Following is a revised procedure based on feedback from suppliers, engineers, industry contacts, and other operational support groups. The changes are intended to further improve the process.
| Scope | All packing materials made from any amount or any combination of solid wood and/or processed wood components. |
| Applicability | All IBM operations worldwide, including Other Equipment Manufacturers (OEM's) and other vendors performing work for IBM or under contract by IBM. It also includes packing for procured parts from suppliers bound for IBM Manufacturing or Field Service locations worldwide. |
| Purpose | To ensure minimal delays or rejected shipments associated with compliance to International Phytosanitary regulations designed to combat pest migration. |
| Objectives | To implement a common marking procedure globally and to identify and use only approved and properly treated materials as required for exports to regulated countries. |
| Achieved By | Providing clear markings on the regulated articles so that shippers can confidently apply the correct declarations or required certificates. |
| Marking Procedure | Mark the pallet, skid, crate, or other wooden packaging assembly a minimum of one time on a visible vertical surface, using 19mm minimum characters which are permanent and indelible. This may be done with ink jet printing, heat stamping, paint stencil, or other similar method. Mark the information as specified below. Redundant markings on the opposite side is recommended but optional. If vertical surfaces provide insufficient space for the markings then scale the characters accordingly or apply them to a top horizontal surface provided that at a minimum the material classification is repeated on a vertical surface. It is also allowed to print the information on multiple lines or break up the information, for instance spread across three separate blocks on a block style pallet. |
| Material Classification Symbols (only one applies to any given item) |
A given item shall only carry ONE classification regardless
of how many different materials are included in the construction. Follow this list in
sequence, the item should carry the marking of the first scenario that matches exactly.
Even if the majority of the construction consists of non-SWPM components, the marking
shall relate to the solid wood component that exists (if any) and any permanent treatment
that was done. "SW" (Softwood): Items marked with this abbreviation contain ANY amount of solid, untreated and unprocessed conifer (aka "softwood", or needle bearing type species of wood) even if combined with treated components. Items with this symbol can technically be exported to non-regulated countries but it is suggested that these not be exported at all (in anticipation of global ban). "HW" (Hardwood): Items marked with this abbreviation contain ANY amount of solid untreated and unprocessed deciduous wood (aka "hardwood", or leaf bearing species of wood) and no conifer even if combined with treated components. Items with this marking technically can be exported to China but we still have had problems with it at certain border crossings. "HT SOFT" (Heat Treated Softwood): Items marked with this abbreviation contain ANY amount of solid, properly heat treated conifer (aka "softwood", or needle bearing type species of wood) which by definition means that it has been heated to a core temperature of at least 56C (133F) for a minimum of 30 minutes and that documentation certifying that has been provided by the treatment facility to the package/pallet manufacturer and can be traced to the production of that specific package, pallet, and so on. This also must not contain any amount of untreated softwood. Note: Only use Kiln dried lumber that meets the temperature and duration requirements above. "HT HARD" (Heat Treated Hardwood): The same heat treatment rules as with conifers (temperature, duration) except when done for deciduous or "leaf bearing" species of wood. "CT SOFT" (Chemical Treated Softwood): For conifers that have been permanently treated with chemicals. Does not include fumigation treatment. Avoid chemically treated softwood since it cannot be recycled or incinerated. "CT HARD" (Chemical Treated Hardwood): For hardwoods that were permanently treated with chemicals. Does not include fumigation treatment. Avoid chemically treated hardwood since it cannot be recycled or incinerated. "NO-SWPM" (No Solid Wood Packing Material): Items marked with this abbreviation may appear to be made of wood and must contain ANY amount of processed wood components but no solid wood whether treated or not of any type. Example: A pallet or crate made with any amount of Oriented Strandboard (OSB), plywood, strawboard, masonite, particle board, or combination of these and meeting the definition of non-solid wood packing materials as defined by the Animal and Plant Health Inspection Service (APHIS) and is totally free of solid wood. Note: Plywood is not considered "solid wood" because it has been processed under extreme heat and pressure. "XX" Items marked with the XX abbreviation would be items in which the composition cannot be affirmed such as with refurbished pallets. Existing markings may also be covered up with this as needed. This would be a signal that this particular item may require fumigation or other approved treatment. Note: There is no marking for fumigation since this is a temporary treatment. Fumigation, if done must be documented with a certificates of fumigation generally issued by the fumigator and endorsed by a Govt. approved Agency.. |
| Supplier Designation | Required: To identify the final assembly
