“We did what you asked, now you actually want us to write it down too?”

Yes. And, keep it in a file. And, have it available when the FDA inspector comes a calling.

“What does the documentation aspect of the FSMA have to do with pallets anyway? Haven’t we got enough to worry about keeping track of our hand washing?”

Well, let me explain more about the FSMA…

Establishing a food safety system

The Food Safety Modernization Act has been crafted to help prevent conditions that might make people sick. This means those facilities covered by the Act must establish and implement a food safety system that includes an analysis of hazards and risk-based preventive controls. The rule sets requirements for a written food safety plan that includes:

• Hazard analysis
  Considers known or reasonably foreseeable biological, chemical and physical hazards like broken, degraded or otherwise insanitary pallets.
    
• Preventive controls
  Includes process, food allergen and sanitation controls, as well as supply chain controls and a recall plan. All of these may require the use of pallets.
    
• Oversight and management of preventive controls
  Insures that preventive controls are effective and actually correct problems that may arise. Problems might include the use of difficult-to-clean pallets.

Pallets cannot be ignored
​
The purpose of FSMA documentation procedures is to make sure:

• preventive controls are consistently performed
• records are kept

Even minor, isolated problems require descriptive record keeping of corrective actions performed to reduce the likelihood of the problem ever occurring again. Ignoring pallets, perhaps the single most ubiquitous item in the supply chain, would be like ignoring the grass on a golf course.

​
FSMA records and written plans
“So what is it you want me to write down?”

When it comes to pallets, just about everything. Think of it as a cradle-to-grave operation.

When an incident happens, one of the first questions to be asked is, “where did the pallets come from?” Your complete records should be ready with:
  

• where the pallets were purchased
• the nature of construction materials
• the history and specifics about what was transported on the pallets in the past

  
You should also include a written plan for day-to-day pallet management including:

• processes for regularly inspecting the condition of your pallets
• procedures for insuring your pallets are sanitary
• a plan for corrective action in the event of an incident 

Verify Implementation
Writing the plan is only half of the equation. Records verifying your day-to-day implementation of the plan will need to be available to the FDA upon an inspection. The key word here is verification. And I can assure you my friend, if you did not write it down, it did not happen.  

Still have questions about FSMA documentation requirements and how they relate to pallets? Feel free to comment here or drop me a line.

Post by: Hartson Poland, Business Development - Plastic
Use of FDA Inspector photo is made available by the U.S. Food and Drug Administration.

OK, kids, we've talked about the Food Safety Modernization Act (FSMA) and what it means to the pallet world in general terms, but it is time to get specific.

We know that the FDA has traditionally insisted that pallets be:

• easy to clean
• non-toxic
• in good repair

So what has FSMA changed?

Under the section of the rule titled Sanitary Transportation of Human and Animal Food, shippers, carriers and receivers will be expected to develop policies and procedures to make sure that food items are temperature-controlled throughout their trip - AND - that transportation vehicles are cleaned and SANITIZED between loads. That’s right, SANITIZED between each load. And that goes for any equipment that might be used in the process.

If you're thinking pallets might be exempt, think again.

In even a brief review of recent FDA inspection reports, one will find pallets mentioned repeatedly as possible sources of cross contamination. 

Each company will be expected to perform a Hazard Assessment, and ignoring your pallets would be like ignoring the grass on a golf course. Pallets are everywhere in food transportation. The FDA likes to use the term touch points to describe areas of scrutiny - areas that will be expected to undergo constant improvement all along the supply chain.

If your pallets are:

• of unknown origin
• shredded, splintered or broken
• covered with food debris or grease
• incapable of being sanitized

then your pallets are not in compliance with the guideline-parameters of the FSMA.

Still not sure if your pallets are FSMA compliant?

Get on the horn with a pallet professional experienced with FDA requirements. Be sure to ask about low cost-per-trip plastic pallets that are:

• easily sanitized
• non-absorbent
• economical (low-cost-per-trip)
• easily recycled 

And, by all means, support the intent of the FSMA and the constant touch point improvement programs that it mandates. 

Not sure where to turn?

Post your FSMA questions or concerns here or give me a call. Also, watch for my next post: FSMA and documentation. Find out what documentation means for pallets and the companies that use them. 

Post by: Hartson Poland, Business Development - Plastic
Use of FDA Inspector photo is made available by the U.S. Food and Drug Administration.

FSMA enforcement begins summer 2016. Are you ready?

The Food Safety Modernization Act is a group of regulations signed into law in 2011. The act is meant to apply the best available science and good common sense to prevent the problems in food production, storage and transportation that can make people sick.

Why do we need new regulations? Isn’t our food supply safe?
Yes, for the most part it is. Still, one in 6 Americans become sick,128,000 are hospitalized and 3,000 die each year from foodborne diseases (CDC). The intention of this law is to prevent foodborne illness before it happens.

