National Plant Board Firewood Guidelines - Revised Jan. 2020
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National Plant Board
Firewood Guidelines
Revised Jan. 2020
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesTABLE OF CONTENTS
1. Introduction
a. Overview 1
2. Regulations
a. Overview 3
b. Quarantine Template 5
c. Heat Treatment Standards 8
d. Compliance Agreements 11
e. Certification Programs 13
f. Defining Firewood 15
g. Labeling 18
h. Enforcement 21
3. Best Management Practices
a. Overview 23
b. Commercial Producers 25
c. Cutting for Personal Use 27
d. Consumers 29
4. Outreach to Outdoor Enthusiasts
a. Overview 31
b. Develop a Webpage 33
c. Focus on Outcomes 35
d. Work with Campgrounds 37
e. Create an On‐line Firewood Directory 39
5. Appendices
a. Heat Treatment 40
b. State Regulations as of January 1, 2020 45
i. Florida 46
ii. Maine (Emergency Order) 50
iii. New Hampshire 52
iv. New York 59
v. Oregon 63
vi. Pennsylvania 66
vii. Utah 68
viii. Vermont 72
c. Examples of Compliance Agreements 76
i. Florida 76
ii. Illinois 76
iii. Indiana 76
iv. New Hampshire 77
v. Vermont 77
d. Examples of Certification Programs 78
i. Minnesota 78
ii. Wisconsin 78
e. National Firewood Task Force Recommendations: Audience Outreach Chart 79
f. Firewood Scout Membership Packet 83
g. National Plant Board Firewood Work Group Contributors 84
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood Guidelines1. INTRRODUCTTION
A. OVERVIEW
Summ mary Statement: This doccument, the National
N Plantt Board Firewwood Workingg Group Guideelines, is a professional
resouurce that com
mpiles currentt scientific, re
egulatory, outtreach, and mmanagement sstrategies on the issue of fforest pest
t U.S. firewood pathwayy. The primaryy audience off this documeent is the Statte Plant Regulatory
transsport within the
Officials (SPROs) for
f all US states and territo ories. Howeve er, all are wellcome to use this document to better inform their
knowwledge and acctions on the firewood patthway.
Each of the three major conten nt sections off the document (Regulatio ns, Best Man nagement Praactices, and O Outreach)
contaains an overvview of the section, followe ed by individu ual guidance documents, ssummaries, aand/or case sttudies. In the
regullatory section
n, these guidaance documents are design ned to informm the processs of drafting n
new or revisedd state‐based
d
regullations pertaiining to firewood. The Guidelines includ de case‐studyy style analyses of how som me states havve already
approached firew wood quarantiines. In the BMPs and Outreach sectionns, these guid dance documeents provide examples of
strategies beyond d regulation thhat could enh hance a state’’s overall respponse to the firewood patthway, as welll as selected
recommmendationss or exampless within these e strategies. Each
E section iis meant to b
be used as a curated resource to allow
everyy state to assess, develop, and/or make e changes to their
t firewoood programs. Lastly, the apppendices con ntain
suppplementary materials (scien ntific references, full text of
o existing quuarantines, ettc.). The Natio
onal Plant Board is
proviiding these Guidelines as a library of resources for voluntary
v use.. The Nationaal Plant Board
d will not, and
d cannot,
require any entityy to implemen nt any of the recommendaations within this documen nt.
Backkground:
The NNational Plant Board (NPBB) Firewood Working
W Group was formedd in 2018 to ccreate a reference documeent
contaaining organized and vetteed firewood resources
r to provide
p to staates, as a resuult of converssations and co
oncerns that
emerrged during the process off the USDA AP PHIS federal proposed
p rulee to deregulate emerald ash borer (EAB B). A number
of SP
PROs, and othhers, expresseed the concerrn that in the absence of feederal regulation of EAB th here would bbe no or
limiteed mechanismms for states to continue regulating
r e movement of firewood. The National Plant Board charged the
the
NPB Firewood Wo orking Group with develop ping a framew work of activitties for statess to make well informed ch hoices on
how they can bestt prevent or reduce
r the movement of pests
p and patthogens on firrewood. Inforrmation abou ut members
of the NPB Firewoood Working Group, extern nal reviewerss of draft guiddelines, and o other contribuutors can be ffound in
Appeendix G.
The m
movement off firewood is a significant pathway
p for the introductiion and spreaad of invasivee forest pests and
pathoogens, and adddressing the e issue of firew
wood transpo ortation is commplex. Firewood producers range from m large‐scale
with national distribution netw works to local and seasonal producers sselling firewoo od to supplem ment their inccome.
wood is used for
Firew f both struccture heatingg purposes an nd recreation.. Because of tthe cross‐secttion of the geeneral public
involved in firewo
ood transportation, and ch hallenges of id
dentifying inddividuals transsporting firew
wood, the fireewood
pathwway is not reaalistically add
dressed solelyy through regulatory approoaches.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesSection Overview: Regulations
Regulations can be used to prohibit firewood movement or restrict the distance and type of firewood that can be moved
into or within a state. Regulations are most effective when they include mechanisms for enforcement with penalties
assessed for violations. The NPB Firewood Working Group has created a firewood regulation template and supporting
materials for states to use if they are interested in pursuing a new or modified regulation. Supplemental resource
materials will assist states to determine how to define firewood, select a standard to exempt certified heat‐treated
firewood, incorporate Compliance Agreements, consider Certification Programs, require consistent firewood labeling
using plain language, and think about the challenges of enforcement.
Section Overview: Best Management Practices (BMPs)
BMPs primarily address firewood used for structure heating (such as a home or cabin). BMPs can provide tools for
industries and consumers to reduce the risk of spreading invasive species. BMPs will reduce, but not eliminate the
probability of a pest introduction in firewood. States should promote BMPs to protect within state movement of
firewood. Incorporating a focus on improving quality of firewood will help ensure broader adoption. The NPB Firewood
Working Group has curated BMPs targeted to producers and consumers of firewood.
