Wood Pallets in Production Area
Hello,
We manufacture dietary supplements and are SQF certified. We have always had a policy that stated only plastic pallets were allowed in the clean rooms during production. I was questioned today if we could stage product on wooden pallets . I initially replied no as they are a source of contamination. I looked into it, however, and I am seeing other places that this may be permitted? Is there anything stating that the use of wooden pallets in clean rooms is prohibited. I believe we were told this by our auditor in a previous audit a few years back.
Never heard of such prohibitions. It's up to you what skids to use as soon as they're under control to prevent product contamination. Plastic pallets are quite heavy, and I haven't seen many companies to use them due to that reason. Wooden pallets are lighter and not that slippery as plastic ones.
The new Version of the SQF code has guidance documents structured differently but this this is pulled from the SQF V8.1 guidance document, Go to Page 65) **Shown at the very bottom**and refers specifically to the foreign material management of wooden pallets. I think as with any other topic you're unsure about, conduct a risk analysis. If you think you can mitigate or eliminate the possible risks, then start using them.
At our facility we have an inspection program. Pallets have to be inspected prior to being brought into the facility for production. You can also purchase only certain grades of pallets, but that process can get expensive.
Go to Page 65.
"Wooden pallets are part of the food industry and are not expected to be banned from processing environments. Depending on the type of operation and the products being produced, the types of controls for the management of pallets can vary from one site to another. At a minimum, all general processing facilities should have a pallet management program in place where pallets undergo inspection for broken slats or wood pieces protruding which could pose a risk to products. If pallets are stored for prolonged periods outdoor, then the pallets may need to be cleaned and inspected for vermin prior to entry into the processing area. For high-risk operations and wet processing environments, the use of clean slip sheets or plastic pallets may be utilized to help to minimize the risk of foreign material or microbiological contamination to the products."
YNA, what does your inspection program look like for pallets? Do you have a form you use?
IMEX (seafood) "wood" is typically, strongly, recommended to be avoided within the Production areas with the (reluctant) exception of final stages where product is fully packaged.and palleting is obligatory. Auditors IMEX invariably agree with such a minimal philosophy.
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The reason for avoidance is simple hygiene 101 - BCP Contamination Risk.
IMEX control/prevention of contamination ex wooden pallets is not easy due supply variabilities.
Where usage is sometimes unavoidable, eg palleted raw material inputs, ingress/stripping is, as far as possible, carried out with documented, visual surveillance during post-production hours via defined, restricted, non-production interactive routes
A risk assessment would be useful in this case to justify your decision (approve/decline the use of wooden pallets). A monitoring and verification programme will also need to be put in place if wooden pallets have been approved to use.
I was thinking that I would add a pallet inspection on our Trailer Inspection Form. Also, add a pallet inspection on our morning Pre-Op Walk through. Also, I could add a pallet inspection section on the production batch record showing that we are inspecting them prior to entering the clean room? Does anyone think that this would work for SQF?
Good morning Sarah,
Back when I ran an SQF facility, this meant that all pallets in the food handling area (sugar bagging) were only allowed for that area, and once they left (warehouse, etc.) they were no longer fit for that purpose. We actually used plastic pallets for this purpose and had a company who would sanitize them for our re-use.
I can't imagine much has changed since then, nor could I imagine that could be R/A'd away since it's a pretty direct code.
Maybe someone under the current scheme can chime in.
Tim,
To give more context, we would basically take our pallets of Bulk Powder into the room on wooden pallets, (after inspection) sieve the material back into its original container and place the containers/drums on the pallets to go back out. We wouldn't be re-using the pallets as they would get sent right back out. I am not finding anything per the FDA saying that we cannot use wooden pallets. We have 50 pallets of bulk powder drums and that is a lot of material to move to plastic pallets just to eventually place it back on wooden pallets to go out if that makes sense. I am trying to find an alternative to doing this. This would not be something that we do for everything, just this bulk powder as it takes a ton of pallets to stage compared to our other products.
Here's your answer
V9.0
17.7.3.6 Wooden pallets and other wooden utensils used in product processing and handling areas shall be dedicated for that purpose, clean, and maintained in good order. Their condition shall be subject to regular inspection.
You get determine what regular inspection is, follow the KISS method
One spot (like at receipt) for pallet inspection should suffice
Does that mean that I cannot take pallets into the room that the product came in on if inspected, process and ship back out ? The pallets will not "stay" in that room. But they also will not be coming back in once they go out.
Same textual clause as Post 8 has this 8.1 (wood) guidance -
wood.PNG 46.19KB 0 downloads
(repeating Post 3)
IMEX BRC are less "flexible".
Hey Sarah, no it wouldn't be an FDA requirement. I thought you were asking under an SQF scheme though?
Does that mean that I cannot take pallets into the room that the product came in on if inspected, process and ship back out ? The pallets will not "stay" in that room. But they also will not be coming back in once they go out.
I've yet to work in a facility where raw materials were un-stacked onto a different pallet in order to come into production. As long as your raw material pallets come into the facility in good condition, then I see no need not to immediately re-use them for finished product. I would insure that they cannot go "above" food contact zones, or open product. We re-use pallets often, especially those that our raw materials come in on. We issued a check during pre-ops for QA to inspect the stack of pallets brought in for the shift. QA will look over them and any broken, dirty, or sub-par palllets get taken to the pallet recycling area.
We do however use plastic pallets only in our "weighing" or "batching" areas of the facility where products are pre-weight prior to mixing, as we use food safe bags to weigh into, and those could be ripped on wooden pallets. These plastic pallets are washed and sanitized nightly by our sanitation crew, but they are only used for in-house raw material transfer.
I think your safest bet is to conduct a hazard analysis, and see what you come up with. I'm always a work smarter, not harder kind of manager, and I would hesitate to add another form to fill out, and see what steps you could take just to enhance your current procedures or forms to add this extra step, if you decide to go down this road.
Good morning Sarah,
Back when I ran an SQF facility, this meant that all pallets in the food handling area (sugar bagging) were only allowed for that area, and once they left (warehouse, etc.) they were no longer fit for that purpose. We actually used plastic pallets for this purpose and had a company who would sanitize them for our re-use.
I can't imagine much has changed since then, nor could I imagine that could be R/A'd away since it's a pretty direct code.
Maybe someone under the current scheme can chime in.
Could you please explain about sanitize the pallet? did sanitize means fumigation?