Pallets and FSMA: the devil is in the details

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

The FDA mentions pallets repeatedly as possible sources of cross contamination

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.