Section Overview: Outreach
The outreach recommendations target campers and users of recreational firewood. Outdoor enthusiasts moving
firewood are challenging to target with regulations and BMPs due to their variable destinations, preferred information
sources, and motivations. The NPB Firewood Working Group has created materials for states to consider including:
developing a key message, working with high‐value partners, creating a state‐managed firewood webpage, focusing on
outcomes, working with campgrounds, and creating a state specific on‐line firewood directory.
Revised Jan. 2020 Page |2
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood Guidelines2. REGU
ULATIO
ONS
A. OVERVIEW
Summ mary Stateme ent: This docuument contain
ns information n for states considering the developmentt of a new or updated
regullation for the movement off firewood. The intent of the e regulatory ttemplate, acco ompanied by supporting gu uidance
documents and ap ppendices, is to
t summarize the experiencces of other sttates that havve existing fireewood regulattions, with a
focuss on those thaat have exterio
or quarantiness. States considering implem menting a fireewood quaran ntine need to identify the
inten
nt of the regulation and the approach. Sttates considerring regulatingg firewood should get meaningful respon nses from a
variety of stakeholders and colleeagues and co
onsider the following:
1
1) Do stakeholders or agen ncy staff in yo
our state thinkk/agree that thhe movementt of firewood sshould be reggulated?
2
2) What are your state’s primary concerrns about firewood movem ment?
a. In ntra‐state movvement from source
s to areaa‐of‐use or sale? (e.g., firew wood cannot m move intra‐staate further
th
han 50 miles; see New Yorkk or Florida’s re egulations in A Appendices)
b. In ntra‐state movvement from knownk infesteed areas to unninfested areaas? (i.e., firewo ood from a qu uarantined
poortion of yourr state cannott be moved to a non‐quaranntined portion n)
c. Im mportation of untreated fire ewood from known
k infesteed areas for a sspecific pest?? (i.e., firewood from states
with
w outbreakss of emerald ash a borer, Asiaan longhornedd beetle, red imported fire ant, or other pests cannot
bee imported)
d. Im mportation of untreated fire ewood from out‐of‐state?
o ((i.e., out‐of‐sttate firewood is prohibited))
3
3) What are the most com mmon forms of o firewood typ pically importted, distributeed, and/or sold d throughout your state?
(e.g., is it cut
c and split lo oose, bagged,, wrapped, bo oxed, deliveredd in cords, as whole logs, or something eelse?)
4
4) Are you co onsidering exe empting certiffied heat‐treated firewood from any quaarantine requirements that you develop? ?
If so, whatt is the minimum treatment level that yo ou would deem m acceptable??
5
5) Will your state
s create and/or maintain a state‐base ed certified trreatment proggram to allow for your statees’ firewood
producerss to sell firewo ood to other states that may be implemeenting their ow wn regulations?
6
6) Are you op pen to considering treatme ent options otther than heatt treatment to wood from the regulatory
o exempt firew
requireme ents?
7
7) What leve el of firewood labeling, traceability, and reporting
r will yyou require?
When these questtions have bee en consideredd, the quarantine template and supportin ng documentss can be reviewed to assist
development of a firewood quarantine. The template
t is de
erived from exxisting exterio
or firewood qu uarantines. Exxamples of
curreent state regullations are inccluded in the appendices.
a The
T template’ss purpose is to o provide a reference firewood
quaraantine, including the aspectts common to o most of the reviewed exteerior firewood d quarantines. This templatte is not
mean nt to be adoptted as written n, but to maximmize the efficiiency and connsistency of thhe process and d end productts for
intereested states. It is understoood that each state
s will havee their unique regulatory lan nguage that w
will need to bee included.
This d
document pro ovides guidance to inform portions
p of thee template regulation. For example, the definition of ffirewood, the
heat‐‐treatment staandard, and methods
m nforcement vary between sttates. Consisteency in labelin
of en ng, in clear lan
nguage, helpss
the fiirewood indusstry be compliant while info orming regulaators in otherss states and co onsumers that firewood haas met
requiirements. Com mpliance Agre eements and Certification
C Programs
P can eenable the firrewood industtry in your staate or region
to co
omply with new w and existingg regulations region‐wide. TheT NPB’s Fireewood Workin ng Group deteermined it waas important
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood Guidelinesand helpful to provide an explanation regarding specific technical or functional decisions, and hopefully this guidance will
help states make the choices that best fit their needs.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesB. QUARANTIN
NE TEMPLA
ATE
State
e of ________
_________________________
Department of ___
_________________________
Exterior Firrewood Quarrantine
hority and Purrpose.
Auth
blished under authority of ___________
Estab _ ___________, this rule is ennacted to pro
otect the Statee of ____________________
_
preveenting the movement
m of invasive pestts transported
d by firewoood, including, but not limited to Agrilu
us planipenniis
(Emeerald Ash Bore
er), Anoplopho
ora glabripen
nnis (Asian Lon
nghorned Beeetle), and otheer forest pestts of concern ttransported in
n
or on
n firewood fro
om outside the
e State of ___
____________
__________.
Defin
nitions.
(1) “Certified heat‐treaated firewood
d” means {pleaase see Heat TTreatment Staandards}.
(2) "Depaartment" meaans the Deparrtment of ____
_____________________________.
(3) “Com
mpliance Agree
ement” mean
ns a written and
a signed leggal contract b
between the sstate or federral agency and
d
the kiiln, processor,, facility, or ve
endor confirm
ming the methhods, conditio
ons and proceedures that w
will be followed
d
to meet
m firewood
d quarantine
es, laws, and
d regulationss. A Compliaance Agreem
ment may co
ontain genera
al
requirements for producing
p and handling re
egulated matterial as well as identify sttipulations orr measures to
o
effecttively addresss a specific qu
uarantine or other
o specific certification standard of tthe destinatio
on. {Please see
e
Comp
pliance Agreem
ments.}
(4) “Firew
wood” means {please see Defining
D firewo
ood}.
