10 replies to this topic

[Lynx42]

The problem: We almost got a non-conformance for broken pallets and he heavily implied that it will be a non-conformance if he does our next audit and he sees them.

 

The issue: We are a 3PL and 2 of our customers just beat the heck out of their pallets.  They come in to us with pieces missing off the front and/or loose shards of wood peeling or sitting on the bottom boards.   Trailers have to be swept out each time we unload and the warehouse floor swept after we put them away or pull them for shipping. These products come in and go out in full pallets.  Neither customer wants to pay us for rethrowing these onto good pallets, and neither plan to "buy better quality pallets" as the auditor suggested.  If items are leaning over or the pallet is outright unusable, we have to send the customer a picture before they will authorize us to rethrow it.  We do store product by customer so there is no risk of foreign material damage to other customers.

 

The question: Can we get a non-compliance because a customer refuses to follow, or require their suppliers to follow, good pallet procedures?  One of these customers is our biggest one and it's just one of their suppliers that this is an issue for (about 10% of the items we store for them).  We send them several pictures every load and they just don't seem to care.  The other customer is our second largest, and newest, customer and we get stuff directly from them after they've manufactured it.  They are less than 100 miles away and we have had several inbounds come in with tipped loads, damaged product, and smashed pallets.

 

The solution: ???  Other than sweeping up after the pallets move and getting on my guys about picking up broken pallet pieces when they see them (I pick up several every time I walk the warehouse) I don't know what else to do when an auditor walks past a pallet in the rack that is missing half of the top leading board.  We can show emails to customers showing the state of the pallets and their responses (or lack thereof) on us moving product to good pallets.  

 

Any suggestions, thoughts, comments?  I think I'm overthinking this to death, but it's extra frustrating because it's out of my control.

 

[SQFconsultant]

We have a pallet program, sounds like your company does not have a policy/program.

[Lynx42]

If you ship stuff to a storage facility, would you expect them to replace damaged pallets and use their staff without compensation? 

 

We have a pallet program.  It covers inspecting inbound pallets and reporting damage to the company that purchased them (if they are empty) or owns the product on them.  We do not own any pallets, full or empty.

 

My company is not going to purchase pallets or provide free manhours to rethrow pallets of products that do not belong to us.  Most of our customers send us empty pallets to use for their products and will pay for the manhours to rethrow pallets as part of our inbound procedures.  2 companies do not and have to approve and account for all pallets, new, used, and damaged, because they don't want to pay to replace the pallet or the for the man hours needed to move product onto an better pallet.  

 

I'm not worried about severely damaged pallets.  If it's missing a sideboard or has damaged product, customers do approve those.  I'm mainly talking about pallets where product doesn't come to the edge at the front and has a split top or bottom board that has splintered off or is hanging off because someone ran a lift into it.  Pallets that are damaged but "usable" and wouldn't be given a second thought at my last facility that was non-food.  

 

If a customer puts product on a pallet, then breaks off parts of the pallet and sends it to us, how is that a non-conformance on our part?

[GMO]

I suppose strictly speaking, you should be rejecting them would be the auditor argument.

 

I'm not sure if the previous reply meant this but there are pallet hire programmes in the UK at least (not sure if you have the same) so while there's a labour cost too of inverting onto another pallet, the actual pallet cost is covered.  Chep are the most popular over here.

 

For me, and I'm not an SQF expert but I'd document the heck out of it.  I'd include every time you've sent feedback to the customers about damaged pallets.  I'd include your H&S concerns in that as actually tipped / fallen pallets are a significant health and safety risk (sometimes that gets peoples attention).  Then if you really can't replace the pallets which are at the level of damage the auditor saw, I'd do a risk assessment on whether it is or isn't a food safety risk.  

 

Another idea to at least show that you're taking it seriously is to have regular connects with your customers on KPIs.  I'm sure they have some for you too.  But as part of that if you start tracking fallen pallets and also damaged but not fallen you can see if they're getting better.

