the entity”). They further noted that provider” is only used in “treatment paragraph 73 of the the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures (2014-005), but is used many times in ISPM 15. The TPG noted that the treatment provider is a person or organization applying the treatment operating in a physical contruction (i.e. the treatment facility). Because could refer to the “entity” facility, the provider, or both, the TPG supported using provider” “treatment and facility” instead of “treatment when it was clear that the “entity” references in the draft ISPM were made to either the provider or the facility. They felt such an approach would be clearer, although they acknowledged it was not consistent with the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures The TPG supported “treatment provider” as in ISPM 15, rather than provider”. “fumigation 260 52 2. Fumigation entitiesproviders Australia See TPG 4. The TPG supported using The definition of providers as operators and provider” rather than “treatment facilities is confusing. provider”. “fumigation The operator can be a company or individual and provides the service to the fumigant. The
the entity”). They further noted that “treatment provider” is only used in paragraph 73 of the the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures (2014-005), but is used many times in ISPM 15. The TPG noted that the treatment provider is a person or organization applying the treatment operating in a physical contruction (i.e. the treatment facility). Because “entity” could refer to the facility, the provider, or both, the TPG supported using “treatment provider” and “treatment facility” instead of “entity” when it was clear that the references in the draft ISPM were made to either the provider or the facility. They felt such an approach would be clearer, although they acknowledged it was not consistent with the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures The TPG supported “treatment provider” as in ISPM 15, rather than “fumigation provider”. 260 52 2. Fumigation entitiesproviders Australia The definition of providers as operators and facilities is confusing. The operator can be a company or individual and provides the service to the fumigant. The See TPG 4. The TPG supported using “treatment provider” rather than “fumigation provider”.
TPG_Recommendations_2014-004_CompiledComments_DraftISPM_RequirementsFumigation_2018-01-02_oK0EVMO.docx