Generally not given much more thought than the wood or plastic from which they are made, pallets have received a great deal of attention in the last year. Even putting aside the “mud-slinging,” lawsuits, and counter suits between the defenders of wood and plastic, the pallets are getting attention from federal and state regulatory agencies as well as various consumer groups.
On the regulatory side:
- A pending proposed rule from the USDA Animal and Plant Health Inspection Service (APHIS) would remove the exemption from ISPM 15 on wood packaging material moving between Canada and the United States in both directions. The exemption currently allows wood packaging material to ship between Canada and the U.S. without first meeting the treatment and marking requirements of the ISPM 15 regulations that apply to wood packaging material to and from all other countries. If adopted, enactment would begin with a period of informed compliance, during which time wood packaging material that is not treated would be allowed to enter. However, the carrier would be notified that wood packaging will be required to comply once ISPM 15 is fully implemented.
ISPM 15 is Guidance for Regulating Wood Packaging Material in International Trade as developed by the International Standards for Phytosanitary Measures. According to an APHIS article, “Wood packaging material made of unprocessed raw wood is recognized as a pathway for the introduction and spread of pests.” Thus, ISPM 15 was adopted by the International Plant Protection Convention to limit the entry and spread of quarantine pest through international trade.
- In May, New Jersey reintroduced a bill (A3936) to regulate the use of pallets in shipment and storage of certain agricultural commodities, foods, drugs, and medicinal products. Identical to A3141 introduced and withdrawn in 2010, the bill would require that pallets used for storing or transporting raw agricultural commodities, foods, drugs, and medicinal products:
- have a moisture content below 20 percent;
- have been cleansed and sanitized using an approved method;
- have been maintained in a manner designed to minimize the likelihood of contact with contaminants; and
- have no protruding parts that could penetrate into the commodity, food, drug, or medicinal product.
While federal and state governments hash out such regulations, the pallet industry itself is working to continually improve the safety of pallets—both wood and plastic.
Wooden Pallets. Four years ago, the National Wooden Pallet and Container Association (NWPCA) approached USDA/APHIS with an unusual request: “We said we want to be regulated,” said NWPCA President and CEO Bruce Scholnick. The association wanted domestic pallets to be regulated by the same standards as those required of imports, he said.
As a part of this, APHIS held forums and conducted an environmental risk assessment. Just this summer, APHIS returned with its results stating that it had not found any valid data that wood pallets were responsible for the migration of non-native invasive species of pests (prevention of which is the primary purpose of ISPM 15 regulations). Thus, Scholnick said, USDA came back to NWPCA saying they wanted out of the equation; that there would need to be proof of risk before USDA would enact regulation.
In working with USDA, NWPCA also formed a task force to develop a certified process for wood pallets “to make certain that pallets designed for food are kept clean and dry,” Scholnick said. The program is to identify practices and be third-party inspected for compliance. It is also to include certification by the ISPM 15 inspection agency.
“The intention is to carry out best handling practices so that the FDA and EPA recognize that the industry is as concerned as they are with food safety and pharma safety,” Scholnick said. And with 1.2 billion wooden pallets currently in use in the U.S., and 93 percent of all goods shipped on wooden pallets, it behooves the industry to ensure the pallets are safe.
Plastic Pallets. Although the plastic pallet is still growing in use, the industry is continuing to refine its features and benefits to challenge the dominance of wood.
“There is a very significant difference in materials,” said iGPS CMO Lew Taffer, which makes the plastic pallet lighter and non-absorptive.
Further refinement of the pallets has been the addition of a bar code for tracking. “Each has a unique serial number so you can track the lifetime history of each,” Taffer said.
The bar coding works well with the current traceability initiatives, as any manufacturer that rents a pallet must scan it with the shipment, thus “marrying it to the shipment,” he said. In addition, iGPS pallets are maintained within a controlled group of users and are visually inspected after every use. If direct contamination or residue is evident on a pallet, it is washed using a high-pressure hose.
Because pallets are considered to be tertiary packaging, that is they do not directly contact food surfaces, neither sanitization nor contamination testing is required. Nor is it something the industry has requested, Taffer said.
However, he added, “It is important from a food safety perspective to maintain pallets in good condition.”
Food Safety Advice. To keep pallets safe for food, Scholnick recommended:
- When using new pallets, ensure that the supplier is not using potentially contaminating chemicals on them.
- Keep all pallets indoors in a clean, dry area.
- When chain of custody is lost on a pallet, it becomes the end user’s responsibility to ensure the incoming pallet meets all food safety standards—and when you are the end user and chain of custody hasn’t been validated, it is your responsibility to do so.
- Before using any pallet, inspect it for maintenance (broken boards, production quality, etc.) and cleanliness.
“The reality is that anything can get contaminated,” Scholnick said, “but there is no evidence that any foods have been contaminated by any pallets.” Wood or plastic.
The author is Editor of QA magazine. She can be reached at firstname.lastname@example.org.