supplier of the pallet, package, crate and so on in some manner. This may be done in any
one of these ways.... 1. A 5 character abbreviation of the supplier’s name... -or- 2. A 3 digit abbreviation followed by 2 numeric digits to distinguish unique manufacturing facilities. -or- 3. The supplier’s logo if this can be easily distinguished. The logo can also be followed with a 2 digit number to identify a specific facility if needed. The name shall be that of the final assembly location which built the pallet or package and shipped it to IBM for use. Take care to ensure that the code chosen does not resemble one of the material classifications. |
| Country of Manufacture of the Wooden Item | Optional / Restricted: It is expected that this
would infrequently if ever be denoted on the wooden item. This is an important change from
the original program.. This is because the regulations apply to the source of the shipment,
not necessarily the source of the raw lumber or the wooden package assembly. It is also
not necessary for shipper declarations or certifications. Therefore, a designation of the
country of manufacture of the wooden item may only cause more confusion and delays than it
would eliminate. If it becomes important for other reasons to denote the country of
manufacture (for instance, reusable items) then these are the rules by which this must be
done.... 1. If country of origin of the pallet is included in the wood marking procedure, it must be prefaced with the phrase: "Pallet made in xxx", where xxx is the full English name of the country in which the pallet was made; 2. If the country where the pallet was made is not the same country in which the pallet was treated, the following phrases must be shown: "Pallet made in <full English name of the country in which the pallet was made>", "Pallet treated by <supplier name> <supplier ISO code>". Clearly, these restrictions and requirements force us beyond what could be achieved in a single line of text which is the goal of this marking procedure. |
| Date of Manufacture | Required: Format may be MM-YYYY or YYYY-MM. The specific day is not required. A four digit year is considered important since in some parts of the world the year precedes the month when dates are printed. |
| Part Number | The 7 digit alphanumeric part number of the package assembly.
Required for IBM designed and specified items, optional for supplier items. |
| Engineering Change Number | Optional: The six digit alphanumeric "EC" number which may distinguish a different design for items with the same part number. This may be important to some locations and it is their prerogative to specify if it if they wish. |
| Reusable Pool System Symbol | Optional / Restricted: For instance, the familiar "EUR" symbol associated with the European pool system pallets (aka "Euro Pallets") or any other similar program previously established or future program. This marking to be placed as specified by that system. Only pallets meeting the design and construction requirements of the marked pool system are to carry that symbol. Note: Unless the material type is marked on a "Euro Pallet" it should not be exported to a regulated country. |
| Example Marking of an IBM Stringer Pallet | HT SOFT__ONG12__6038888__06-2000 (Underscore shown to demonstrate spacing between elements, it is not printed) |
| Example Marking of an IBM Block Style Pallet | HT SOFT 6038888 ONG12 06-2000 (First Block) (Second Block) |
| Example Markgin of a Supplier’s Pallet | HT SOFT__ONG12__06-2000 (Underscore shown to demonstrate spacing between elements, it is not printed) |
| Points of Emphasis | 1. Do not mark items which are clearly not of wooden origin
unless that assembly does have some wooden components somewhere else in the assembly. For
instance, if a package consisted of a plastic pallet and a plywood crate on top of it then
the appropriate wood classification marking should be placed on a vertical surface of the
wooden crate portion, not the plastic base pallet. It is not necessary to mark corrugated
or plastic items. 2. There is a concern that the country of manufacture (of the wooden item) may be confused as a Country of Origin declaration of the goods. For this reason, the country name or initials should be avoided unless deemed essential for other reasons. If so, strict policy for denoting this applies (as shown above). 3. Reusable containers, regardless of material composition, must always be marked as follows... "Reusable Container, Container Made in XXX" (where XXX is the full country name in English where the container was made). This is a separate matter not related to the infestation issue but is important regarding duty payments and taxes. 4. Use the "XX" material classification marking if the species, origin, or treatment cannot be affirmed. By default, anything marked this way or unmarked cannot be used for export to a regulated country. 5. If refurbishing a pallet which has already been marked, obliterate, cover up, or remove the original marking and then instruct suppliers to turn this side to the inside so that it will not likely be observed. Any marking appearing on an inside surface is not to be used for inspection or operational purposes. 6. Every wooden assembly would get some type of marking regardless of composition at the time of manufacture. |
| References | USDA’s APHIS Website: http://www.aphis.usda.gov/ppq/swp National Wooden Pallet and Container Association http://www.nwpca.com |
| Originator | This document originated by IBM’s Worldwide Distribution organization. Bob Sanders (btsander@us.ibm.com), Erich Guenter (eguenter@de.ibm.com) |
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