# Importation of Wooden

**Handicrafts into the United States** 

**Environmental Februa**  **United States**  **Department of Agriculture**  **Marketing and Regulatory**  **Programs** Animal and Plant Health Inspection Service 

# Importation of Wooden **Handicrafts from**  **China into the United States** 

**Environmental Assessment,**  **Februa ry** **2011** 

# Importation of Wooden

**China into the United States** 

**Assessment,**

# Importation of Wooden

**Handicrafts from**  **China into the United States** 

**Env ironmental**  **As sessment,**  **Febr uary 2011** 

**Ag ency** **Contact:** John T. Jones Forestry Products Trade Director Plant Protection and Quarantine Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Rd. Unit 14 0 Riverdale, MD 20737

________________________________ __________________________ The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’S TARGET Center at (202) 720

– 2600 (voice and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326

–

W, W hitten Building, 1400 Independence Avenue, SW , W ashington, DC 20250

– 9410 or call (202) 720

– 5964 (voice and TDD). USDA is an equal opportunity provider and employer.

________________________________ __________________________ Mention of companies or commercial products in this report does not imply recommendation or endorsement by the U.S. Department of Ag riculture over others not mentioned. USDA neither guarantees nor warrants the standard of any product mentioned. Product names are mentioned solely to report factually on available data and to provide specific information.

________________________________ __________________________ This publication reports research involving pesticides. All uses of pesticides mu st be registered by appropriate State and/or Federal agencies before they can be recommended.

________________________________ __________________________ CAUTION: Pesticides can be injurious to humans, domestic animals, desirabl e plants, and fish or other wildlife

— if they are not handle d or applied properly. Use all pesticides selectively and carefully. Follow recommended practices for the disposal of surplus pesticides and pesticide containers.

## Table of Contents

**I. Purpose and Need for the Proposed A** **ction**

**...................... 1**  **II. Al**  **ternatives**

**................................ ................................**  **.......... 2**  **A. No**  **Ac tion** 

**................................ ................................**  **....... 2**  **B. Proposed A ction** 

**................................ ...........................**  **2 III.**  **Environmental Consequences** 

**................................ ...........**  **3 A.**  **No Ac**  **tion**

**................................ ................................**  **....... 3**  **B. Proposed A ction** 

**................................ ...........................**  **4 C. Cumulative**  **Impacts**

**................................ ......................**  **6 D. Endangered Species A** **ct**

**................................ ..............**  **7 IV.**  **Other Issues**

**................................ ................................**  **......... 8**  **V. Ag**  **encies and Organizations Consulted**

**............................ 9**  **VI. References** 

**................................ ................................**  **......... 10** **1** 

## I. **Purpose and Need for the Proposed Ac**  **tion** Encouraging trade with foreign countries , such as China , is a priority for the United States. However, allowing such trade can also increase the potential for introduction and subsequent establishment of pests of concern if infested articles enter the United States. Chinese wooden handicrafts are an example of a group of products the United States would l ike to be able to import. Chinese wooden handicrafts are generally

comprised of products such as wooden carving s, baskets, boxes, bird houses, rustic garde n and/or l awn/ patio furniture, potpourri, artificial trees (usually artificial Ficus spp.) , trellis towers, garden fencing and edging , and other wood items. Many of these items have been imported into the United States in the past; however, repeated interceptions o f quarantine pests caused concern about the potential introduction of wood

- boring pests into the United States

. Inthe time period from 2002 through 2005, the U.S. Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS) issued more than 300 emergency action notices , and also conducted nationwide recalls to remove Chinese wooden handicraft products from the marketplace in the United States that were discovered to be infested with pests of concer

n . In 2005, APHI S suspended the importation of Chinese wooden handicrafts made from wooden logs, limbs, branches or twigs greater than 1 centimeter in diameter and with intact bark in order to take the time to further assess the pest risks associated with Chinese handicrafts , and to determine the best course of action to reduce the pest risk.
USDA

–APHI S is now proposing to amend regulations in “L ogs, Lumber, and Other Unmanufactured Wood Articles” (7 Code of Federal Regulations (CFR) 319.40) to allow for resumption of the importation of wooden handicrafts from China made from wooden logs, limbs , branches or twigs under certain mitigations

