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The National Consumer League calls for pallet safety standards [2010-06-02]

“To live means to buy, to buy means to have power, to have power means to have responsibility.” – Florence Kelley, first General Secretary, National Consumers League

The National Consumer League is an organization whose founding principles for more than 100 years is: “That the working conditions we accept for our fellow citizens should be reflected by our purchases, and that consumers should demand safety and reliability from the goods and services they buy.  Promoting a fair marketplace for workers and consumers was the reason for the League’s founding in 1899 and still guides us into our second century.”

A release by the NCL announced testing of 70 wood pallets and 70 plastic pallets that have been loaded with perishable products and shipped to an end user was shipped overnight to an independent microbiology lab for testing.  The results came back with 10 percent of the wood pallets positive for E. coli and 1.4 percent positive on the plastic pallets.  In addition, the aerobic plate count reflects unsanitary conditions on approximately one third of the wood pallets and one fifth of the plastic pallets.  The aerobic plate count indicates the level of microorganisms which help determine the quality, spoilage level, sanitary practices during processes and handling that can lead to contamination.  The more serious result showed that 2.9 percent of the wood pallets tested positive for Listeria, which causes 2,500 illnesses and 500 deaths in the United States annually.  The NCL goes on to state: “Furthermore, regardless of the materials from which it is made, any pallet that is not properly cleaned between trips increases the likelihood of cross-contamination. Storing a pallet outside, in unsanitary areas, in places accessible to vermin, or near potential contaminants increases the chances that the pallet could harbor dangerous pathogens. In conducting our testing, we observed that wood pallets – which we found to have a higher incidence of pathogens – are more often stored outside and exposed to weather, rodents, bird droppings, and insects.”

Resistance is futile

Government regulation is coming and has already spawn regulations and legislation that will affect the landscape of the pallet industry.  This report indicates the first documented case that the impervious plastic pallet is vulnerable to contamination.  In regards to the plastic pallet, susceptibility to contamination depends on pallet construction and materials.  Several new plastic pallet companies have taken this issue into consideration and taking measures to make their pallet more resistant.  Government regulation means additional steps in the supply chain.  Growers and manufactures must have set standard operating procedures to ensure limited cross-contamination can occur.  It is important to note that the majority of E. Coli and other food-borne pathogen contamination occurs from product handling in the field, mainly from manure.  The product contaminates the pallet, usually not the other way around.  However, pallet recyclers generally do not wash used wood pallets down prior to repairing and selling.

E. Coli is a host specific organism which can help determine the source of contamination and thrives in temperatures from 98.6 degrees and 120 degrees.  E. Coli can survive for months in animals or in moist or wet environments.  In a survey of U.S. agricultural fairs 11% of the 97% cattle tested came up positive for E. Coli, confirming where the majority of breakouts occur.  Product handling requires enforcement of existing regulations.  There are no existing cases of E. Coli or Listeria illnesses due to wood or plastic pallets.  E. Coli survival rates drop dramatically on dry surfaces such as pallets, which is why the pallets required air transport for testing by the NCL .

Getting Serious

Bottom-line is, no organization or company has performed a truly scientific test without results leaning towards a pre-determined outcome.  In other words, iGPS testing is pushing for wood pallet testing and safety regulations.  The NCL is pushing for both wood and plastic testing, as both tested positive for E. Coli.  The end result will be government policy, regulations and legislation that will hurt small business.  Testing needs to have the following occur:

  1. Choose a national pallet company that can track pallets:
    1. CHEP, PECO, and iGPS Pooling has the network required to track pallets throughout the supply chain.
  2. Choose a large agriculture company to volunteer testing:
    1. Dole Fresh, Grimmway Farms, Bolthouse Farms, Driscolls
  3. Test pallets prior to loading:
    1. Get an average of contaminated pallets prior to loading
    2. Send only clean pallets for transport
  4. Choose a U.S. Distributor to unload and separate.
    1. US Foodservice, Sysco, Wal-Mart, Costco
  5. Test again

The pallets would need to be marked and the workers cannot know about the test.  Except for management it needs to be blind.  Use a test of 100 pallets shipped throughout a season on a commodity susceptible to contamination.

What we have here is a failure of imagination.  These organizations and companies are conducting “gotcha” testing in an effort to get the public and politicians to act.  With this kind of testing you get irresponsible and ignorant bills like A09173 submitted by Representative Boyland of New York which bans perishable products shipped on wood pallets into New York.  Question to Mr. Boyland, some plastic pallets came up positive for E. Coli, what now?