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NWPCA Releases Proposed Pallet Handling Guidelines, Hopefully the Pallet Sanitation Discussion Will Return to Common Sense
Amid a lot of hype and concern, the wooden pallet industry responds to sanitation and mold concerns by releasing draft handling and sanitation standards.
By Rick LeBlanc
Date Posted: 9/6/2011
In the propaganda war that has been waged against wooden pallets in recent years, it has been hard for many from the wood pallet community to keep their blood from boiling. Wooden pallets were made the scapegoat by iGPS in its pallet sanitation survey, Johnson & Johnson and its 2010 recalls that it blamed on a taint coming from a chemical used to treat pallets in Puerto Rico, and some lawmakers who were trying to address this made-up crisis seeking a real problem.
“The crisis that occurred in the pharma industry from an alleged contamination of drug products from a wooden pallet caused a great deal of concern to many of our customers… It increased our workload in trying to quell the fallout and defending our non-chemical processes with repeated requests for documentation,” Don Baldwin of General Pallet, Readington, NJ, commented to Pallet Enterprise earlier this year. “It also seems highly unlikely that the problem arose from a wooden pallet in the first place and hardly possible, that if it did, it involved a pallet from the USA.”
All the bad press for wooden pallets has left customers scrambling for answers. Some pallet users are overly paranoid even asking for guarantees, certification and testing that goes beyond any measure of reason.
And Now Pallet Swabbing?
In recent months one Virginia pallet maker was asked by a customer to start taking swab tests of pallets. Contacting numerous experts for this story, we found it difficult to get someone who would even comment on the need for swab testing, or how a pallet company might approach it. A sales person for one private lab in Arizona told Pallet Enterprise that of course they would be happy to perform sampling for a pallet company, but as tertiary packaging, why would anyone want them to do this? “Environmental testing (swabbing and plating) gives one an idea of risk associated with pallets,” added Martin Bucknavage, senior food safety extension associate for the Department of Food Science at Penn State University, “but that is one pallet out of 50 or a 100 that a facility may use and not good for actual control.” Martin did emphasize that it is important to differentiate between pallet usage during production or for direct food contact than for tertiary packaging, which we return to later in this report.
When asked about how he thought pallet companies should approach such requests as swabbing, Michael McCartney of QLM Consulting (www.qlmconsulting.com) encouraged pallet industry members to take a broader, more proactive approach than simply reacting to specific customer requests such as swab tests, which he sees as being more symptomatic to a lack of confidence in the system rather than in addressing the underlying issue of restoring confidence in the product itself.
Indeed, while pallet people may feel like they are alone under the harsh glare of the food safety spotlight, the reality is that everyone involved is under scrutiny from the proverbial field to fork. This includes the agriculture industry, food processors and logistics providers. McCartney suggested that the pallet industry might be well served by looking at proactive efforts in other industries to restore customer confidence, such as the California Leafy Green Products Handler Marketing Agreement.
With growing concern about food safety, California farmers organized to address the issue in 2007 through the establishment of the California Leafy Green Products Handler Marketing Agreement (LGMA), with a goal of working collaboratively to protect public health by reducing potential sources of contamination in California-grown leafy greens.
With over 100 participating firms, LGMA represents approximately 99% of the volume of California leafy greens. Member companies commit themselves to selling products grown in compliance with the food safety practices accepted by the LGMA board. Verification of compliance with the accepted food safety practices is required through mandatory government audits. With food safety practices developed by university and industry scientists, food safety experts and farmers, shippers and processors, LGMA has developed a unique system that has provided a model for leafy green growers in other states. (It is worth mentioning as an aside, that while this proactive food safety initiative lists detailed program requirements at its website in terms of foods safety practices, it has nothing that speaks about pallet selection or handling.)
Ralph Rupert of Virginia Tech’s Center for Unit Load Design agrees that the pallet industry would be wise to take steps to increase customer confidence. But he does not believe that mandatory measures, such as the approach used by leafy green growers requiring mandatory audits, are the best course of action for the pallet industry. Ralph has been raising the issue of pallet handling best practices for over a year. At the last MH1 pallet standards meeting, the group discussed drawing up a best practices guideline.
