Don't ignore pallets in your FSMA documentation

“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…

The FDA needs written verification you're actually implementing your day-to-day pallet management plan.

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
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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.

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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.