Certification Programs and Interstate Firewood Trade
A Certification Program is administered by a state (where firewood is harvested and/or processed) to provide oversight of firewood entering trade in another state (where this product is sold and/or distributed). Certification Programs are how states help their own producers meet the regulatory requirements imposed by other states. States considering a Certification Program should consider if it provides sufficient benefits to their states’ firewood vendors to encourage participation.
The Complexities of Certification Programs
Certification Programs are currently most appropriate for firewood producers with kilns that are interested in firewood heat-treatment certification. Exemption of certified heat-treated firewood is relatively consistent among existing external state and international firewood quarantines. Certification of firewood kilns has been the role of USDA APHIS PPQ in many states, and changing federal regulations could impact the continued federal support of kiln certification, so states should consider whether or not a Certification Program could be managed by the state.
Certification Programs can be implemented for certification other than heat-treatment. Certification Programs involve regulatory oversight of treatment conditions, review of documentation, and verification of monitoring equipment. A Compliance Agreement can be used within a Certification Program to provide enforcement of non-compliance. States requiring certification will have improved compliance if requirements and standards are provided in clear language. See summaries in the Appendices.
Benefit
- Certification Programs and associated training materials are valuable tools to ensure the understanding of regulations and the requirements to move regulated articles to another state.
Advantages
- States can require training and verify that entities are able to comply with the regulations.
- States may require notification and additional documentation of movement.
- Records in the form of permits or chain-of-custody documents allow trace backs.
- The Compliance Agreement in the Certification Program is the enforcement document.
- Producers of firewood have a product that has been treated or mitigated so risk of introduction or spread is decreased.
- Completion of the treatment processes within the certification program may result in a value-added product.
Disadvantages
- States vary in certification requirements.
- States vary in their ability to oversee Certification Programs.
- Costs may result in small producers avoiding a Certification Program.
Certification Program Recommendations
- Determine if there is an industry that would benefit from implementation of a Certification Program.
- Determine the terms and oversight of the Certification Program within the quarantine or departmental policy.
- Publicize the availability of a Certification Program to producers, trade groups, green industry and suppliers of related equipment such as saws, wood splitters and trailers. Focus on the positives – certification will allow them to continue to legally export their product to another state, or sell to regional wholesalers and distributors.
- Incorporate training with certification. During that training, ask questions that demonstrate how the entity can meet the certification requirements.
- Develop and foster relationships with industry to improve communication and increase the likelihood of reporting suspected outbreaks.
Regulations
Quarantine Template
Firewood Definitions
Firewood Labeling
Heat Treatment Standards
Compliance Agreements
Certification Programs
Enforcement