Compliance Agreements

Summary statement: Commercial entities must have a Master Permit issued by the state that outlines the conditions under which firewood may be imported into Florida. Firewood imported into the state must be certified as treated in accordance with the USDA APHIS PPQ Treatment Manual (Rev. 05/2012), Treatments and Schedules T312 and T31. This allows for heat, fumigation, or chemical treatments of wood products. There are exemptions for out-of-state firewood produced within a 50-mile radius of a Florida destination. There are record-keeping requirements.

Benefit: Verified treatment of firewood entering the state under Master Permit system.

Advantages: High confidence that imported firewood has undergone disinfestation to reduce risk. High traceability and accountability of firewood.

Benefit: Ability to trace firewood back to its source.
Advantages: Inexpensive to operate. Potential source of revenue ($25 per importer per year). Opportunity to address quarantine violations before they occur.

Disadvantages: Doesn’t necessarily discourage long-distance transport of firewood and may do little to inhibit the spread of non-regulated pests and disease.

Summary statement: State properties have a rule that firewood can only be sold to a state park, reservoir, state forest or state fish and wildlife property if under Compliance Agreement from the USDA APHIS or Indiana DNR. Indiana accepts four compliant treatment options for firewood: 1) fumigated using schedule T404-b-1-1 methyl bromide by a licensed fumigator at 5 lb./1000 cubic feet for 16 hours at a temperature at or above 4˚C (40˚F), 2) heat treated using schedule T314-C: 71.1˚C (160˚F) for 75 minutes, 3) debarking, or 4) seasoning firewood for one full year and ensuring that the moisture content is less than 20%. Approximately 95-98% percent of firewood producers in Indiana choose the seasoning certification option. These producers sign a Compliance Agreement with the state and their company information is listed on the state website. Visitors bringing firewood with them for personal use at the park may comply with the requirement with a visual inspection of the firewood upon entry to ensure that it is appropriately de-barked.

Benefit: Meets the requirements of state law regarding bringing firewood to state properties.

Advantages: Relatively inexpensive to operate though staff time is needed for Compliance Agreements, inspections and administration. Treatment requirements are not difficult to meet, making the program accessible to more producers.

Disadvantages: State certification is only recognized by Indiana state properties. Program does little to discourage long distance movement if wood isn’t destined for a state property or crosses a quarantine line. There is varying information on whether one year of seasoning is sufficient to ensure wood is free from emerald ash borer.

Summary statement: Compliance Agreements are available from the State of New Hampshire for: 1) certified heat-treatment kilns receiving untreated out-of-state wood for treatment; 2) haulers transporting out-of-state firewood to compliant heat treatment kilns; 3) firewood suppliers harvesting firewood in New Hampshire, processing out of state, and then distributing back into New Hampshire; and 4) another process, approved by both Departments with quarantine oversight, shown to provide protection against a range of pathogens and pests, and which process can be documented and reported. There are record keeping requirements, use of labels and forms, and potential other restrictions based upon type of wood moved, and timing of harvests and transportation. Those with Compliance Agreements to process New Hampshire wood in another state usually require permission from that state to import New Hampshire-origin firewood, as Maine and Vermont both also have exterior firewood quarantines.

Benefit: Based on risk-mitigation of firewood rather than origin of firewood and presumed known pest populations.

Advantages: Partnerships with firewood kilns that are reducing risk from firewood. Lower heat-treatment standards means that there are several certified kilns in the state that are able to use this program. Recognition of historical movement of firewood across state lines for processing in a small state with long borders. Use of decals to mark trucks with compliance agreements communicates compliance with enforcement personnel, receiving kilns, and the public.

Disadvantages: Limited enforcement personnel results in uncertain levels of non-compliance. Commitment to communication with the industry is necessary as well as staff hours to oversee compliance agreements. Requires transporters to maintain different types of records (i.e. asking for type of wood such as oak, ash, maple, rather than the usual descriptor of mixed hardwoods) than they are used to, resulting in non-compliance issues requiring additional oversight and training.

Summary statement: Vermont issues a “waiver” of quarantine requirements upon request if the Department can determine that the request to import firewood is in the public interest and poses minimal risk to forest health. The waiver request is based upon information about both the origin and destination of firewood, amount, type, timing of transportation, reason for the request, if any treatments have occurred, transporter’s contact information, and any other supporting information.
Benefit: Provides the ability to waive the quarantine under conditions merited as low phytosanitary risk, with some level of control as to what enters the state.

Advantages: Provides flexibility to the state with requests for importation of firewood. Provides a level of traceability of wood entering the state. Provides an avenue for compliance without significant cost to the producer under conditions that have been determined to be low risk.

Disadvantages: Necessary requirements for approval not clearly stated. State approves requests on a case-by-case basis which can cause some difficulties if decisions are challenged.