 0 for softwood treatment and between $14 0 and $27 0 for hardwood treatment. Heat treatment costs range between $ 300 and $54 0 for heating soft wood and between $35 0 and $7 1 0 for heating hardwoods. Finally , heat treatment with moisture reduction costs range between $42 0 and $7 60 for softwood treatment and between $ 500 and $9 80 for hardwo od treatment. 13

12 Chaille Brindley, Fumigation 101: The Other Treatment Alternative ( http://www.palletenterprise.com/pests/fumigation101.asp ). According to another report the cost of fumigating wood packaging material ranges between $300

- $450 per 40

- foot equivalent container unit (http://www.wmma.org/cuttingedge/July09/index.html) 13 U.S. EPA, Heat treatments to Control Pests on Imported Timber, Methyl Bromide Alternative Case Study, Part of EPA 430
- R
- 96
- 021, 10 Case Studies, Volume 2 December 1996 ( http://mbao.org/heatlog2.html ). These values are8



### Impacts Because of man y interceptions of wood
- boring beetles, importation of most wooden handicrafts from China was suspended in April 2005, until a thorough evaluation of the pest risks associated with those articles could be conducted. The impact of the suspension has been minor in terms of the total value of wood product imports from China
. The vast majority

of w ooden handicrafts are thought to be contained within the Harmonized Sy stem (HS) commodity categories that includ e the subcategories HS 6404 (foliage, branches, grasses, mosses, etc.), HS 1401 (vegetable materials used primarily for plaiting), HS 4404 (hoopwood; split poles, piles, pickets and stakes of wood), HS 4419 (tableware and kitchenware of wood), HS 4420 (wood marq uetry and inlaid wood; cases, etc.), HS 4421 (articles of wood, not elsewhere specified or indicated), HS 4602 (basketwork, wickerwork, and other articles made from plaiting), HS 6702 (artificial flowers , foliage and fruit), and HS 9505 (festive, carnival, and other entertainment articles, including Christmas ornaments). In 2004, the last year that wooden handicrafts from China could be imported into the United States, imports of the relevant HS commodity catego ries were value d at a total of $ 2.95 b illion
. Inparticular, imports in the categories covering Christmas and other festive articles were valued at $1.758 billion
. However, the suspended Chinese wooden handicrafts comprise only a very small portion of even these narrow import categories . In the ye ars following establishment of the ban, the values of these import cate gories were virtuall y unchanged
. From 2005 through 2010 , imports in the relevant HS categories had an average annual value of $ 2.9 9 billion, or about $ 40 million ( 1 obtained using the following steps. First we adjust for inflation betw een 1996 and 2010 using the CPI index. ( http://www.bls.gov/cpi/cpid1105.pdf ). Then to convert the cost per 1,000 bd ft to 40
- foot equivalent unit, we use the 1,000 board feet to tons value of 8 tons or 7.26 MT ( http://www.arnatural.o rg/News/Timber_Report/Converting_Weight_Board_Feet.pdf ). We assume that each forty
foot container can carry 18.4 MT of wooden handicrafts. Multiplying the adjusted cost of heating 1,000 board feet by the ratio of 18.4/7.26 we obtain the cost of heating 18. 4 MT.9

percent ) more than their value in 2004
. Imports in the categories covering Christmas and other festive articles had an average annual import value of $1.756 billion from 2005 through 2010, a value that was less than $2 million smaller than the 2004 aggregate lev el
. (See a ppendix t able 1
. ) T he cost of heat treatment or fumigation of these articles is expected to be small in comparison to the value of the wooden handicrafts shipped , and should therefore have little effect on the volume of imports once the ban is lifted
. In2010, Chinese imports arriving b y ship had an average value of about $ 62 ,00 0 per 40
- foot container equivalent. 14 Treatment costs ranging from $12 0 to $9 80 per 40
- foot container would represent between 0.2 percent and 1.6 percent of that value. The scale of resum ed imports will also depend on the ability of the Chinese to certify

that treatment has occurred. China already has in place the heat treatment and fumigation facilities that will be needed, due to the required treatment of wooden packing material shipped internationally
. 

### Potential Impact on Small Entities The Regulatory

Flexibility

Act requires that agencies consider the economic impact of rule changes on small businesses, organizations, and government jurisdic tions. This analy sis provides a factual basis for certification by the Administrator of the Animal and Plant Health Inspection Service that the rule will not have a significant economic impact on a substantial number of small entities. There were no sign ificant issues raised during the comment period in response to the initial regulatory flexibility

anal ys is. The Small Business Administration has established guidelines for determining the number of firms considered small under the Regulatory Flexibility