(5) “Labe
eling” means {please see Laabeling}.
(6) “Othe
er wood prod
ducts” means raw or treate
ed wood prodducts includin
ng sawlogs, p
pulpwood or w
wood chips to
o
facilities for processsing into lum
mber, paper or manufacturred wood pro
oducts and wh
hich are exclu
uded from the
e
requirements of this quarantin
ne {states sho
ould add which products are excluded
d and pleasee see Defining
g
ood}.
firewo
(7) "Perso
on" means an
ny individual, organization,
o corporation,
c oor partnership
p.
(8) "Unccertified firewood" means any firew
wood not m eeting the d
definition off "certified heat‐treated
d
firew
wood" or thatt is not certiified through
h a Complian
nce Agreeme
ent.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesArea Under Quarantine.
(1) All areas outside of the jurisdictional boundaries of the State of ________________________.
Articles and Commodities Under Quarantine.
(1) This quarantine applies to all out‐of‐state firewood offered, exposed, or held for sale in the State of
________________.
(2) This quarantine excludes other wood products as defined in this quarantine.
Restrictions.
(1) A person may not import out‐of‐state firewood unless the firewood is certified heat‐treated or the person
producing the firewood is under a Compliance Agreement.
(2) All certified heat‐treated out‐of‐state firewood transported, offered, exposed, or held for sale in the state shall
be labeled in accordance with _________________ {please see Labeling}.
(3) Any person that imports certified heat‐treated firewood in this state shall maintain records for two (2) years.
Requirements for Certified Heat Treated Firewood Labeling Requirements.
(1) Heat‐treated firewood is heated to 60 °C (140 °F) for 60 minutes at wood core. {Refer to Heat Treatment
Standards for advantages and disadvantages to higher and lower heat treatment standards.}
(2) Firewood is certified by a federal, state, or 3rd party organization.
(3) Temperatures are as measured in the core of the firewood during the heat treatment process.
(4) Records of treatment, origin of firewood, and sales are maintained and auditable by a certifying agency.
(5) Firewood is labeled with:
(a) all information required by the National Institute of Standards and Technology (NIST) Handbook 130;
(b) identification of the commodity as firewood, unless the contents can be easily identified through the wrapper or
container;
(c) name and address of the manufacturer, packer, or distributor of the firewood, if the package or bulk shipment
was not produced on the premises where it is offered, exposed, or held for sale;
(d) the certifying authority and certification number; and
(e) statement of the heat treatment standards used to certify the firewood in plain language.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesExemptions.
(1) Firewood harvested within the State of _______________ is exempted from the treatment requirements.
(2) The department may issue an exemption for firewood certified under an existing program {see Certification
Programs}.
Enforcement.
(1) Authorized agents of the department shall refuse admittance into the State of _______________any firewood
products that do not meet the provisions of this quarantine {please see Enforcement}.
(2) Any shipment found within the State of _________________ in violation of this quarantine shall be treated to
comply with this quarantine, returned to the exporter at once, or destroyed under supervision of the state. The state
shall not be responsible for costs incurred for treatment, shipment, or destruction of any non‐compliant firewood.
Violations and Penalties.
(1) Any fraudulent use of incorrect information on any forms used in the enforcement of this quarantine is a
violation of this quarantine.
(2) Any fraudulent representation of state or federal certifications is a violation of this quarantine.
(3) Any use of state or federal certifications after they have been expired or retracted is a violation of this
quarantine.
(4) Any misrepresentation of untreated firewood as certified firewood is a violation of this quarantine.
(5) Failure to comply with any provisions of this quarantine shall be a violation of this quarantine.
(6) Violators of this quarantine shall be subject to penalties__________________________________.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesC. HEAT TREAATMENT STAANDARDS
Summ mary statemeent: This guid
dance will desscribe the heaat‐treatment standards that may be ussed to exempt heat‐treated
d
firew
wood from quaarantine requiirements.
A heaat‐treatment standard
s inclu
udes both the time and temmperature reqquired to disinfest firewood of insect life stages and
viablee pathogens. Standardly referenced treaatments for firrewood are T3314‐b: 56 °C ((133˚F) for 30 0 minutes (commonly
knowwn as the gypsy moth or ISSPM 15 standard), T314‐a: 60˚C (140 ˚F) ffor 60 minutees (commonlyy known as the EAB
stand
dard), or T314
4‐c: 71.1˚C (160 °F) for 75 minutes
m (commmonly known as the “Vario ous Wood Pestts” standard). All three
dards can impact survivorsh
stand hip of insects and
a pathogen ns when approopriately appllied and documented, with some studiess
demo onstrating bettter consistentt control of th higher standaards. See Heatt
hermotolerantt insects and ppathogens witth use of the h
Treattment for morre information n.
Tablee: Heat Treatm
ment Standardd Comparisonn in Existing Firewood Regu
ulations (Jan 1, 2020)
SSTATE Heat Treatment Staandard Refere enced Requirem ments for Permits or
Notification
T314‐c: 71.1
1 °C for 75 min
nutes (not exxplicitly
Floridaa Certification
n and Master Permit
stated in quaarantine)
New Hampshire T314‐a: 60 °C for 60 minu
utes Certification
n
New Yo ork T314‐c: 71.1
1 °C for 75 min
nutes Certification
n
Oregon n T314‐a: 60 °C for 60 minu
utes Not explicitlly stated
Pennsyylvania T314 (any fe
ederal treatment therein) Certification
n
Certification
n and Advance
Utah T314‐c: 71.1
1 °C for 75 min
nutes
Notification
Vermo ont T314‐c: 71.1
1 °C for 75 min
nutes Certification
n
ANALYSES
The sscience and data
d associate
ed with heat disinfestation
d n, heat‐treatm
ment standard ds, and kiln ceertification is summarized
in thee appendicess under “Heatt Treatment.”” Please review
w for additio nal background informatio on.
