6 replies to this topic

[QAfood]

Our facility had a non compliance due to our wood pallets not being heat treated. I know for a fact that our owner will not shell out money to change our wood pallets for HT ones. I am not sure if this is in 21CFR 111.

I am trying to look up any FDA regulations if this is a major non compliance or can we just say that monitoring pest around the wood pallets are enough, rather than changing our hundreds of wood pallets that we have.

Does anyone have any solution for a corrective action to this? Thank you!

[john123]

When you say non-compliance for non-heat treated pallets, what standard is that held against? I find nothing in 21 CFR 111 requiring heat treated pallets.


Beyond that, if the concern is pests infecting an untreated pallet, there's no guarantee that a heat treated pallet wasn't subject to infestation after it's treatment. Our facility uses a trailer inspection form on received material. This helps us to prove we are monitoring things prior to allowing them into the facility, and ties into pest control too. I think something like that along with a visual inspection of pallets during your pest control checks could be sufficient (even if an auditor doesn't think it's ideal).

[Wine Gum]

DearQA Food

Weonly use pallets that were heat-treated according to ISPM 15 regulation Each pallet is stamped with the supplier’sregistration no + HT, showing it is heat treated.

International Standards For Phytosanitary Measures No. 15(ISPM 15) is an International Phytosanitary Measuredeveloped by the International Plant Protection Convention (IPPC)that directly addresses the need to treat wood materials of a thickness greater than 6mm, used to ship products between countries. Its main purpose is to prevent the international transport and spread of disease and insects that could negatively affect plants or ecosystems. ISPM 15 affects all wood packagingmaterial (pallets, crates, dunnages, etc.) requiring that they be debarked and then heat treated or fumigated with methyl bromideand stamped or branded,^[1]with a mark of compliance. This mark of compliance is colloquially known as the "wheat stamp". Products exempt from the ISPM 15 are made from alternative material, like paper, plastic or wood panel products (i.e. OSB, hardboard, and plywood).



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Hope this helps.

Regards

Makayla

[QAfood]

Thank you!

The auditor concentrated on our pest control criteria. He observed that most of our pallets our not heat treated and told us we need to have them all heat treated. I Our facility do have a procedure on inspecting receive materials. I do not know if they will accept that. We will see. Thank you again!

When you say non-compliance for non-heat treated pallets, what standard is that held against? I find nothing in 21 CFR 111 requiring heat treated pallets.


Beyond that, if the concern is pests infecting an untreated pallet, there's no guarantee that a heat treated pallet wasn't subject to infestation after it's treatment. Our facility uses a trailer inspection form on received material. This helps us to prove we are monitoring things prior to allowing them into the facility, and ties into pest control too. I think something like that along with a visual inspection of pallets during your pest control checks could be sufficient (even if an auditor doesn't think it's ideal).

[D-D]

Anyone got any examples of issues that occurred because pallets were not heat treated?

[RMAV]

(Quote is an excerpt of orginal message).

International Phytosanitary Measuredeveloped by the International Plant Protection Convention (IPPC)that directly addresses the need to treat wood materials of a thickness greater than 6mm, used to ship products between countries.

QAfood,

Does your facility ship products on pallets internationally?

[QAfood]

Yes we do.
This corrective action was under 21 CFR 111 Subpart C-There are adequate precautions agains contamination by micro, chemicals, filth or other extraneous materials.

Auditor observed some perimeter of the warehouse are dirty along with non heat treated wood pallets.

I am still unsure as to how to submit the non heat treated pallets.

(Quote is an excerpt of orginal message).


QAfood,

Does your facility ship products on pallets internationally?