. In addition, the change in regulations will also more clearl y define and clarify the specific ty

pes of articles that are considered to be Chinese wooden handicrafts and that are therefore subject to the new import regulations. Before amending and implementing the new regulations, APHIS must analyze the potential impact s in the United States of the proposed change s to the regulations. This environmental assessment (EA) has been prepared, consistent with USDA

–APHI S' National Environmental Policy Act of 1969 (NEPA) implementing procedures (Title 7 CFR part 372). It examines the potential effects on the quality of the human environment that may be**2** associated with revising import regulations that would allow greater importation of wooden handicrafts from China. 

## II

**. Al**  **ternati ve**  **s** This EA considers the potential effects of the proposed action and its alternatives. Two alternatives are being considered in this EA: (1) no change to the existing regulations (the no action alternative), and (2) amending existing regulations to more clearl y define wh ich products are considered to be Chinese wooden handicrafts , and amending existing regulations to allow for resumption of importation of Chinese wooden handicrafts if certain pest mitigation measures are met (the proposed action)

. 

### A. **No A**  **ction** The no action alternative would result in no changes to the current regulations , and would not change the current suspension of importation that is in place

. Importation of Chinese wooden handicrafts made from wooden logs, limbs, branches or twigs greater than one centimeter in diameter and with intact bark would continue to be prohibited from entry into the United States . This alternative would address the conce rn about introduction of pests of concern into the United States from Chinese wooden handicraft products. However, c hoosing the no action alternative would unnecessarily hinder free trade because effective mitigation measures have been identified to address the risk of introduction of pests of concern as a result of importation of these products. 

### B

**. Proposed**  **A ction**  Under the proposed action, the regulations would be amended to clarify the definition of products that are classified as Chinese wooden handicrafts , to demonstrate that wooden handicrafts fall under the definition of regulated articles within the subpart, and to incorporate the appropriate phy tosanitary measures that are required in order to import Chinese wooden handicrafts into the United States while mitigating the risk of introduction of pests of concern
. T he amended regulations would define the term “wooden handicraft s” as a commercial class of articles derived or made from natural components of wood, twigs, and vines, including bamboo poles and garden stakes. Handicrafts would include the following products where wood is present: C arvings, baskets, boxes, bird house s , garden and lawn/patio furniture (rustic) , potpourri, artificial trees (t ypicall y artificial Ficus spp.), trellis towers, garden fenci ng and edging, and other items composed of wood. The amended regulations would also clarify that products, such as wood en**3** handicrafts, that “contain (wooden) parts that are either unprocessed or have received onl y primary processing and are not feasibl y separable from other parts of the product” are regulated under the subpart. Under th e proposed action , articles with regulated components that are more than 6 inches in diameter will be required to be treated with one of the following treatments:

 Heat treatment , as specified in the PPQ Treatment Manual in accordance with 7 CFR part 305 , or
 Heat treatment with moisture r eduction , as specified in the PPQ Treatment Manual in accordance with 7 CFR part 305

. For articles with regulated components that are less than 6 inches in diameter, one of the following treatments will be required:

 Heat treatment , as specified in the PPQ Treatment Manual in accordance with 7 CFR part 305 , or
 Heat treatment with moisture reduction , as specified in the PPQ Treatment Manual in accordance with 7 CFR part 305 , or
 Fumigation with methyl bromide (T404

– d), in accordance with 7 CFR § 305. 5

. E ach shipment must be accompanied by a treatment certificate issued by the treatment facility . Individual boxes of wooden handicrafts will also be labeled with a merchandise tag containing the identity of the product manufacturer

. The identification tag must be applied to each package in China prior to exportation and remain attached to the package until it reaches the location at which the handicraft will be sold in the United States. This facilitates tracking of shipments should a recall be necessary. In addition, each shipment is required to be inspected at the port of entry

. Any shipment that is inspected and found to have pests may be cleaned or the entire lot may

be refused entry

into the United States in accordance with 7 CFR § 319.40. 