Geneeral Benefit: Heat‐treatme
H ents kill insectts and pathoggens found inn or on firewo
ood. Industry creates a mo ore
phyto
osanitary prooduct. Regional and nation nal consistenccy in heat‐treaatment standdards benefitss states’ abilitties to
main
ntain forest prroducts markkets and support appropriaate regional ddistribution annd sales of firrewood.
T314
4‐ b: 56 °C forr 30 minutes
Advaantages:
Lowest standard and aligned
a with USDA
U gypsy moth
m and ISPMM 15 standardds.
If applied correctly is adequate
a for control
c of life
e stages of maany insects an
nd pathogenss.
A study fo ound it is adequate for conntrol of life stages of Asiann longhorned beetle1.
Encourage es broad partticipation by the
t industry.
Disad
dvantages:
Inadequatte for controll of pests such h as emerald ash borer as well as somee thermophilic pathogens.
1
Myyers, S.W. and
d S.M. Bailey. 2011. Evaluation of the ISPM‐15 Heatt Treatment SSchedule for A
Asian Longho
orned
Beettle, Anoploph
hora glabripennis (Coleopttera: Cerambyycidae) For. PProd. J. 61: 466‐49.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesT314‐a: 60 °C for 60 minutes
Advantages:
T314‐a is the current USDA emerald ash borer firewood standard, and is therefore used as a de‐facto standard
by many states. Emerald ash borer larvae are highly tolerant of elevated temperatures, potentially surviving the
levels required by T314‐b. T314‐a’s higher temperature and duration is required to provide adequate heat
disinfestation of emerald ash borer2.
Provides security that life stages of more insects and pathogens are controlled when compared to T314‐b.
Standard is achievable by a broad range of firewood kilns, even when seasonal conditions impact heat‐
treatment of firewood.
Disadvantages:
May provide incomplete control of some thermophilic pathogens, particularly those infecting the sapwood.
Please see Heat Treatment for more information about firewood heat treatment and thermophilic pathogens.
International firewood or firewood originating in a gypsy moth quarantine area is certified to T314‐b, which is
lower, and therefore states requiring T314‐a for entry would need firewood to carry additional certification to
comply with this standard.
T314‐c: 71.1 °C for 75 minutes
Advantages:
Highest treatment standard in the USDA’s Logs and Firewood T314 series. This is the standard referenced by
many of the states that were early adopters of exterior firewood quarantines.
Greater confidence about control of thermophilic pathogens and insects as well as those pests with
undetermined thermotolerance.
Greater confidence of adequate treatment when wood core temperatures are not measured or recorded.
Disadvantages:
Inability to certify firewood kilns unable or unwilling to run at these higher temperatures, particularly where
seasonality impacts heat‐treatment of firewood.
Regulating the industry to higher standards than necessary for many insects, nematodes, and pathogens –
including some that are adapted to survive periodic high heat. Please see Heat Treatment for more information.
Requires increased communication to producers and certifying agencies about higher treatment standards.
Firewood from sources with lower treatment requirements (international firewood, firewood originating in a
gypsy moth or emerald ash borer quarantine area, firewood certified under a T314‐a aligned state‐based
program) would need additional certification to comply with this standard.
HEAT TREATMENT STANDARD RECOMMENDATIONS
1. Explicitly state heat treatment standards by temperature and duration.
2. Explicitly state standards are as measured in the core of the firewood.
3. Require that heat‐treated firewood is certified by a federal, state, or 3rd party organization.
4. Require that treatment, supply, and sales records are maintained and auditable by a certifying agency.
5. Consider use of the T314‐a: 60 °C for 60 minutes standard as the required standard.
6. Consult with stakeholders if considering the higher T314‐c: 71.1 °C for 75 minutes standard.
2
Sobek, S., Rajamohan, A., Dillon, D., Cumming, R.C., & Sinclair, B.J. (2011) High temperature tolerance and thermal
plasticity in emerald ash borer Agrilus planipennis. Agricultural and Forest Entomology 13(3): 333‐340.
Revised Jan. 2020 Page |9
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesSample Definitions
(a) "Treated firewood" means any firewood certified as heated to 60 °C (140 °F) for 60 minutes at wood
core, OR
(b) "Treated firewood" means any firewood certified as heated to 71.1 °C (160 °F) for 75 minutes at wood
core, OR
(c) "Treated firewood" means any firewood certified as heated to 56 °C (133 °F) for 30 minutes at wood
core.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesD. COMPLIANCE AGREEM
MENTS
Summ mary Statement: A Compliance Agreem ment is issued d by a state tto provide oveersight of fireewood in trad
de in their
statee. Compliancee Agreementss may be issue ed to processsors or transpporters of fireewood and prrovide opporttunities for
indusstry to contin
nue legal trade in firewood d. Compliance e Agreementss can supportt a state’s regulatory progrrams and/or
best managementt practices recommendatio ons. But, theyy may not enttirely eliminaate risk. A Com mpliance Agreeement may
not bbe recognizedd by other states. This is paarticularly tru
ue for Compliaance Agreements that aree based on do ocumenting
moveement of firewood rather than addresssing risk mitiggation. Complliance Agreem ments may bee part of a staate’s firewood
d
Certification Program.
The tterms of the Compliance
C Agreement
A may allow exclusions based on type of firewood, origin of firewood,
timin
ng of delivery, or additionaal processing of uncertified
d wood, such as heat‐treattment, seasoning, or de‐barking.
The CCompliance Agreement
A may include use of labels, foorms, or otheer documentaation, as well as requiremeents for
treattment recordss.
