Are your pallets ready for the Food Safety Modernization Act (FSMA)

3/24/2016

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.

If your business has revenues over $500,000.00 a year, expect a visit from the FDA.

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.

9 Comments

Martha I Gallego Ward link

11/9/2016 03:02:34 pm

I have customers that buy pallets asking if they will be impacted by this new regulation? or does this impact only the manufacturing companies of pallets?

Hartson Poland link

11/10/2016 03:01:32 pm

Hey, Martha

Thank you for asking. Certainly if your customers are using the pallets to transport, hold or store food they should be fully aware of the impact of the FSMA. If all of the food is fully sealed in packaging, not much would changed. The FDA has always wanted pallets in good repair, easy to clean and not to pose a hazard in themselves. If they are using pallets to transport food that is not fully packaged (such as fresh produce, for example) the pallets should also be able to be sanitized, and should be between uses. Larger companies are hiring FSMA officers to assure full compliance with the act. As all situations and uses are unique, we always suggest checking in with the FDA to get a final determination on any question that seems difficult to assess. A response from them in writing and on file can go a long way if a question is ever raised further down the road. Thanks again

Hartson

Mark D

12/11/2017 06:15:57 pm

Can we use wooden pallets for dry goods storage and boxed food storage in a walk-in freezer?

Hartson link

12/11/2017 07:31:36 pm

Mark,

Thank you for checking in. The FDA has always stated that any pallet used for storing food, even in sealed containers, would need to be in good repair, easy to clean and not pose a hazard in themselves. There is no prohibition of wood pallets in any of the FDA regulations, and as long as they are clean and in good repair, they would be in compliance in your freezer. Having said that, if you are required to frequently clean your walk in, you might want to consider using plastic pallets as a best practice. The absorbent nature of wood can make it difficult to keep clean, and by definition, that is what the FDA wants. As all situations and uses are unique, we always suggest checking in with the FDA to get a final determination on any questions that seem difficult to assess. A response from them in writing and on file can go a long way if a question is ever raised further down the road. Thanks again

Yaw-Kuen Lin

1/5/2018 11:18:33 am

Hartson,
can the regrind HDPE be food-grade compliant? How the resin and pallet manufacturer be certified for food-grade pallet?

Hartson link

1/5/2018 11:55:02 am

Greetings, Yaw

And thank you for your inquiry. Regrind HDPE can be "food grade" as long as the material does not contain any intrinsically hazardous substances. It would be up to the material producer to certify that this is the case. A MSDS on the material would want to be on file. Full contact FDA compliant material is another story. If the pallet in question would be expected to be in direct contact with unpackaged food on a regular basis, the material from which that pallet is made would need to have been compounded under the regulations set forth by the FDA for full product contact. FDA (Title 21 Section 177.1520). As long as a molder had documentation that any regrind came from a source in compliance with this regulation, I see no reason why it would not be acceptable.

It is important to note that for fully packaged foods, as long as pallets are clean, in good repair, and not a hazard in themselves, the FDA will be satisfied. The FSMA does want pallets to be sanitized between uses when used to transport open containers of food stuffs such as fresh produce. And if full product contact is anticipated, the MATERIAL from which a pallet is molded would need to be FDA compliant for that purpose.

As all situations and uses are unique, we always suggest checking in with the FDA to get a final determination on any questions that seem difficult to assess. A response from them in writing and on file can go a long way if a question is ever raised further down the road. Thanks again

Hartson

yawkuen Lin

1/5/2018 12:06:05 pm

Hartson:
Thanks,

Yaw

Anne

7/25/2018 02:42:39 pm

Does the FDA require slip sheets on wood pallets for finished goods shipping, packaging or ingredient storage and handling?

Hartson link

7/25/2018 10:06:09 pm

Greetings, Anne

And thank you for your inquiry. For fully packaged food, pharma or ingredients meant for human consumption, the FDA does not require an additional barrier between that packaging and a pallet. Certainly if the pallet is not in good repair, or poses a threat by nature of being dirty or otherwise unsafe, no slip sheet or any other barrier is going to make the FDA happy. What the FDA wants to see are pallets that are clean, in good repair and not hazardous in themselves. If you are concerned that nails or splinters from a pallet may pierce or tare packaging, perhaps a slip sheet might not be a bad idea, but again, not a regulation. As all situations and uses are unique, we always suggest checking in with the FDA to get a final determination on any question that seems difficult to assess. A response from them in writing and on file can go a long way if a question is ever raised further down the road. Thanks again

Are your pallets ready for the Food Safety Modernization Act (FSMA)

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