A ct. E ntities engaged in

14 U.S. Waterborne Foreign Trade by Trading Partners, and U.S. Waterborne Foreign Container Trade by Trading Partners. U.S. Department of Commerce, Maritime Administration.10

logging, wood product manufacturing, wooden furniture manufacturing, and importing of the regulated articles are considered small if they employ 500 or fewer workers, and the small
- entity standard for pulp, paper, and paperboard mi lls is 750 employ ees (see table 4). 15 , 16 In2007, there were 45,366 establishments engaged in wood and wood product manufacturing, of which onl y 233 establishments (about 5 percent) could be considered to be large. 17 The 233 large establishments had average annual receipts of $626 million, while the 45,133 small establishments had average annual receipt s of $3 million. It is unlikel y that these establishments, large or small, will be significantl y affected b y this rule. As stated above, the treatment costs range o n average between $12 0 and $9 80 . This range of treatment costs should rep resent less than 2 percent of the value of cargo transported on average . Treatment costs will be directly borne by the manufacturer or exporter in China. Even if a portion o f this cost is passed on to the U.S. importer, an y effects will be very minor. Under these circumstances, the Administrator of the Animal and Plant Health Inspection Service has determined that this action will not have a significant economic impact on a substantial number of small entities.

15 U.S. Census Bureau, 2007 economic census, Manufacturing
- Subject Series 16 U.S. Small Business Administration, Table of Small Business Size Standards ( http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf ) . 17 Code 321 is made up of: Sawmills (321113); Wood Preservation (321114); Hardwood Veneer and Plywood Manufactur ing (321211); Softwood Veneer and Plywood Manufacturing (321212); Engineered Wood Member (except Truss) Manufacturing (321213); Truss Manufacturing (321214); Reconstituted Wood Product Manufacturing (321219); Wood Window and Door Manufacturing (321911); C ut Stock, Resawing Lumber, and Planing (321912); Other Millwork (including Flooring) (321918); Wood Container and Pallet Manufacturing (321920); Manufactured Home (Mobile Home) Manufacturing (321991); Prefabricated Wood Building Manufacturing (321992); All Other Miscellaneous Wood Product Manufacturing (321999 ).11



### References Brindley, Chaille, Fumigation 101: The Other Treatment Alternative ( http://www.palletenter

prise.com/pests/fumigation101.asp ) Center for technology Transfer, Inc, Wisconsin’s Forest products Industry: Business Climate Status Report 2004. (http://www.cleantechpartners.org/uploads/images/pdf/BusinessClimateStatusRptRevised.pdf). CPI index. (htt

p://www.bls.gov/cpi/cpid1012.pdf). Georgia Forestry Commission, State of the Forest: A Report on Georgia Forests 2007 (http://www.gfagrow.org/PDF/07%20state%20of%20forest.pdf) Hodges, Alan W., W David Mulkey, Janaki R. Alvalapti, and Douglas R. Carter, Economic Impacts of the Forest Industry in Florida, 2003, Publication #FE538 (http://edis.ifas.edu/FE538) North Carolina Forest Association, Economic Slowdown Impacts Forest Landowners ( http://www.ncforestry.org/WEBPAGES/PRODUCTS/1FORESTPRODUCTS1.pdf ) Jabara, Cathy, Mary Burfisher, and David Ingersoll, “Wood Packaging SPS Regulation: Effects on U.S. Imports and Containerized Trade,” 2007, pp.1
- 23. ( http://aede.osu.edu/programs/anderson/trade/59Jabara.pdf ) Laaksoman
- Craig, Susana, George E. Goldman, and William McKillop, Forestry, Forest Industry, and Forest Products Consumption in California, publication 8 070, University of California Division of Agriculture and Natural Resources, 2003 ( http://ucanr.org/freepubs/docs/8070.pdf ). Novak, David J., Daniel E. Crane and John F. Dwyer, “Compensatory Value of Urban Trees in the United States.” Journal of Arboriculture, Vol. 28, (July 2002): 194
- 199. www.ca.uky.edu/AGC/NEWS/2006/Dec/ashborer.htm Sydnor, T. Davis, Mathew Bumgardner, and Andrew Todd, “T he potential economic impacts of emerald ash borer (Agrilus planipennis) on Ohio, U.S., communities.” Arboriculture and Urban Forestry, Vol. 33 (January 2007):48
- 54. UN/FAO, Yearbook of Forest Products, Rome, 2010 (http://www.fao.org/docrep/012/i1521m/i1521m00.htm) U.S. Census Bureau, 2007 Economic Census, Statistics of U.S. Businesses ( http://www.census.gov/econ/susb/index.html ) U.S. Census Bureau, 2007 Economic Census, Sector 31: EC0731SG3: Manufacturing: Summary Series: General Summary: Industry S tatistics for Subsectors and Industries by Employment Size: 2007, released 11/16/2010. U.S. EPA, Heat treatments to Control Pests on Imported Timber, Methyl Bromide Alternative Case Study, Part of EPA 430
- R
- 96
- 021, 10 Case Studies, Volume 2 December 1996 ( http://mbao.org/heatlog2.html ) U.S. Small Business Administration, Table of Small Business Size Standards (http://www.sba.gov/sites/default/files/Size_Standards_Table.pdf)
. World Trade Atlas, 2000
- 2010 Globa l Trade Information Services, Inc., January 2011. http://www.gtis.com/gta/secure/gateway.cfm WTO, International Trade Statistics 2010, http://www. wto.org/english/res_e/statis_e/its2010_e/its10_world_trade_dev_e.htm