ANALYSES
Variaability in the use
u of Compliiance Agreem ments exists between statees depending on the pests and pathogeens of
concern as well ass the firewood economy in n the area. In most cases, tthe Complian nce Agreemen nt defines wh
hat articles
are regulated, the e state or fede
eral regulatio
ons applicablee to the quaraantine, and th
he specific conditions undeer which the
mateerials may be moved. Many states are familiar
f with Compliance
C Agreements through their use as part o
A of the emeraldd
ash bborer program m. States withh internal emerald ash borrer quarantinees have based their Comp pliance Agreemments either
looseely or directlyy upon the USSDA APHIS PPQ Emerald Assh Borer Com mpliance Agreeement. This iis advantageo ous when a
pest or pathogen is relatively widespread,
w as
a the Compliance Agreem ment is easily understood ffrom state to state. A few
statees have incorp porated the use
u of Compliaance Agreem ments as part oof an exteriorr firewood quuarantine. Thhere are
exammples of state Compliance Agreements in the append dices.
Beneefit:
Compliance Agree ements and associated training/advisorry materials aare valuable ttools to ensurre and demon nstrate that
ntity understaands the regu
an en ulations and the
t steps requ uired to legal ly move regu
ulated articless. They clearlyy describe
which articles are regulated, th a the treattment or mitiggation requirred to move the articles.
he applicable codes/regs, and
Advaantages:
States cann require trainning and veriffy that entitie
es are able too comply with
h the regulatioons prior to m
movement.
States maay require nottification and additional do ocumentationn of movemeent in the form m of permits.
Records in n the form off permits or chain‐of‐custo ody documentts allow tracee backs in thee case of an inntroduction of
a pest or pathogen.
Producerss of firewood have a produ uct that has been
b treated or mitigated so risk of intrroduction or sspread is
decreased d.
Risk mitiggation may result in a valuee‐added prod duct.
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1
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesDisadvantages:
States must communicate the need for a Compliance Agreement, so investment in outreach is necessary for
success.
State resources are needed to provide training and permitting. This demand may result in fees for cost
recovery.
Costs may result in small producers avoiding Compliance Agreements and attempting to operate outside of the
regulations.
COMPLIANCE AGREEMENT RECOMMENDATIONS
1. Consider your answers to the questions in the Regulatory Overview document. Base Compliance Agreements on
risks to trees in your state and whether oversight of origin of firewood, type of firewood, timing of delivery, and
additional processing will help to alleviate those risks.
2. Determine the terms and oversight of the Compliance Agreement within the quarantine or departmental policy.
3. Publicize the availability of Compliance Agreements to producers, trade groups, green industry and suppliers of
related equipment such as saws, wood splitters and trailers. Focus on the positives – Compliance Agreements allow
them to continue to work with regulated articles while mitigating the risk of spreading a pest or pathogen and
protecting their industry.
4. Incorporate training when signing an entity up for a Compliance Agreement. During that training, ask questions that
demonstrate how the entity can meet the Compliance Agreement requirements.
5. Develop and foster relationships with industry to improve communication and increase the likelihood of reporting
suspected outbreaks.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesE. CERTIFICATION PROGRRAMS
Summ mary Statement: A Certifiication Prograam is adminisstered by a sttate (where fiirewood is haarvested and//or
proceessed) to proovide oversigh ht of firewoood entering trrade in anothher state (wheere this produ uct is sold and d/or
distriibuted). Certiification Programs are how w states help their own prooducers meett the regulato ory requiremeents imposed d
by otther states. Sttates consideering a Certificcation Prograam should connsider the levvel of risk thatt their state ttakes on with
the p
program, as well
w as if it pro ovides sufficie t their statess’ firewood veendors to enccourage participation.
ent benefits to
ANALYSES
Certification Programs are currrently most appropriate fo wood produceers with kilns that are interrested in
or those firew
firew
wood heat‐tre eatment certiffication. Exemmption of certtified heat‐treeated firewood is relatively consistent among
existing external state
s firewood quarantines, as well as forf movemennt of firewood d across international bord ders.
Certification of firrewood kilns has
h been a ro ole that USDA A APHIS PPQ hhas performeed in many staates, and producers in
thosee states rely on
o the availab
bility of certiffication to me
eet the requirrements of otther states an nd purchasingg agents.
Channging federal regulations could impact the t continued d federal suppport of kiln ceertification, aand states sho
ould consider
whetther or not a Certification Program could be part of the t state servvices provided to firewood d vendors. Staates with
existing heat‐treatment kilns will
w likely face greater pressure to impleement a statee‐based Certiffication Progrram.
Certification Programs can be implemented
i d for certificattion other thaan heat‐treattment. These programs maay not deliverr
as much impact because the ce ertification off the product may not be aas widely reco ognized by otther states orr commercial
distriibutors. Certification Programs involve regulatory ovversight of treeatment cond ditions, review of documeentation, and
onitoring equipment. A Com
verifiication of mo mpliance Agreement can bbe used withiin a Certificattion Program to provide
enforcement of non‐compliancce. States req quiring certificcation of firew
wood for entry or sale willl have improvved
comp pliance if requ
uirements and standards are a provided in clear languuage within th heir quarantine.
Beneefit:
Certification Programs and associated training/advisory materials aree valuable too ols to ensure and demonsttrate that an
entity understand ds the regulattions and the steps require move regulateed articles to another state. They
ed to legally m
clearrly describe which
w articles are regulated
d, the applicable codes/reggs, and the trreatment or m
mitigation req
quired to
movee the articles..
Advaantages:
States cann require trainning and veriffy that entitie
es are able too comply withh the regulatio
ons prior to m
movement.
States maay require nottification and additional do ocumentationn of movemeent in the form m of permits.
Records inn the form off permits or chain‐of‐custo ody documentts allow tracee backs in thee case of an in
ntroduction of
a pest or pathogen.
The Comp pliance Agree ement in the Certification
C Program
P is thhe enforcemeent documentt that assuress a receiving
state thatt, in the eventt of a violation, the state of
o origin will ffollow up with
h regulatory aaction.
Producerss of firewood have a produ uct that has been
b treated or mitigated so risk of intrroduction or sspread is
decreased d.