 

I know they're your supplier but also if you go to their site I think you'll find one or all of these things.  Firstly the pallets are already damaged before they're used.  Why not see if they can at least rule that out?  Secondly, they have absolutely appalling fork lift drivers.  If they don't solve that, they will end up with a serious injury, serious loss of stock or even a death.  I'm not joking.  There was a famous case in the UK of a cheese maturation store where the whole thing collapsed on a driver.  Lastly they're not properly securing their loads in the vehicles.  I'd take a colleague who works in H&S and is an expert in workplace transport with me to go and look into this as an "offer of help" for the customers.  

 

Then I'd politely write the whole thing up, record it, keep tracking if things do or don't get better and when the auditor next comes you can show them the work you've tried to stop this recurring but to no avail in all likelihood but you have shown it's not a food safety risk and that you've done everything in your power.

[Scampi]

The auditor isn't wrong (but I see your point)

 

The contract with these customers needs to be bulletproof. If it currently doesn't state ANYTHING about pallet condition upon arrival, I get it your hands are tied

 

I would be rejecting the loads at the dock,  they will figure it out quickly

 

no, you are not responsible for their product BUT your are responsible for your facility

[jfrey123]

Dang, reminds me of where I started in food where we were a 3PL processor and storage company.  I'd say as much as possible, you need to build this fact into your SOP's/programs, mentioning heavily where you're limited on certain actions due to not owning the product.  Take non-conforming and disposals: where most companies get to place product on hold and dispose immediately when a non-conformance is observed, you're stuck with an isolate and notify type situation where you have to wait for the customer owning the product to actually decide.  It sucks, but once an auditor really starts to understand where you're limited by the 3PL and can see in your SOP's you're addressing code compliance as strongly as possible, it enables the wiggle room you need to operate in reality.  Lot of it means isolate and notify, and in reality your customers will end up making choices that you and auditors might not like, but the fact remains it's outside of your authority in those cases.

 

So back to specifically the broken pallets:  the auditors are right the broken wood creates a FM hazard and they're used to seeing broken pallets immediately removed.  You should have an SOP dealing with FM hazards that mentions wood, specifically pallets as it's one of the few places where we realistically can't eliminate wood pallets from our sites.  When broken pallets are observed, you notify the customer and request permission to handle the merchandise to correct the issue.  If they deny, you're still on the hood to figure out how to prevent the wood from being a hazard.  Maybe tagging the broken pallet and making sure those are isolated to the bottom of your storage racks only (to prevent wood from falling on other pallets).  Where your hands are tied on the ideal solution, you can implement some form of control to reduce the hazard and make sure that's written into the SOP.

 

Now, ideally, your upper management should be involved and aware of this situation.  Ideally, they'll establish precedent with the customer to say that these issues need to be corrected on their end and that food safety hazard corrections must be done and paid for.  This customer will have a far larger headache if their trusted 3PL storage site loses their GFSI cert because of a situation they're creating.

[Lynx42]

I know they're your supplier but also if you go to their site I think you'll find one or all of these things.  Firstly the pallets are already damaged before they're used.  Why not see if they can at least rule that out?  Secondly, they have absolutely appalling fork lift drivers.  If they don't solve that, they will end up with a serious injury, serious loss of stock or even a death.  I'm not joking.  There was a famous case in the UK of a cheese maturation store where the whole thing collapsed on a driver.  Lastly they're not properly securing their loads in the vehicles.  I'd take a colleague who works in H&S and is an expert in workplace transport with me to go and look into this as an "offer of help" for the customers.  

 

They are not our suppliers, they are our customers that retain ownership of the product and pallet the entire time it's in our care.  The product is all under 50lbs and single stack, so there is no increased risk of injury when handling them, with the exception of splinters or nails sticking up if our employees are not wearing proper gloves when they are moving empty pallets by hand.   We have been told to reuse pallets unless a full board is missing, so a splintered board is okay, per the customer.  Our H&S guy bought cut gloves for employees to use if needed.

