July-August 2016

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16 PalletCentral • July-August 2016 n April 6, 2016, the Food and Drug Administration (FDA) issued its Final Rule on Sanitary Transportation of Human and Animal Food. This rule requires many entities that ship, load, carry, or receive food to use sanitary practices to ensure that food safety is not compromised during transportation. You may be asking yourself, "What does this have to do with me, I'm a pallet manufacturer?" Pallets are considered "transportation equipment" under the Final Rule. Therefore, pallet suppliers have an obligation to ensure that pallets are designed and maintained so that they are suitable and adequately cleanable for their intended use, in order to prevent food from becoming adulterated. From 2007-2012, Texas state health officials, under contract from FDA, inspected Blue Bell ice cream company facilities. This was brought on by 10 people being hospitalized in four states with illnesses linked to Blue Bell ice cream products. Inspectors noted cleanliness and maintenance issues as contributing factors to violations of food safety protocols. The pallet was not the cause of the outbreak, but was named as part of the investigation. Thus, it is important to educate yourself, company, and customers on the responsibilities outlined by the FDA Final Rule and know your respective obligations and exposure under the regulation. FDA, in issuing the Final Rule, recognized the longstanding value that FDA'S SANITARY TRANSPORTATION FOR PALLETS INDUSTRY O Compiled by Patrick Atagi, NWPCA, with assistance from Stuart M. Pape, Polsinelli law firm. Stuart helps clients understand and face challenges presented by regulations imposed by the U.S. Food and Drug Administration (FDA), U.S. Department of Agriculture (USDA), and similar health and safety regulatory bodies worldwide. FDA'S SANITARY TRANSPORTATION FOR PALLETS

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