Completio on of the treaatment processes within th he certificatioon program mmay result in a value‐added d product.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesDisadvantages:
States vary in certification requirements. States with higher standards for certified firewood, such as using
71.1°C (160 °F) for 75 minutes as a heat‐treatment standard, requiring pre‐notification, or additional reporting
requirements may limit participation.
States vary in their ability to oversee Certification Programs, including limitations on personnel, training,
calibration equipment, cost‐recovery for the program, etc.
Costs may result in small producers avoiding a Certification Program and attempting to operate outside of the
regulations.
CERTIFICATION PROGRAM RECOMMENDATIONS
1. Determine if there is an industry that would benefit from implementation of a Certification Program, and how the
state could implement a Certification Program.
2. Determine the terms and oversight of the Certification Program within the quarantine or departmental policy.
3. 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.
4. Incorporate training with certification. During that training, ask questions that demonstrate how the entity can meet
the certification requirements.
5. Develop and foster relationships with industry to improve communication and increase the likelihood of reporting
suspected outbreaks.
Revised Jan. 2020 P a g e | 14
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesF. DEFINING FIREWOOD
D
Summ mary Stateme ent: States shoould considerr how firewood is defined. TThe definition n of firewood ccan include in
nformation
abouut intended usse, size, and exxclusions of otther raw wood products. Broad definitio ons of firewoo
od provide add ditional
proteections from pests
p moved in n other raw wood
w productss, but can incrrease oversigh
ht by regulatory agencies. TThe public hass
a cleaar idea of how
w to define and recognize firewood – it iss burned in their fireplaces,, wood stoves, and fire pits.. Broad
defin
nitions that incclude other raaw wood prod ducts may confuse wood prroducts industtries and conssumers.
Tablee: Elements In ewood Definitions
ncluded in Fire
SPEECIFICALLY EX
XCLUDES
TYPPE OF FIREWO
OOD
STA
ATE INTENTION
N/USE SIZE O
OTHER RAW W WOOD
COVERED
PRODUCTTS
Cut wood produccts
Floridaa Any length Wood of any speciees Yes
intended for burn ning
New Thatt which is desstined for
Any length Wood of any speciees Yes
Hampsshire use as fuel
Thatt which is desstined for
New Yoork Any length Wood of any speciees Yes
use as fuel
In a form and size e
appropriate for useu for fuel Less than 48
Oregonn Wood of any speciees Yes
woo od uses such as a home inches
heatting or campffires
Meaant for use in a
Pennsyylvania cammpfire or other outdoor Any length Wood of any speciees Yes
or in
ndoor fire
For use as fuel fo or fires in
open pit, grill, fireplace,
stovve, or other wood
w
burnning furnacess or Less than 48
Utah Wood of any speciees No
deviices in any form inches
commmonly used for f
burnning in campffires,
stovves, or fireplaces
Used in residential,
recrreational, or
Less than 48
Vermoont commmercial wood burning Wood of any speciees Yes
inches
appliance or firep place
indooor or outdoo or
ANALYSES
Nearrly all states define
d firewoood by intent or
o use (e.g., fiirewood is woood that is inttended to be used as a fueel). This alignss
the regulatory deffinition of fire
ewood with the commonlyy understoodd definition off firewood. In ncluding inten nt in the
firew
wood definitio on helps to se
eparate the reegulated articcles from otheer raw wood products. Ho owever, a defiinition
incorrporating inteent can resultt in enforcement challenge es. Intent can be difficult to prove unlesss the article already exists
as cu
ut and split firrewood. Likewwise, intent may
m change ass the productt is moved alo ong the supplly chain.
Manyy states include length resstrictions whe
en defining firrewood (e.g., firewood is less than 48 inches in lenggth). Including
g
lengtth of firewood
d in a definition may focuss the regulatio
on primarily oon consumerrs of recreatio
onal or ambiaance
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5
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood Guidelinesfirewood, which is typically moved in stove lengths. Firewood purchased by processors or used for structure heating can
also be delivered in longer lengths. States where firewood is regularly imported as tree‐length may want to consider
opening the firewood definition to include any length of wood.
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. For instance, firewood under the federal emerald ash
borer regulation includes all hardwood firewood as a regulated article. This definition excludes softwood firewood from
the regulation. This differentiation can help a state focus on the forest resources currently at risk, but it also presents
challenges when considering the long term potential for new threats‐ which may or may not include the excluded
classes of wood. States with diverse urban and/or natural landscape forests, should consider regulating all types of
wood. Further, regulating only a species or type can create difficulties and confusion when encountering mixed species
loads or debarked products.
Some states also specifically exclude certain other wood products from the firewood definition. 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. Excluding other wood products can help provide a focus on
firewood by clearly stating what is not considered firewood.
Benefit:
Defining firewood exclusive of other wood products helps ensure that states are clearly communicating what wood
products are regulated by a firewood quarantine. Consideration of how firewood is transported into a state should help
a state determine how to maintain the focus on firewood.
Advantages:
Maintains focus on firewood. Firewood is a high risk pathway compared to other wood products because:
o It is moved both commercially and recreationally; it is a broad pathway that can be challenging to target.
o 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.
o Firewood is used incrementally, increasing the time over which pests may emerge.
o Firewood generally undergoes very limited processing, resulting in fewer opportunities to kill or destroy
all life stages of pests.
o Firewood is frequently subdivided and spread to additional destinations, increasing the area over which
pests may emerge.
o 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. Communication about
the goal and purpose of the quarantine is facilitated by clearly defining firewood.
Revised Jan. 2020 P a g e | 16
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesDisadvantages:
Other types of unprocessed wood products may pose a risk, but may be excluded from the firewood definition.
For instance, bark‐on, log cross‐sections sold on craft vendor websites like Etsy are transported around the
country for decorations. Some nurseries use unprocessed wood to support balled and burlapped nursery stock.
This may be transported between states without consideration of the risk that it may pose. Excluding these
types of products from a firewood regulation does not address these risks.
