What is Firewood?
An important step in developing firewood guidelines is defining exactly what constitutes firewood.
- can include information about intended use, size, and exclusions of other raw wood products
- if broad provides protections from pests moved on other raw wood products, increases regulatory oversight, but can be confusing
- helps the public have a clear idea of what firewood is
Elements Included in Firewood Definitions
|State||Intention/Use||Size||Type of Firewood Covered||Specifically Excludes Other Raw Wood Products|
|Florida||Cut wood products intended for burning||Any length||Wood of any species||Yes|
|New Hampshire||That which is destined for use as fuel||Any length||Wood of any species||Yes|
|New York||That which is destined for use as fuel||Any length||Wood of any species||Yes|
|Oregon||In a form and size appropriate for use for fuel wood uses such as home heating or campfires||Less than 48 inches||Wood of any species||Yes|
|Pennsylvania||Meant for use in a campfire or other outdoor or indoor fire||Any length||Wood of any species||Yes|
|Utah||For use as fuel for fires in open pit, grill, fireplace, stove, or other wood burning furnaces or devices in any form commonly used for burning in campfires, stoves, or fireplaces||Less than 48 inches||Wood of any species||No|
|Vermont||Used in residential, recreational, or commercial wood burning appliance or fireplace indoor or outdoor||Less than 48 inches||Wood of any species||Yes|
The Complexities of Defining Firewood
Nearly all states define firewood by intent of use (e.g., firewood is wood that is intended to be used as a fuel). This aligns the regulatory definition of firewood with the common definition and helps separate regulated articles from other raw wood products. However, a definition incorporating intent can result in enforcement challenges as it can be difficult to prove unless the article already exists. Likewise, intent may change as the product is moved along the supply chain.
Many states include length restrictions when defining firewood (e.g., firewood is less than 48 inches in length). States need to consider this and make adjustments particularly where firewood is imported as tree-length.
Some definitions of firewood include language based on processing by cutting (e.g., firewood is cut and/or split into pieces/chunks). States should consider other types of wood which are also cut and split, intended to be used as fuel, and less than 48 inches in length, such as smoker chips or wood chips. States should determine if they want to regulate these products as firewood.
Some definitions of firewood exclude species or types of firewood (federal emerald ash borer regulation excludes softwood). This can help a state focus on the forest resources currently at risk, but doesn’t consider future potential for new pest threats. States should consider regulating all types of wood.
Some states also specifically exclude certain other wood products from the firewood definition, which helps. For instance, the definition may exclude wood or logs used for dimensional lumber, pulp or paper mills, manufacture of wood pellets or plywood, or wood biomass-using refineries or power plants.
- Defining firewood exclusive of other wood products helps ensure that states are clearly communicating what wood products are regulated by a firewood quarantine.
- Maintains focus on firewood. Firewood is a high-risk pathway compared to other wood products because:
- It is moved both commercially and recreationally
- Firewood increases in value if it has been seasoned (aged) for over a year, creating an incentive for storing firewood over a long period of time over which pests may emerge.
- Firewood is used incrementally, increasing the time over which pests may emerge.
- Firewood generally undergoes very limited processing, resulting in fewer opportunities to kill or destroy all life stages of pests.
- Firewood is frequently subdivided and spread to additional destinations, increasing the area over which pests may emerge.
- Firewood may be abandoned and not used, allowing slow emerging pests to reach maturity.
- The public understands what firewood is – they burn it in their woodstoves and fire rings.
Other types of unprocessed wood products may pose a risk, but may be excluded from the firewood definition. These may include wooden hand crafts from on-line vendors, nursery stock transport packing material, and chew toys for pets.
Defining firewood can help states clearly communicate the goal and purpose of the regulation.
- Firewood definitions should include a statement of intent, e.g. to be used as a fuel.
- Determine how firewood is transported into the state. If longer length firewood is not generally moved into the state, then a length restriction to 48 inches or less makes sense.
- Consider whether or not to exclude some types of firewood from the regulation. If so, that should be stated through listing species or types of firewood regulated, and whether or not treated firewood is excluded, including the type of treatment.
- Consider clarifying the firewood definition by specifically listing types of products not considered as firewood, but rather as “other wood products”.
(a) “Firewood” means any kindling, logs, timber, or other portions of a tree of any species four (4) feet or less in length, cut or split, or intended to be cut or split, into a form and size appropriate for use as fuel for fires in open pit, grill, fireplace, stove or other wood burning furnaces or devices. OR
(b) “Firewood” means all wood of any species, cut or not cut, split or not split, regardless of length which is destined for use as a fuel.
Firewood shall not include kiln-dried dimensional lumber, nor wood that has been chipped to smaller than 2 cm diameter. In addition, firewood shall not include logs or wood being commercially transported to, or possessed by, the following operations and facilities for use in their primary manufacturing process:
- sawmill for dimensional lumber;
- pulp and/or paper mills;
- wood pellet manufacturing facilities;
- plywood manufacturing facilities;
- wood biomass-using refineries or power plants;
- re-constituted wood or wood composite product manufacturing plants;
- wood transported to be chipped for either mulch or compost;
- facilities treating firewood in accordance with heat-treatment standards.
Heat Treatment Standards