## I **II . Env**  **ironmental Consequences**
**A. No**  **Ac tion**  Current regulations do not allow the importation of Chinese wooden handicrafts that are made from wooden logs, limbs, branches or twigs greater than one centimeter and with intact bark into the United States. Under the no action alternative, importation of these wooden handicrafts from China into the United States would continue to be prohibited. Although there would be no potential environmental consequences of**4** prohibiting the importation of Chinese wooden handicra fts, this alternative would result in prohibit ing trade that has been determined to be safe through the use of the certain mitigations. 

### B. Proposed **Ac tion**  A pest risk assessment (PRA) titled Pests and mitigations for manufactured wood décor and craft products from China for importation into the United States ( USDA, 2007 a ) was prepared by APHI S to determine the arthropod pests that may follow the pathway

of Chinese wooden handicrafts and to propose possible mitigations that would be necessary to prevent pest introduction and/or establishment

. One of the greatest quarantine concern s associated with Chinese handicrafts is wood boring beetles in the families Buprestidae, Ceramb ycidae, and Scolytidae (USDA, 2011 ). In troduction of two wood boring beetles , the emerald ash borer (EAB) and the Asian longhorned beetle (ALB) , into the United States has prompted very large and costl y programs to eradicate them (USDA, 2011 ). Wood boring insects have the ability to cause a great deal of harm to ecosy stems in the United States if they should become established. Because immature stages of wood boring beetles can develop completely inside wood , these beetles are highl y likely to enter the United States , undetected , within wood (USDA, 2011 ). Economic costs associated with the wood boring beetles ( EAB and ALB ) have been in the millions of dollars (USDA, 2011 ) ; 144 of the 510 arthropod species liste d in the PRA are wood boring beetles (USDA, 2007a). To mitigate the wood boring beetles and the other insect pests of concern , APHIS has chosen methyl bromide fumigation and/or heat treatments with other safeguards as mitigations to the importation of manufactur ed wood décor and craft products from China into the United States , as described above in the preferre d alternative. Prio r to 2005, artificial trees required kiln heat treatment in C hina

. If pests were detected through inspection of the articles at the port of entry in the United States , the trees were treated with methyl bromide fumigation (USDA, 2011 ). In the final rule , the mitigation measures require kiln heat treatment or meth yl bromide fumigation in China (for regulated articles less than 6 inches in diameter) , as well as, a treatment certificate issued by the treatment facility

and port of entry inspection (USDA, 2011 ). Also, p rior to 2005, other Chinese wood handicrafts (in addition to the art ificial trees) required only port of entry

inspection (USDA, 2011 ). In the final rule , the proposed mitigation measures require heat treatment or methyl bromide fumigation (for articles less than 6 inches) , a treatment**5** certificate and port of entry inspection (USDA, 2011 ).
APHI S prepared a risk management document entitled Pests and m itigations for m anufactured w ood d écor and c raft p roducts from China for importation into the United S tates ( USDA, 2011 ) which concluded that the required mitigation measures (methyl bromide , for articles less than 6 inches, and/or heat treatment, phy tosanitary certificate, and inspection at port of entry) will mitigate the risk of pests of concern associated with the importation of manufactured wood décor and craft products from China into the United States (USDA, 2011 ). In ad dition, the risk management document specified that “ [b]ased on the pests’ biological characteristics, methods of dispersal, ability to be detected , and evaluation of effectiveness of the phy

tosanitary measures directed against them, APHIS finds that the safeguards of 7 CFR § 319.40 and the additional mitigations described above will result in the effective removal of the pests of concern.” Risk mitigation measures, such as fumigation , heat treatment , and inspection, are designed to prevent an y potential quarantine pests from entering the United States. Environmental concerns associated wi th these mitigations are discussed below in greater detail. Methyl bromide fumigation may occur prior to exporting wooden handicrafts leaving China . The final rule requires that wooden handicrafts which are subject to fumigat ion are products that contain regulated articles with components smaller than 6 inches in diameter, as outlined in treatment schedule T404

