| OTO No. | 640 | Classification | METI-(1) | |
|---|---|---|---|---|
| Date of Acceptance | May 17, 2001 | Ministry/Agency Receiving Complaint | Cabinet Office | |
| Responsible Ministries | Ministry of Economy, Trade and Industry | Related Laws | Industrial Standards Law | |
| Complainant | United States Embassy in Japan (Proxy complaint) | Exporting Countries | USA | |
| Subject | Review of the "qualitative standards and testing methods of wood preservatives" (JIS K 1571) | |||
| Description of Complaint |
1. The "qualitative standards and testing methods of wood preservatives" (JIS K 1571), part of Japanese Industrial Standards based on the Industrial Standards Law, prescribes test methods etc. of injection preservatives for wood. According to the standards, the test subject, a wood piece that has had a preservative injected into, must be cleansed repeatedly in water (an operation for weatherproofness) before the preservative's resistance to decaying bacteria is measured, based on the idea that wood preservatives should preserve their performance even in an environment in which wood is constantly exposed to water. 2. The United States wants to export wood preservatives made of boric acid salts (for preservation from decay and protection against insects and moths) and woods treated by boric acid salts for preservation from decay and protection against moths. Since wood preservatives made of boric acid salts maintain their water-solubleness after being injected into wood, the test method mentioned above causes boric acid salts in the subject piece to dissolves into water, with the result that they cannot satisfy the performance requirements. 3. However, boric acid salts are useful as a wood preservative, mainly because (1) they are effective in preventing all types of decaying bacteria, wood eating insects and white ants, (2) they have low toxicity for humans and (3) they are inexpensive. They have been used for a long time in developed countries as wood preservatives in sites that do not touch the earth and are not subject to exposure. A recent Japanese report also says, "If boric acid salts are only used in sites that do not touch the earth and are not subject to exposure, they can control all living things that will decrease the quality of wood." So far, there has been no reports published that refute this report. 4. An increasing number of countries have been adopting the concept of hazard classes: appropriate wood preservatives and treatment conditions should be chosen in compliance with the environment in which the wood is used. The subcommittee on the durability and preservation of wood of the International Organization for Standardization is currently reaching an agreement on the classification of five hazard classes. Taking account of such an international trend, the "qualitative standards and testing methods of wood preservatives" (JIS K 1571) also provides for an operation for weatherproof performance of wood preservatives as "Attached Document (for reference): Another weatherproof operation." It exempts the weatherproof operation of stirring the subject wood piece in water for eight hours, leading us to believe wood preservatives made of boric acid salts can clear the standard of preservative performance. 5. However, since the Attached Document has as the precondition that an international standard is accepted, the Recording Method of the performance of preservatives must include the statement: "This preservative performance is based on the Attached Document (for reference): Another weatherproof operation. It does not satisfy the original qualitative standards." This still does not allow boric acid wood preservatives to meet the qualitative standards of the "qualitative standards and testing methods of wood preservatives" (JIS K 1571). 6. Therefore, we request the Ministry of Economy, Trade and Industry to recognize boric acid wood preservatives as satisfying the qualitative standards of the "qualitative standards and testing methods of wood preservatives" (JIS K 1571) as well as change the mandatory statement above of "This preservative performance is based on the Attached Document (for reference): Another weatherproof operation. It does not satisfy the original qualitative standards." to "This preservative performance is based on the Attached Document (for reference): Another weatherproof operation." in the 4.6. Recording Method of the Attached Document." |
|||
| Details of Measures |
1. The ministry forwarded its reply as follows: Taking account of the deliberations at the ISO on whether to make an international standard of the "durability and preservation of wood" based on a European standard, the ministry added the "Attached Document (for reference): Another weatherproof operation", which is in compliance with ISO/DIS, to the JIS in question (a revision of JISA9201) when it was established in 1998. It was intended to be the first step for introducing environmental classifications. However, since the ISO did not reach an agreement on a draft international standard in this field, the ISO, in order to accommodate the demands of the countries concerned, began by promoting deliberations on setting up an international framework for classifying the durability of wood, based on environmental classifications. Recently, the TC165 (the expert committee on wood structure) of the SCI (the subcommittee on the durability and preservation of wood) reached an agreement on the direction of new environmental classifications (hazard classes) and decided to promote deliberations for establishing an ISO standard related to wood preservatives. Japan is promoting the consistency of the JIS, based on a WTO agreement and has a policy for making the JIS consistent with any international standard on qualitative standards and testing methods corresponding with environmental classifications by the ISO. 2. Following the response above, the complainant made a request for the ministry to specify the progress in and prospects for the matter in the ISO as well as a timetable expected by the METI. The ministry's response was as follows: "In the "weatherproofness and preservation of wood" field of the ISO, deliberations are under way for an international framework for classifying the durability of wood based on environmental classifications. At the TC165/SCI in May this year (2001), a direction was agreed as to environmental classifications (hazard classes), which had been a pending question. After surveying intentions of the countries concerned on future deliberations, the ISO is going to make deliberations toward establishing an ISO standard in the field at the next meeting of the SCI (May next year) and after. The ministry (the METI) will review JISK1571 in an appropriate manner at a proper time while paying attention to the movements for establishing a future ISO standard." 3. The complainant made a further statement described below. Japan's agreement to the concept of environmental classification at the TC165/SC 1 subcommittee can be described as a change of direction in its basic policy, not just an accommodating movement toward the classification of environments in which wood preservatives are used. This change paved the way for boric acid salts, which had been positioned only as an insect repellent, being approved as agents for preventing decay and white ants. The necessity for introducing environmental classifications (hazard classes) has been discussed by Japan's academy for preservation of wood and the businessmen concerned and the revision in 1998 added "Attached Document (for reference): Another weatherproof operation to JIS K 1571, considering the movements for establishing an ISO standard. The acceptance this time around of the ISO environmental classifications no longer gave Japan a proper reason for excluding non-adhesive wood preservatives. However, because it seems difficult to establish a new system for regulating wood preservation in a short period of time, the United States of America requests Japan to take measures described below as relief measures for corporations dealing in non-adhesive wood preservatives. 1) Japan is requested to introduce as soon as possible a temporary standard as a relief measure for corporations dealing in non-adhesive wood preservatives, a separate move from the movements for establishing an ISO standard (for example, the transfer of the Attached Document of JIS K 1571 to the main text of the standard). 2) Upon review of JIS K 1571, scheduled in 2003, we would request Japan to accurately reflect the agreement made at the TC165/SC1 subcommittee in May this year. 4. The response of the ministry to the statement above: The ministry plans to make considerations for reviewing Japanese Industrial Standards related to wood preservatives including the standard in question in the next fiscal year, because the ISO has reached an agreement on environmental classifications (hazard classes) and JIS K1571 will reach its term for reviewing in 2003. During the process, the ministry plans to look into the handling of the Attached Document of K1571, which states: "an operation for weatherproofness for wood preservatives that has a small possibility of being provided with water but has the possibility of being put into an environment that has abruptly become highly humid. Incidentally, Japanese Industrial Standards are not mandatory standards, but voluntary ones. Since their adoption is at the discretion of those concerned, it would not be fair to say that Japan excludes corporations dealing in non-adhesive wood preservatives for the reason that no test method is prescribed in the standard for non-adhesive wood preservatives. |
|||
| Classification of Processing | Cc | Directions | I-a | |
| Remarks |
A written reply was made on June 7, 2001 A written reply was made on September 28, 2001 (to the opinion of September 18, 2001) A written reply was made on December 17, 2001 (to the opinion of December 4, 2001) | |||