While Ralph emphasizes that it would not be a standard, “there is nothing that would prevent this committee from putting out a separate document under the auspices of MH1 and calling it a best practices type of document.” This guideline would likely cover cleanliness, storage and handling practices.
Ralph said, “The wording is going to be fairly contentious because so many pallet mills do not have storage space to store pallets inside.” As part of MH1, the committee would want to make it inclusive of pallets made of all materials.
“There are some wheels turning to get that done, but as you are well aware, those wheels turn slowly” Ralph continued, “but at least there is some action taking place, and I would say that it is our proposal, to start drawing up that document.”
The National Wooden Pallet & Container Association (NWPCA) has also been active in tackling the pallet sanitation issue. It put together a blue ribbon panel that has developed best practices which were recently released to the pallet industry for review.
Bruce Scholnick, president of the NWPCA, commented in the April/May issue of Food Logistics magazine. He said, “This initiative will help eliminate any concerns people might have about using wood pallets because there will be guidelines on how to handle pallets properly. This will help contain costs across the board because it will minimize the potential of recalls when pallets—of all materials—are handled properly throughout the supply chain.”
Shane Thompson, pallet division president of Westwind Logistics has been one of the leaders of that NWPCA effort. He sees their role as trying to tone down the rhetoric that has been stirred up by iGPS and the drug industry, “basically trying to get out ahead of it and putting forth suggestions that are doable and not going to add a lot of cost and a lot of unneeded processes,” he said to Pallet Enterprise. “Pallets are not intended to be a direct contact product.”
The best practices include visual inspection and then if pallets arecontaminated, then they can be power washed and re-entered back into the system. Pallets stored outside would require re-inspection before loading. Shane envisions that sorted pallets would be loaded onto enclosed trailers and then sealed. A record would be kept of each trailer in case there is any problem, so it could be traced back. Shane emphasized that they would like to see the quality assurance program take place at the load level and not at the individual level which might require something along the lines of an individual pallet stamp. “It’s just what this industry needs is another stamp,” Shane said wryly.
When asked if he envisioned a 3rd party auditing process for a pallet supplier’s pallet inspection process as being part of a NWPCA guideline, Shane said that he does not. He suggested that this is something that could be arranged between customer and pallet provider if this was a customer requirement.
Independently, many companies already incorporate a cleanliness inspection as part of their process for specific customers, scraping and pressure washing pallets as necessary to remove stains or residue. As might be expected, companies such as CHEP and others have formal standard operating procedures for pallet quality. In the case of CHEP, this involves the removal of stained components and washing where needed. Any visible foreign material is removed from the pallet, as is debris, such as shrink-wrap, cardboard, slip-sheets, stickers, staples and tape. Any CHEP pallet that cannot be repaired to meet the inspection criteria is removed from the pallet pool.
In fact, shortly after reaching Shane for comments, the NWPCA released a draft copy of its Good Handling Practices. See the entire document as an attached sidebar to this article starting on page 59. Pallet industry members are encouraged to review the document and contact the NWPCA to comment before it is finalized and released for distribution to pallet customers.
Intended Usage Matters
For applications exposed to processing, however, hygiene is an important issue. “Pallets, or really anything brought from outside, can be an issue in certain facilities,” commented Martin from Penn State. “The biggest risk is when pallets are brought into areas where there is post-process exposure of the final product. Facilities go to great lengths to keep environmental contaminants out of these areas - people change boots and clothes, designated forklifts or hand jacks never leave the area, floor foamers are used to decontaminate wheels and feet, etc.
“But pallets are an unknown as far as what they bring into the plant. The concern of where the pallets were stored or what was previously held on the pallet is on the mind of QA managers.”
According to Martin, the two big concerns when pallets are used in dry food operations are with Salmonella and Listeria. He said Salmonella can be a concern if pallets are held outside and are exposed to bird droppings. Likewise, Listeria can be a concern, especially if pallets had been used to carry animal products.
“Research has shown that wood has natural antimicrobial properties that do not allow organisms to grow, and even reduces them. But if there is a glob of material on the pallet, there may be no protection from the wood’s antimicrobial effect....such as a bird dropping. Older pallets have less of an antimicrobial effect than new wood.”