FIREWOOD DEFINITION RECOMMENDATIONS
Defining firewood can help states clearly communicate the goal and purpose of the regulation.
1. Firewood definitions should include a statement of intent, e.g. to be used as a fuel.
2. There should be further detail on how firewood is defined:
a. 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.
b. States should put some consideration into whether or not they specifically want 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.
3. States should consider clarifying the firewood definition by specifically listing types of products not considered
as firewood, but rather as “other wood products”.
Sample Definitions
Firewood
(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.
Not Firewood
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:
i. sawmill for dimensional lumber;
ii. pulp and/or paper mill s;
iii. wood pellet manufacturing facilities;
iv. plywood manufacturing facilities;
v. wood biomass‐using refineries or power plants;
vi. re‐constituted wood or wood composite product manufacturing plants;
vii. wood transported to be chipped for either mulch or compost;
viii. facilities treating firewood in accordance with heat‐treatment standards;
Revised Jan. 2020 P a g e | 17
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesG. LABELING
Summ mary Stateme ent: States sho
ould considerr requirements for labeling firewood thatt are consisten nt, clear, and iin plain
langu
uage. Labelingg can identify heat treatmen nt standards to
t regulators aand the publicc. Labels also assist in identtifying
certiffying authorities. Firewood distribution companies
c strruggle with meeting varied labeling requ uirements from m multiple
states. Where posssible, there sh hould be a foccus on using plain language in labeling reequirements raather than staate‐specific
langu
uage.
Tablee: Labeling Re
equirements
Label Language Explicit within
w
SSTATE Label R
Requirementts
Qu
uarantine
Certiificate indicatting compliannce with Florida’s Firewood and
Unprrocessed Woood Products rrules, Chapteer 5B‐65, F.A.C C. This shall
inclu
ude:
Allowable firrewood in Maaster
Name
N of the pproducer/shipper under compliance
Floridaa Permit Systeem requires a
Compliance
C A
Agreement nu umber issued to them by tthe state of
certificate
origin
o
Statement
S inddicating that tthe product mmeets the req
quirements
of
o 5B‐65 Flori da Administrrative Code
Firewood
F labeeled as treateed to standards of 60 °C (1
140 °F) for
60
6 minutes
Exempted heat treated Display
D APHISS or State Dep partment of AAgriculture au
uthorization
New Hampshire
firewood req
quires labelin
ng and
a Compliannce Agreemen nt number
Company
C namme
Bulk
B firewoodd shipments aalso have labeeling requirem ments
Exempted heat treated “Neww York‐approoved treated ffirewood/pesst‐free”, or
New Yo
ork
firewood req quires labelin
ng phyttosanitary cerrtificate, or pllant health ceertificate
Firewood harvested and a
sold in th
he Pacific “Approved
“ Paacific Northweest Firewood” is sourced w wholly
Northwe est does not need
n within
w the Paccific Northweest and outsidde of declared
d
to be lab
beled. quarantine
q arreas for invasive species. In
ncludes recorrd keeping
Oregon
n There is optional labe eling requirements
r s.
for untreeated Pacific “Approved
“ Peest Free” firewwood is heat treated to 600 °C (140 °F)
Northwe est firewood. for
f 60 minutees or equivaleent treatmentt approved byy Oregon
Treated firewood may be Department
D oof Agriculturee.
labeled.
Exempted trreated firewo ood Kiln
K Dried andd/or USDA Ceertified
Pennsyylvania
requires labeeling Producers
P namme and addreess
Labeling for all firewood, and Based
B on weigght and meassure of firewo ood
advance nottification of Origin
O of firew
wood
Utah
firewood shipments into the Treatment
T of firewood
state Exporter
E and importer info ormation
Firewood
F labeeled as treateed to standards of 71.1 °C (165 °F) for
Label is one option for 75
7 minutes
Vermo
ont
certification of treatmentt Name
N and ph ysical addresss of heat treaatment facility
Name
N of certiifying agency
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8
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesANALYSES
Label requirements by states are mostly associated with information about meeting a heat‐treatment certification
process, or in some cases, about origin of firewood. Labels can be used by regulators, law enforcement, and the general
public to identify firewood that is deemed to be compliant by a certifying authority. Labels should be as easy to read as
possible, and consistency in label requirements makes compliance easier.
Labels, certificates, and other documents may be subject to fraudulent use. Labels that require company information,
the certifying authority, and certification number make it easier to identify and confirm firewood as legitimately treated
and labeled.
Requiring use of the USDA shield on heat‐treated firewood can be problematic. Kilns located in areas that are not
regulated for a federal pest may not qualify for federal certification and heat‐treatment monitoring. Requiring use of a
federal shield on labels can have the unintended consequence of favoring firewood originating in known quarantine
areas. Although state regulatory agencies may understand the nuances associated with use of the federal shield,
purchasing agents and the general public do not. Clear labels with identifying information should be preferred rather
than emphases on shields and other graphics.
Benefit: Ready identification of compliant firewood.
Advantages:
Makes it easy for enforcement officers to identify compliant firewood.
Makes it easy to perform trace backs.
Makes it clear that the producer is aware of standards and requirements.
Consistent information on labels increases adoption by industry.
Communicates standards to the public.
Disadvantages:
Inconsistency in labeling requirements, such as state‐specific language, makes it challenging for the industry to
comply.
Labels are dual purpose and are used by industry for marketing. Required regulatory information must be
legible.
Claims such as “Bug Free”, “Free of all pests”, or “Seasoned Wood” are not verifiable and don’t reflect the
treatment process.
LABELING RECOMMENDATIONS
1. Explicitly state treatment requirements in plain language.
2. Consistency across states will make it easier for the industry to comply.
3. Regulatory language should be of a size to be legible on the label.
4. Plain language indicating the requirements for the applicable Compliance Agreement should be favored over use
of shields or graphics.