– d in the PPQ Treatment Manual

. Methyl bromide fumigation is generall y conducted i n contained facilities, thus limiting the potential exposure of other nontarget animals, including humans and the environment. Methyl bromide may also be conducted with tarps overlaying the commodities. However, even when tarps are used, there is limited exposure to other nontarget animals, humans, and the environment. Occupational workers are at the most risk of methyl bromide exposure ; however, adherence to pesticide label application directions , use guidelines and restrictions should ensure that there are no adverse effects on persons exposed occupationally. Additionally , based on the effectiveness of methyl bromide to eliminate the presence of insect pests, the importation of wooden handicrafts from China into the United States is not expected to hav e an effect on nontarget animals or the environment. The primary

concern with the use of methyl bromide fumigation is ozone depletion. Methyl bromide is a substance classified by the U.S. Environmental Protection Agency (EPA) under the Clean Air Act as a Class Iozone - depleting chemical. This ozone depletion is the primary **1. Methy l**  **Bromide 6**  issue of environmental concern related to fumigations with methyl bromide. The expected use of meth yl bromide in fumigations of Chinese wooden handicrafts is well below any levels that could contribute substantially

to ozone depletion. The amount of methyl bromide required to treat Chinese wooden handicrafts will be less than 27.36 pounds per container . China expects to export no more than 1000 containers of wooden handicrafts a ye ar . This would result in a maximum of less than 2 8 , 0 00 pounds of methyl bromide for the importation of wooden handicrafts from China into the United States. The total global consumption of methyl bromide in 200 7 was approximately 23,568,517 pounds 1 ( UNEP, 2008 ). A thorough review of the potential effects of methyl bromide uses in fumigations on ozone depletion was originally presented in the final environmental impact statement ( EI S ) for “ Importation of Solid Wood Packing Material

—

August, 2003; ” this document has recently been updated and is titled , “ Importation of Solid Wood Packing Material, Supplement to the Final Environmental Impact Statement

—2007” (USDA, 2007b ). This EIS determined that the cumulative impact of methyl bromide on ozone depletion from routine commodity treatments is not expected to be consequential.
P rior to Chinese handicrafts leaving China for importation to the United States, heat treatment or heat treatment with moisture reduction, must be performed for articles greater than 6 inches . Heat treatments are generall y conducted in contained facilities thus limiting the potential exposure to the treatment to other nontarget animals, including humans, and the environment. Additionally , based on the effec tiveness of heat treatment to eliminate the presence of live pests , the importation of wooden handicrafts from China into the United States is expected to have no effects to humans and the environment. 

### C. **Cumulative Impacts** Cumulative impacts are defi ned as “ the impact on the environment which results from the incremental impact of the action when added to other past, present , and reasonably

foreseeable future actions regardless of what agencies or person undertakes such other actions” (40 CFR 1508.7). The potential impacts from this final rule are not expected to pose s ignificant c umulative impacts. The mitigations of the preferred alternative are expected to provide an effective level of phy tosanitary protection (USDA, 2011 ). These mitigations are designed to prevent

1 The worldwide consumption of methyl b romide in 2007 w as 6,414.3 ODP. Methyl b romide has an ODP value of 0.6. 6,414.3 ODP tons /.6 tons = 10,690.5 metric tons 10,690.5 tons * 2204.6 pounds/ton = 23,568,276 pounds **2. Heat Treatment** **7** adverse cumulative impacts on the environment by decreasing the risk of introduction and establishment of pests of concern as a result of the importation of wooden handicraft products from China . Should other countries petition to export wooden handicraft products into the United States, those requests will be considered under separate rulemaking s
. The mitigations will not lead to significant cumulative impacts. Although the use of meth yl brom ide will increase the overall use of methyl bromide, the limited quantities of methyl bromide needed to treat the wooden handicrafts are within the negligible treatments anticipated under previous cumulative anal ys is of methyl bromide use (USDA, 2007b ; per s. comm. with EPA , 2007 ). 