We do have some customers who use Chep pallets, but we cannnot tell customer what pallets they should store their products on, especially with the extra cost to use them.  There are some retailers that will only accept Chep or PECO pallets (Costco) and other retailers that will reject Chep and PECO because they don't want them in their buildings.  

 

 

The auditor isn't wrong (but I see your point)

 

The contract with these customers needs to be bulletproof. If it currently doesn't state ANYTHING about pallet condition upon arrival, I get it your hands are tied

 

I would be rejecting the loads at the dock,  they will figure it out quickly

 

no, you are not responsible for their product BUT your are responsible for your facility

 

Since the customer retains ownership of the product we cannot reject trailers without customer approval, with the exception of pests that pose a risk to other customers products (we occasionally get trailers with a lot of flying insects and once or twice a year evidence of rodents). 

 

 

I've asked receivers to take pictures of every load for these two customers and asked the CSR's to create a folder to drop them in and include me on emails to customers regarding pallet damage.  One of the customers has asked us to report damaged product only, not damaged pallets unless we "physically are unable to pick it up with available lift equipment". 

 

I guess I'm mostly just venting frustration that we could get hit even though we are "following customer requirements."  I wish the storage and distribution standard was more clear for those who do zero manufacturing.   

[GMO]

Sorry I meant to write customer not supplier.

 

I think all you can do in this situation is document everything then use that as evidence.  

 

The point on health and safety is if they're having that level of damage to pallets, it suggests your customer has got some appalling fork lift drivers.  I was suggesting it as an angle in to try and change their behaviours or at least to get them to show some interest in changing them.  Pallets should not be getting routinely damaged to the level you are describing unless someone is doing something very wrong.

 

But ultimately if you've tried and documented everything, the customer owns the pallet and you've risk assessed it's a minimal food safety and health and safety risk on your site, I think that's all you can do.

[TimG]

Which section of the code did he reference? I'd like to take a look at that before I throw in my 2 cents.

[Lynx42]

Sorry I meant to write customer not supplier.

 

I think all you can do in this situation is document everything then use that as evidence.  

 

The point on health and safety is if they're having that level of damage to pallets, it suggests your customer has got some appalling fork lift drivers.  I was suggesting it as an angle in to try and change their behaviours or at least to get them to show some interest in changing them.  Pallets should not be getting routinely damaged to the level you are describing unless someone is doing something very wrong.

 

But ultimately if you've tried and documented everything, the customer owns the pallet and you've risk assessed it's a minimal food safety and health and safety risk on your site, I think that's all you can do.

 

Thank you.  I am probably making it sound way more dramatic that it is. Not every pallet is damaged, but a few on each truck have long splinters poking out or broken pallet debris on the bottom board and they fall off when we are moving them. Our priority is to not ship out damaged product or unsafe pallets, and to make sure it's not going to effect any other customers product.  I've got copies of the emails saying they good to go as is, but if we have to take the product off for any reason we damage it and will not reuse it.  

 

Which section of the code did he reference? I'd like to take a look at that before I throw in my 2 cents.

 

He didn't, but I'm guessing it's 12.7.2.9 Wooden pallets and other wooden utensils used in food handling areas shall be dedicated for that purpose, clean, and maintained in good order. Their condition shall be subject to regular inspection.

 

Hopefully mentioning we are following customer requirements and showing him emails that the customer is good with it will suffice.  

 

I will stop stressing about this now.  

[TimG]

I don't think you're over dramatizing it. My interpretation of the code (which means little btw) is that section is there to minimize risk from pallets. If you can show that you have considered and acted on any risk from customer pallets, perhaps even 'sequestering' these customers finished goods in a naughty no-no bad palleted product area where they absolutely cannot impact other customers products, you should have a leg to stand on.

You already have a threshold where you reject or repalletize if they are too bad, so this might be one where the auditor will toss their opinion in on why your threshold isn't stringent enough. Just be ready to show why you feel it is.