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March-April 2019

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palletcentral.com PalletCentral • March-April 2019 13 Questions from Pallet Manufacturers Q. What is a "food contact" article? Are pallets or wooden crates considered food contact articles? A. A food contact article is an item that comes into direct contact with food. A wooden crate may be a food contact article if it is used to carry unpackaged raw produce, for example. Typically, a wood pallet would not be a food contact article, because it is most frequently used to hold and transport food items that are packaged in cans, boxes, or other packaging, and the pallet does not come into direct contact with unpackaged food. Nevertheless, companies may be concerned with the use of chemicals on pallets, even if the pallets will not be used with unpackaged foods, because of the frequency with which pallets are brought directly into food facilities or manufacturing facilities. While these companies may want to prevent mold growth on pallets that will enter their facilities, they may also be concerned that the chemicals used to treat the pallets may contaminate the food inside those facilities. Therefore, as both a legal and a practical matter, when considering what antimicrobial chemicals may be used to treat pallets, crates, or other wood items that will be used in connection with food, it may be advisable to view all such items as though they were "food contact" articles in order to determine which chemicals can lawfully be used, and for purposes of responding to customer inquiries. By using only substances approved for use on food contact articles when treating pallets (and wooden crates), one is able to ensure food industry customers that the pallets are safe for their use.

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