U.S. wood pallet industry supports call by iGPS for FDA to test pallets for food safety; says European food industry studies found wood equal and sometimes superior to plastic
August 12, 2009
– The National Wooden Pallet and Container Association (NWPCA) supports the suggestion by the Intelligent Global Pooling Systems (iGPS) plastic pallet company that the Food and Drug Administration (FDA) test pallets for food safety. To aid this process, NWPCA is submitting several studies already conducted by the European food industry to meet the European Commission (EC) Hygiene Directive introduced in 2000.
"The goal of the European Commission directive was to make a single hygiene policy effective from the farm to the table," said NWPCA President Bruce Scholnick. "The European food industry conducted a number of field and laboratory tests on wood and plastic pallets and found wood to be equal to, and in some cases superior to, plastic. Apparently plastic is made up of minuscule honeycomb patterns that hold onto bacteria in a way that wood does not."
The German Institute for Food Technology carried out field tests comparing wood and plastic pallets used in the meat, dairy, vegetable and bakery sectors. They found "the overall bacterial count on commercial wooden pallets made from different types of wood was on average 15% lower than on plastic pallets."
A Nordic food industry study conducted field tests on the survival of bacteria commonly found in the meat industry. That study was compared against those in German laboratory tests. The overall conclusions were the same -- "bacteria didn't survive within the wood."
The Nordic project also did laboratory testing on the efficacy of cleaning wood and plastic pallets after contamination using normal detergent without antibacterial additives. The conclusion of that testing was that "bacterial survival is lowest on wood." A Swiss study on the hygienic aspects of wood cutting boards compared with polyethylene (PE) boards similarly demonstrated that "wood is just as easy to clean and is an acceptable hygienic material."
"We are sharing these food industry studies with the appropriate FDA administrators and are encouraging them to replicate them," said Scholnick. "We are also asking that they include a safety test for deca-bromine chemical fire retardant which is infused in the iGPS plastic pallets. In fact, according to the company's own life cycle analysis, there is 3.4 lbs of Deca in each iGPS pallet."
"After pallets are roughed up in the normal wear-and-tear of the material handling and warehouse system, those chemicals are bound to leach into the products they carry," continued Scholnick. "The FDA needs to test the older plastic pallets to see how much deca dust is getting onto our food."
Last June, the Environmental Working Group (EWG) urged the FDA to halt the use of plastic pallets containing decabromodiphenyl ether (Deca) for transporting food products. "Deca is a neurotoxin and suspected carcinogen that persists in the environment and accumulates in human tissue," Richard Wiles, EWG Senior Vice President for Policy and Communications said in his letter to the agency. "Millions of plastic pallets, each containing 3.4 pounds of Deca (according to industry estimates) are currently in use. These contaminated pallets could introduce millions of pounds of toxic fire retardant into the environment each year."
August 3, Wiles followed up with a letter to the country's largest grocery stores and supermarkets saying, "We are writing to ask that you determine whether or not you or your suppliers are currently using plastic pallets, and if so, we urge you to immediately stop the use of these pallets by you or your suppliers until proper FDA approvals are received."
The FDA itself has weighed in on the use of plastic pallets containing Deca for hydrocooling fruits and vegetables. In an April 2009 letter, Dr. Elizabeth Sanchez of the FDA's Center for Food Safety and Applied Nutrition, stated that Deca is "not authorized" as a component of plastic pallets used in hydrocooling produce. She also said that FDA requires pre-market approval for the chemical "to be used in contact with food."
The states of Maine, Washington, and most recently Oregon have passed legislation banning the use of Deca for household goods. Washington State, in consultation with the Washington State Department of Health developed the Final PBDE Chemical Action Plan that says: "The United States Congress or Washington State Legislature should phase-out the manufacture, distribution and sale of new products containing Deca-BDE provided that safer, effective and affordable alternatives are found or upon the emergence of additional evidence of Deca-BDE harm." That report can be found on the Federal EPA Website.
Oregon Representative Ben Cannon said during the debate that "Deca is an effective fire retardant, but it poses potentially serious health risks. Using it does not make us safer when there are safe and equally effective alternatives to Deca."
As for iGPS' request that FDA look at engineered wood, the agency might save itself time by examining California's policy which is one of the most stringent in the world. At the request of NWPCA, the California Air Resources Board (CARB) reviewed wood packaging industry practices and came to the conclusion that "these products are not subject to any of the requirements of the airborne toxic control measure."
"Plastic pallet companies are in a difficult position," said Scholnick. "Without Deca their products represent an extreme fire hazard; with it they pose other risks. iGPS is in a difficult position and they are responding by tossing around non-supportable claims and accusations.
"There are numerous studies that substantiate the safety of wood packaging on a number of variables including sanitization, fire reaction, strength and durability," Scholnick added. "We've submitted these for examination. Where are the studies from iGPS that support the safety of food that comes in contact with Deca dust? Where are the studies that evidence that the gases from burning plastic pallets containing Deca will not injure fire fighters? Where are the end-of-life studies that prove an iGPS plastic pallet, which contains a heavy metal rod, can be fully recycled? Show the world the data."
The NWPCA represents wood pallet and container companies in 28 countries including the United States where it is headquartered. Wood pallets are made from a natural material that is reusable, repairable, recyclable and made from a renewable resource. It is a byproduct using lumber that lacks cosmetic appeal for housing materials, furniture and wood flooring, but offers strength and durability. When wood pallets can no longer be repaired to a standard that will ensure protection of the goods being shipped and safety of workers handling the load, the pallets are recycled into new products such as landscape mulch, animal bedding, boiler fuel, firewood and wood stove pellets. The nails from ground pallet chips are removed through a variety of collection technologies and sold as scrap metal to be used again. Wood pallets are the sustainable choice.