Clear Sample Language:
This firewood has been certified heat‐treated to a core temperature of 60 ˚C (140 ˚F) for 60 min [or other preferred
standard]. Certifying agency: State or Federal Department of__________________. Certification number_____________.
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https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesUnclear Sample Language:
“[State]‐approved treated firewood/pest‐free”
“Product meets the requirements of [regulation #] [State] Administrative Code”
“Meets State of [State] standards”
Revised Jan. 2020 P a g e | 20
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesH. ENFORCEM
MENT
Summ mary Stateme ent: States sho
ould considerr their potential enforcemennt approaches. Enforcing a firewood quaarantine can
be chhallenging andd enforcement capacities caan vary widelyy between staates. Some of the regulatoryy and enforceement
strateegies common nly used by states may be effective
e with commercial transporters o of firewood, bu ut may be chaallenging
when n addressing the
t movement of recreation nal firewood. The approachh to recreation nal firewood ttransportation n may require
e
particcipation from other agenciees within your state. Howevver challenginng, the efficaccy of the quaraantine will be enhanced
throuugh transparency about pen nalties and ennforcement. Sttates with Plaant Inspectionn Stations and established in nspection
progrrams could readily integratee external fire
ewood quaran ntines into exissting enforcem
ment activitiees. Other statees may need
to pu
ut some consid deration into their
t approacch to enforcemment of an extternal quaranttine. Appendix B includes sseveral state
exterrior firewood quarantines.
q These
T example quarantiness contain penaalty and enforrcement langu uage, and thoose states’
SPROOs could servee as referencess for questions about their enforcement strategies.
Case Study: Maine
e
Mainne has an eme ergency order that is admiinistered by the Maine Forrest Service (MFS) within tthe Departmeent of
Agricculture, Conseervation and Forestry. The
e Maine Forest Service proovides forest rangers who enforce statee forestry
laws,, including the
e firewood emmergency ordder. Most enforcement occcurs during eevents scheduled by the M MFS, Division
of Fo
orest Health, visits
v to camp
pgrounds, andd inquiries fro
om the publicc. Events usuually occur at public rest arreas on the
New Hampshire‐ Maine border and are scheduled to coincide with naational holidaays including Memorial Daay, July 4th and d
Labor Day. These e are the time
es when people are comingg to Maine too open or closse summer co ottages, or to visit
camp pgrounds thro oughout the state
s from eaarly summer through
t the faall. Rangers aalso spend thee summer seaason
randomly visiting campgrounds, focusing on n campers with out‐of‐statte plates. The MFS also haas a link and a phone
numb ber allowing the
t forest ranngers to respoond to reportted concerns about out off state firewoo od.
Case Study: New Hampshire
H
New Hampshire’s quarantine is shared betwe een the Department of Agrriculture, Marrkets & Food aand the Deparrtment of
Natural and Culturral Resources.. The Departmment of Naturaal and Culturaal Resources’ fforestry laws provide autho orities for any
y
law eenforcement agency
a in the state to enforrce forestry laaws, includingg the firewood
d quarantine. W
While other laaw
enforrcement agenncies are involved in enforce ement of the firewood quaarantine, the p primary entityy involved in p
planning
enforrcement evennts and issuingg warnings and summonsess is the NH Divvision of Foressts and Landss, Forest Rangers.
The N NH Forest Ran ngers have enforced the staate’s firewoodd quarantine oon both comm mercial transp porters of firew
wood and
thosee moving firew wood recreationally. While individual Rangers may stoop vehicles wiith out‐of‐statte plates movving firewood,
and cconduct camp pground inspe ections, the bigggest impactss have been w
with scheduled d firewood checkpoints. These have
includded checkpoints during higgh traffic weekkends (like Me emorial Day oor Labor Day), as well as during the NASC CAR races at
the NNew Hampshirre Motor Spee edway (NHMSS), which are thet largest camping eventss in the state. The NHMS haas been a
critical partner in these
t events. These events have required substantial planning to ensure enforceement of indivvidual
violattions while minimizing the impacts to traaffic flow. Multiple agency partners, both state and feederal, have p participated in
this eeffort. Firewoo
od has been inntercepted froom as far awaay as Florida aand the Pacificc Northwest. TThere have beeen several
intercceptions fromm EAB quaranttine areas, butt none from ALB
A quarantine areas. The eenforcement events, as req quired by
statee statute, are publicized
p ahe
ead of time. The NHMS hass placed inform mation about firewood ontto their website and in their
mailings. Year afteer year of conttinued enforceement has seen a reduction in the numb ber of individu
uals bringing ffirewood into
the state. Firewoo od collected du
uring the checckpoint is burnned on‐site att a monitoredd location.
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1
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesConsiderations for planning a firewood checkpoint include:
Is a court petition required for the checkpoint? (For checkpoints along public roads, the New Hampshire Attorney
General’s Office requires a petition be brought before the Superior Court for approval.)
How much staff will be needed and is there authorization for their time and potential overtime for the event?
Will other agencies be involved, like DOT, local police departments, and property jurisdiction and access like the
NHMS or the USFS for events that occur in the White Mountain National Forest?
What can partners contribute? Will there be subject matter experts that can provide identification of insects or
insect damage?
Will there be a facility for staff to process violations and take breaks throughout the event (i.e. a command trailer)?
What safety equipment will be necessary for those staffing the events?
What are the confiscation documentation requirements for the violation to have legal standing (i.e. paperwork,
photography, etc.)?
What signage will be required?
How will the public be notified?
What permissions are necessary to conduct the event?
Will there be an outreach component (e.g. brochure) for occupants of all stopped vehicles, regardless of firewood
found?
Will the firewood be confiscated as part of the event?
If confiscated, how will it be transported and destroyed?
Are permits needed for destruction of confiscated firewood?
Will firewood vouchers for replacement firewood be provided, and if so what is the available budget?
Revised Jan. 2020 P a g e | 22
https://nationalplantboard.org/ >>> Documents and Policies >>> Firewood GuidelinesYou can also read
