Packaging Corner: Government regulations for food supply chain to affect handling, pallet use

The coming changes to the food supply chain—prompted by the Food and Drug Administration (FDA) Food Safety Modernization Act (FSMA) signed into law by President Obama in July 2011—are weighing heavily on the minds of companies involved in the manufacture, production, distribution, importation and marketing of food.

“This law requires the FDA to create at least 10 new regulations, with the bulk of the proposals due over the next two years,” says David Deal, senior director of marketing for CHEP Americas, one of the world’s largest pallet and container pooling companies. “Food facilities—from harvest to production to transportation to consumption—will be required to develop hazard analysis and risk-based preventive controls in response to those regulations.”

Food-handling companies must identify potential points of contamination and put in active countermeasures, adds Deal. “Our industry is going to have to address the two types of materials defined by the FDA: items that touch food directly such as packaging and non-food contact articles such as pallets.”

Because the regulations have the potential to be complex, and the need for companies to understand and adhere to them is so critical, CHEP has partnered with Kelley Drye & Warren, a Washington D.C.-based law firm with a specialized practice in food safety. The law firm is developing a CHEP-sponsored series of educational presentations and whitepapers.

The first whitepaper, released in June, outlines the high points of the FSMA. It touches on a variety of requirements: analysis and control, registration, FDA access to records, new harvest safety standards, fee assessment and collection, recordkeeping and more.

Because most companies are already familiar with the laws that pertain to packaging that touches food, future topics will cover the new regulations affecting the inspection and control of food-associated pallets in general, Deal adds.

“Everyone will have to be in compliance, and that will include demonstrating that their pallets or pallet supplier uses current good manufacturing processes (cGMP), particularly when cleaning and conducting inspections, then providing the corresponding documentation to verify pallet safety,” Deal says. “We want to help pallet users understand what the food safety laws are today, as well
as how they will continue to develop going forward.”

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