### D. Endangered Species A**ct** Section 7 of the Endangered Species Act and its implementing regulations require Federal agencies to consult with the U.S. Fish and Wildlife Service and/or the National Marine Fisheries Service to ens ure that their actions are not likel y to jeopardize the continued existence of threatened or endangered species or result in the destruction or adverse modification of critical habitat.
APHI S has considered the potential effects of the rule to allow imp ortation of wooden handicraft products from China into the United States

. Heat treatments and meth yl bromide fumigations are generall y conducted in contained facilities; listed species and their habitats would not be exposed to these treatments. In addit ion, based on the mitigation measures in pl ace (methyl bromide fumigation , heat treatments , and other safeguards ) to eli minate the presence of pests of concern , the program has determined that importation of wooden handicraft products from China would have no effect on an y threatened or endangered species or their critical habitats.**8** 

## I **V. Other Issues**  Consistent with Executive Order (EO) 12898, “Federal Actions to Address Environmental Justice in Minority Populations and L ow - income Populations,” APHI S considered the potential for disproportionately high and adverse human health or environmental effects on any minorit y populations and low

- income populations. No disproportionate adverse effects are anticipated to any m inorit y or low

- income population, or particular subgroup of the U.S. population as a result of implementing the proposed action considered in this document. Consistent with EO 13045, “Protection of Children From Environmental Health Risks and Safet y Risks,” APHI S considered the potential for disproportionately

high and adverse environmental health and safety risks to children. No disproportionate adverse effects to children are anticipated as a result of impleme nting the proposed action considered in this document. Executive Order (EO) 13175, “Consultation and Coordination with Indian Tribal Governments,” was issued to ensure that there would be “meaningful consultation and collaboration with tribal officials in the development of Federal policies that have tribal implications....” No aspect of implementation of the proposed action considered in this document would result in tribal impacts that would require the need for consultation or collaboration with tribal officials.**9** 

## V. **Ag encies**  **and Organizations**  **Consulted** This EA was prepared and reviewed b y APHI S. The addresses of participating APHI S units, cooperators, and consultants (as applicable) follow.
U.S. Department of Agriculture Animal and Plant Health Inspection Service Plant Epidemiology

and Risk Analy sis Laboratory Center for Plant Health Science and Technology Plant Protection and Quarantine 1730 Varsity

Drive, Suite 300 Raleigh, NC 27606 U.S. Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine 4700 River Road, Unit 140 Riverdale, MD 20737 U.S. Department of Agriculture Animal and Plant Health Inspection Service Policy and Program Development Environmental Services 4700 River Road, Unit 149 Riverdale, MD 20737**10** 

## V **I . References** 

EPA

— See U.S. Environmental Protection Agency.
USDA

— See U.S. Department of Agriculture, Animal and Plant Health Inspection Service.
UNEP

— See United Nations Environment Programme United Nations Environment Programme, 2008. Consumption in ODP Tonnes Annex E, Group I (Meth yl Bromide) All Parties. Data Access Centre. Available at http://ozone.unep.org/Data_Reporting/Data_Access/ Last accessed on September 30, 2008. U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2003. Importation of s olid w ood p acking m aterial , f inal e nvironmental i mpact s tatement

— August 2003. Riverdale, MD. U.S. Department of Agriculture, Animal and Plant Health Inspection Service , 2007a. Pests and mitigations for manufactured wood décor and craft products from China for importation into the United States. Pest risk a ssessment. Center for Plant Health Science and Technology . July , 2007. Raleigh, N C

. U.S. Department of Agriculture, Animal and Plant Health Inspection Service , 2011

. Pests and craft mitigations for manufactured wood décor and craft products from China for import ation into the United States: r isk m anagement d ocument. Plant Protection and Quarantine. Revised January 7, 2011 . Riverdale, M D

. U.S. Department of Agriculture, Animal and Plant Health Inspection Service , 2007 b . Importation of s olid w ood p acking m aterial, s upplement to the f inal e nvironmental i mpact s tatement

— October 2007. Riverdale, MD

. U.S. Environmental Protection Agency , Stratospheric Protection Division, 2007 Pers

. c omm
. between J. Arling (EPA) and P. Grove (USDA, APHI S) regarding changes to current methyl bromide treatment schedules or rates of usage. August 29, 2007.