What will the FDA be looking for? 
The FDA puts it rather bluntly. They mention bacterial or chemical contamination caused by:

• Filth
• Decomposition 
• Unsanitary Conditions

What does this mean for pallets?
FSMA is broken down into 7 main sections, but for pallet use, it gets pretty simple:

• Preventive controls for human food
• Preventive controls for animal food
• Produce safety
• Sanitary transportation

Who will the FDA be inspecting?
Considering that pallets may well be the single most ubiquitous item in the food supply chain, it is not an overstatement to say that the FDA will be looking at YOUR pallets and how they will or will not contribute to your efforts to comply with the FSMA. To comply, your pallets must be:

• Easy to keep clean
• Non-toxic
• In good repair 

How should I prepare?
Have a plan. The FDA man will be going where no FDA man has gone before. Even if you have never seen an FDA uniform, be prepared. This act has teeth and congress has given the FDA the full funding they will need to use them. Whether you are a processor, shipper, carrier or receiver of food products, ask a pallet professional today about solutions available to keep you in compliance - before an inspection.

Still not sure if you're ready for FSMA? Post your questions or concerns here, give me a call and watch for my future posts on some of the important details of the FSMA that will be rolled out in the months ahead.

Post by: Hartson Poland, Business Development - Plastic
Use of FDA Inspector photo is made available by the U.S. Food and Drug Administration.

Here’s a hint that you might need an FDA pallet: you handle unpackaged food or other consumables.

If you read my last post, you learned that in some food applications you don't always need a blue FDA pallet. But, even when an FDA pallet is not required, the FDA still wants pallets to be:

• easy to clean
• non-toxic
• in good repair

Easy enough to comply for the packaged stuff. But, the rules change if you intend to use your plastic pallets for full product contact.

 
​​Let’s say you work in the processing area of a food producer and want to put a slab of curing bacon right on the pallet. You, my friend, need a plastic pallet that is made of material FDA certified for full product contact.

Isn’t plastic just plastic?

No. In fact, the FDA has set standards (Title 21 Section 177.1520) for:

• how certified plastic resins are produced
• how certified plastic resins are tested
• listing what substances will or will not react to that plastic resin

The manufacturer of any plastic article intended for full product contact needs documentation certifying that the resin used to produce that article complies with federal regulations.

Which pallet is right for you?

When deciding what type of plastic pallet is best for your application, first consider how it is going to be used. Next, communicate your product and contact specifics to a pallet professional knowledgeable in FDA requirements. Here's a simple test: is your unpackaged food item coming in direct contact with the pallet? If you answered, "yes" it means you'll need a pallet made of materials compliant with federal regulations. 

Need help figuring out which full-contact FDA certified material pallet is right for your application? Get in touch with me or post your questions below. I am glad to help. 

And, if you are in any link of the food or drug supply chain, watch for my next blog on the implementation of the Food Safety Modernization Act and what the FSMA will mean to you. 

Post by: Hartson Poland, Business Development - Plastic
Use of Pork Belly licensed under the GNU Free Documentation license.

Has searching for an FDA approved plastic pallet left you with confusion and sticker shock? Save money (and avoid buying the wrong pallet) with these tips for understanding what the FDA really wants in your pallet application.

You work with packaged food or pharmaceuticals and you've been told you need to purchase an inventory of FDA approved plastic pallets. You're not even sure you know what that means. Worse, the thought of complying with government regulations sounds complicated. Don't worry. Finding the right pallet is often easier than it first appears.

The FDA Code of Federal Regulations can seem confusing but it boils down to this: the FDA is concerned with the design, workmanship and material used in equipment meant to handle food and drugs (Title 21 CFR part 100.40).


What does this mean for incidental product contact?

• FDA pallets need to be easy to clean
  Hidden areas can trap debris or liquid which can foster contamination and bacteria growth causing adulteration of your product.
    
• FDA pallets need to be non-toxic
  The FDA does ban some substances outright and your pallets cannot contain them if they are to be used in a regulated facility.
    
• FDA pallets need to be in good repair
  Broken or dilapidated pallets can become part of the dangers of contamination rather than part of the solution. Broken pallets become hard to keep clean and pieces of broken pallets can end up in product.

Bottom line from the FDA on plastic pallets

When asked specifically about pallets, the FDA has answered repeatedly that for incidental product contact, a pallet must simply not pose an intrinsic hazard. Easy, right? It doesn't even have to be blue. For most applications, the less expensive standard black Plastic Pallet will be approved for use in FDA regulated applications.

So now you know the basics for using plastic pallets in FDA regulated facilities. When there is general, incidental product contact, a standard plastic pallet may be all you need. If your product contact is not incidental, please watch for my next post: FDA Pallets for FULL PRODUCT CONTACT.

Still not sure about which plastic pallet will work best for your FDA requirements? Get in touch with me or post your questions below. I am glad to help.

Post by: Hartson Poland, Business Development - Plastic