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July-August 2016

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wooden pallets provide in transporting food from place to place. We are pleased that FDA, appropriately, continues to permit the use of wooden pallets as a safe and efficient food transportation option. Pallet suppliers have always been committed to providing their customers with well-designed pallets that allow them to move food products easily and safely within and between facilities. We take our responsibilities under the new rule seriously and look forward to continuing to provide our customers with the high quality products and service they have come to expect from us. Below are some commonly asked questions specific to wooden pallets, written with the assistance of the Polsinelli law firm in Washington, DC. FDA's Sanitar y Transpor tation Final Rule: What Makers of Pallets Should Know Q: How are pallets regulated under the Final Rule? A: Under the Final Rule, pallets are considered "transportation equipment." They must be designed and maintained in a way that makes them suitable and adequately cleanable for their intended use, so that food does not become unsafe during transportation. Q: How do I know that wooden pallets won't damage my food packaging? A: Our members are careful to monitor pallets for any jagged edges, splinters, raised nail heads, or other damage that could potentially tear or puncture food packaging. However, no one can guarantee against the possibility that pallets could become damaged during shipping or storage. Therefore, it is always a sound practice to examine pallets before use. Q. Can wooden pallets be stored outside when they are not in use? A: Yes. FDA permits outdoor storage, as long as the pallets, when they are used, will not cause food placed on them to become unsafe. Ultimately, if you store them outside, you should be aware of your responsibilities when you bring them into your facility, and decide what level of cleaning is required to make the pallets suitable for their intended use, which may depend on what type of food will be on the pallets and whether any visible contaminants are present. Q: When I return an empty pallet to my pallet supplier, am I shipping "food"? A: No. FDA has stated that empty food shipping and storage equipment is not "food" under the Final Rule. When you return a pallet to a pallet supplier you are not subject to the Final Rule's requirements. palletcentral.com PalletCentral • July-August 2016 17

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