Technical Bulletin No.14 - BioGro

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BioGro New Zealand Technical Bulletin Issue 14 | November 2010Questions and AnswersQuestions and Answers on the prohibition of treated posts and timber on properties certified to the USDA NOP and/or the COR:Refer notification on this in the Inputs – all sectors section of this Technical Bulletin. The following questions and answers apply toproperties which are certified / in conversion to the NOP and/or COR. They do not apply to properties which are certified / in conversionto BioGro but are not also certified / in conversion to the NOP and/or COR, but these properties may elect to comply with theserequirements if they wish.Q: Which types of production are affected by this ruling?A: All primary production properties which are certified / in conversion to the NOP and/or COR, including dairy farms, sheep and beeffarms, cropping farms, orchards, and vineyards.Q: Which uses of posts and timber are affected by this ruling?A: All uses including fences (end assemblies, stays, posts and battens), livestock housing (calf houses, milking sheds, hay sheds,stock yards), crop support and artificial shelter structures on orchards and vineyards, crop structures such as greenhouses andraised beds, packing sheds, and bins and other containers for harvesting fruit, grapes, vegetables and other crops.Q: Does this affect existing fences, buildings, crop structures, and bins etc on my NOP or COR certified / in conversion toproperty ?A: No, existing fences, buildings, crop structures, and bins etc are ok, this ruling applies to repairs of existing fences, buildings, cropstructures, and bins etc, and to new fences, buildings, crop structures, and bins etc.Q: Can the runners underneath, or any other part of, new fruit bins brought onto the property be treated timber?A: No. Existing bins in use which were constructed using treated timber for any parts of them can continue to be used, but new binscan not be constructed using treated timber for any parts of those bins.Q: Boundary fences are legal requirements and are usually maintained also by the neighbour who may not be certified / inconversion to the NOP and/or COR. Can treated posts and timber be used for boundary fences for properties which grazecertified livestock (dairy farms, sheep and beef farms, orchards or vineyards which graze livestock) provided an internalfence using allowed materials such as steel posts and wires is run inside the NOP / COR certified / in conversion propertyand will ensure that the certified livestock can not contact the boundary fence ?A: Yes you can apply to BioGro to decertify that strip of land. The internal fence must be permanent and effective (such as apermanent electric fence) so the stock can’t graze to the treated post boundary fence, typically the decertified strip should be atleast 1m wide. Just outriggers on the boundary fence are not acceptable. We would also encourage planting of trees in thedecertified strip.Q: Can boundary fences and artificial shelter constructions on boundaries of orchards, vineyards, and cropping propertiesbe built or maintained using treated posts and timber provided there is a buffer strip inside the NOP / COR certified / inconversion property ?A: Yes you can apply to BioGro to decertify that strip of land. If certified livestock graze that property then the Q & A immediatelyabove applies. If certified livestock don’t graze that property then an internal fence is not required but there must be a buffer zoneinside the boundary fence / artificial shelter construction such as a headland, ideally at least 4m wide.Q: Can fences and artificial shelter constructions within certified/conversion properties such as orchards, vineyards, andcropping properties be built or maintained using treated posts and timber ?A: No we don’t believe it is practical, or would be acceptable to USDA, to have decertified areas within a certified property for thisreason.Q: Can buildings such as machinery and implement sheds be built using treated posts/poles and timber ?A: If the area in and around the building can effectively be a decertified area, ie certified livestock and products can not / do not enterthat area, then this can be considered. In general this will only be possible when such buildings are on the perimeter, or outside, ofthe certified area of the property. In general it will not be able to be considered when the building is within the certified area of theproperty. We encourage NOP and COR certified farms, orchards, and vineyards to look for ways of building without using treatedposts/poles and timber in order to meet the spirit of these export regulations.8 of 14
BioGro New Zealand Technical Bulletin Issue 14 | November 2010Q: What about hay and feed sheds, either within a certified property, or outside of a certified property ?A: Hay sheds and feed sheds are storing certified feed so treated posts/poles and timber can not be used to repair and/or build hayand feed sheds.Q: What about packing sheds, either within a certified property, or outside of a certified property ?A: If the area in and around the packing shed can effectively be a decertified area then this can be considered. In general this will onlybe possible when the packing shed is on the perimeter, or outside, of the certified area of the property. In general it will not be ableto be considered when the packing shed is within the certified area of the property. We encourage NOP and COR certified farms,orchards, and vineyards to look for ways of building without using treated posts/poles and timber in order to meet the spirit of theseexport regulations.Q: Can treated posts and/or timber be used to build or repair stock yards and stock loading ramps?A: No, because the certified stock can/will be in contact with them at times.Q: Can beehives on the property be wholly or partly constructed using treated timber, such as the runners underneath thehives ?A: If the hive(s) is permanently on the certified property then repairs, or new hives made or brought in, can not use any treated timber.If the hive(s) are brought onto the certified property for the pollination period only then removed then they may contain treatedtimber.Q: Can I move an existing fence and reuse the treated posts, or dismantle a crop structure or livestock housing and reuse thetreated posts / timber elsewhere on my certified property ?A: If your property is NOP certified / in conversion then no. If your property is COR certified / in conversion and not NOP certified /conversion then theoretically you can do the above. However we don’t recommend this, as in general properties certified / inconversion for North American markets should comply with both the NOP and the COR to ensure that both markets are open toyour products.Q: If I have new and/or already used treated posts and timber stored on my property can I use these after 1 July 2010 ?A: If your property is NOP certified / conversion then no. If your property is COR certified / conversion and not NOP certified /conversion then theoretically you can do the above. However we don’t recommend this, as in general properties certified /conversion for North American markets should comply with both the NOP and the COR to ensure that both markets are open toyour products.Q: If I have new or old or broken etc treated posts and/or timber stored on my property which aren’t in use and won’t beused, do I have to remove them ?A: We can’t require them to be removed but suggest you should remove them asap to simplify management and auditing of theseNOP and COR requirements. If new or old treated posts and/or timber are stored on your property and won’t be used then typicallyyour auditor at your annual audit will issue an RFA to remove them at some stage over the following year.Q: Cross arms on crop support structures such as for kiwifruit and pipfruit are not in contact with soil or certified livestock,can they be replaced or repaired using new treated timber ?A: It could be argued that this meets the wording of the NOP, but the USDA have made it clear to NZFSA that treated posts and timbercan not be used for any uses on NOP certified / conversion areas of a property. The COR doesn’t allow this so our replyimmediately above also applies, ie we recommend that properties certified / conversion for North American markets should complywith both the NOP and the COR to ensure that both markets are open to your products.Q: Can treated posts covered with a compliant material such as a plastic be used ?A: No, our understanding is that treated posts, even if covered in some way, can not be used on NOP and COR certified / conversionproperties.Q: Can we use posts and timber not tanalised (copper chrome arsenate) but treated with other treatments ?A: At this stage we are not aware of any other post and timber treatments being used in New Zealand which comply with the NOP and/or COR. Note that some materials such as copper hydroxide, sodium tetraborate, and sodium octaborate which are listed asallowed in the NOP may be worth considering as timber preservatives, but this would require our prior assessment and writtenapproval.9 of 14
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Technical Bulletin No.14 - BioGro

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