This point of view is generally consistent with the perspective of other quality assurance professionals. As part of the research for this story, we monitored quality assurance online forums with respect to conversations about pallets. Generally speaking, manufacturing areas are strictly controlled across the board, ranging from forklifts to footwear to pallets, and wood pallets are not welcomed in the manufacturing process by those who commented. And for post-process exposure, such as in decanting product from one container to another, again wood pallets are not recommended. Post-production, however, wood pallets are generally accepted for storage and distribution, although as part of the facility’s HACCP plan, pallets should be visibly clean, dry and in good repair, thereby posing no danger of product exposure by puncture or moisture transfer.
Going forward Martin stresses the need for manufacturers to isolate their manufacturing process from distribution, and for pallet suppliers to have good quality assurance programs, as well as for additional research with respect to the risks posed by debris left on pallets.
At the end of the day, what quality assurance practitioners are looking for sounds a lot like the programs being suggested by NWPCA and the MH1 committee, which is good news. By establishing sound quality assurance programs, the pallet industry can take a huge step towards diffusing anti-wood pallet rhetoric and building customer confidence.
NWPCA Good Handling Practices – Principles and Recommendations
Guiding Principle I
Manufacturing Clean Safe Pallets
The industry produced more than 400 million new pallets in 2006. It is recommended the following procedures be implemented by new pallet manufacturers that serve the food and pharmaceutical industries:
• Source(s) of raw materials (lumber, fasteners) should be identified (local or imported from other countries) and properly handled prior to manufacture. Certain wood preservatives or fungicides (e.g. tribromophenol/TBP, trichlorophenol/TCP, pentachlorophenol/PCP) must not be used to treat against mold or present in the lumber components.
• Pallet components (i.e. deckboards, stringerboards, stringers, blocks) should be properly handled during the manufacturing process (cutting into size, assembly)
• 100% inspection of new pallets and containers. Exposed nails/shiners and broken boards must be rejected.
Moisture in wood as it pertains to mold growth and product contamination is an issue for new hardwood pallets. Most, if not all, hardwood pallets are assembled using “green” (above 30% moisture content) components. Since lowering the moisture content down to 19-25% requires time and energy, hence added cost, an alternative is to use softwood pallets since the lumber components are kiln-dried to 19%.
Guiding Principle II
Handling/Sortation Practices for Reused, Repaired,
The wood pallet industry also process about 300 million recycled pallets annually. Recycled pallets can be considered as used, repaired (replaced a component) or remanufactured (disassembled and reassembled using new and/or recycled components). Accordingly the following handling guidelines are recommended for pallet recyclers:
• Incoming pallets should be inspected, sorted then processed (i.e repaired, disassembled or discarded). During repair, disassembly or assembly, the recycled pallets will be inspected as they go through the processing line.
• Contaminated pallets are set aside for cleaning (e.g. power washing) Recycled pallets, regardless if it is hardwood or softwood, have moisture content less than 15% which prevents or practically eliminates mold growth unless the wood surface is rewetted. The major issue with recycled pallets is no one can tell where a pallet or its components came from (in terms of country of origin or the industry in which it was previously used).
Guiding Principle III
Cleanliness Standards for
New & Recycled Pallets
It is highly recommended that both new and recycled pallets be “household clean” which means they are free of any foreign material (e.g. dirt, debris). Visible mold growth and/or blood should be removed by washing with a mild detergent.
Pallet cleaning is done through these steps: full wash, rinse then dry. Power washing/jet spray is the preferred washing procedure. The rinse and dry steps can be accomplished by air blades, forced air drying or air drying.
Guiding Principle IV
Storage and Handling for
Warehouses, Distribution Centers, Retailers
It is strongly recommended that pallets be maintained in a dry atmosphere. Indoor storage is the preferred method and damp and cold storage should be avoided. All pallets that have been stored outdoors must be reinspected prior to shipment/delivery at all times. Pest mitigation procedures should be coordinated with pest control service providers.
Guiding Principle V
Shipping New & Recycled Pallets
Pallet providers should use clean trailers and flat beds for deliveries to avoid contamination of pallets. The “No daylight” rule for containers will be enforced. Trailers are immediately pulled from the dock and should be sealed after loading to secure the cargo. Records for every outbound trailer must be kept and maintained including:
• Date of loading, and time of departure
• Quantity of pallets
• Forktruck operator and truck driver