Samuelsoni_cg.- The National Committee of Transport by Road(CNTC) has submitted a written application to the Spanish Food Safety Agency to ban in Spain, the exchange of pallets during the transport phase effective to controlled temperature, thus supporting the national campaign and community initiated by the association ATFRIE.
ATFRIE presented his campaign last week during the meeting of the Plenum corresponding to the month of March of the CNTC, arriving at the conviction by unanimity of all the member associations that the Committee should turn over in this issue. The Association has already submitted a complaint with instances national health ( AECOSAN ) and eu ( EFSA ), which impinges on the dangers of transporting food along with pallets of exchange, transport acceded to tax by some companies loaders at national and european level.
Content of the letter sent by the President of the CNTC, Mr. Carmelo Gonzalez to Dña. Agnes Blanco, Head of Service AECOSAN:
The full Department of Goods of the National Committee of Transport by Road, at its meeting of full for the month of march, has agreed unanimously, to direct the following communication:
We put the knowledge of this European Authority that, long since, by the different shippers of goods from our country, as well as of the European Union, it comes forcing the transport refrigerator to the use of wooden pallets in exchange (known as euro pallets). The problem comes not from the circulation of such pallets, but your management system. There are no norms regarding the conditions of security that must comply with such pallet in the process of commissioning as the International Standard for Phytosanitary Measures number 15, to ensure that, in their origin, these pallets comply with the minimum levels required for food security. The problem arises, when such pallets began to circulate.
We need to bring to the attention of this Agency that such pallets may be transported previously in any other previous transport pesticides, animal skins, hides, fertilizers, or any other goods that may produce pollution, since in addition to when the vehicle is empty and is moved to perform the load contracted and, therefore, to make exchange, travel continuously and continuously in the porta pallet trucks that are located in the lower parts of semi-trailers, by imposing those same chargers that do not wish to perform the unloading of the pallets, are inside the cabin of the truck, so that during such displacement does not make another thing that to pick up all the dirt and pollutants that we all know are in the roads, like dead animals, oils, and all kinds of impurities.
The european legislation, in particular the Regulation 852/2004, in Chapter X of Annex II, provides that:
1. The materials used for the packaging and the packaging must not be a source of contamination.
2. The containers should be stored so that they are not exposed to any risk of contamination.
3. The operations of packaging and packing shall be performed in a way that prevents the contamination of the products (…)
4. Containers and packaging that are re-used for foodstuffs is to be easy to clean and, where necessary, to disinfect
Taking into account that the pallets are part of the packaging of the product, it cannot be contended that the system of reuse of pallets of wood, trading for it among the operators of the food chain, without control of any kind, is compatible with the legislation on the hygiene of the products.
But, what is more, the same eu Regulation 852/2004, requires carriers to keep clean and in good repair receptacles in vehicles and / or containers used for transporting foodstuffs in order to protect foodstuffs from contamination and must be designed and constructed, if necessary, to permit adequate cleaning and / or disinfection.
It is forcing carriers and manufacturers to ensure a sanitary conditions of their vehicles optimal, when those food products are placed on a potential source of contamination without any type of control. The conveyances and / or containers must not be used for transporting anything other than foodstuffs where this may be contaminated by another type of load, however, you can use brackets to those goods that have been transported any type of cargo without any limitation. All in all it’s a contradiction that should be resolved, not by illogical, but dangerous.
The reason for this attention is no other than our fear that at any moment it could produce cross-contamination of food due to the fact that, in addition, wood is an element absorbent that can be contaminated easily. All of this located within a vehicle refrigerator whose function is to keep the temperature of transport, for what necessarily is emitting a stream of air into a receptacle, without a doubt, you can drag, to boot, and deposit those pollutants in the product.
We would not like for this reason that one day you experience a crisis like the one that happened a few years ago in Germany, known as the crisis of the cucumber, the bearer of bad consequences. But we don’t like that, at the expense of this, criminalizara to the carriers that are the victims of this perverse system of exchange of euro pallets, forcing them to carry out the tasks of washing, disinfection, maintenance and proper maintenance, but that would have to be done by those who enjoy its use, that are not other that the shippers and distributors.
In any case, there are systems of management of packages on the market, consisting of the rental of the use of these and their subsequent treatment to ensure your health, on the part of companies dedicated exclusively to it. All this in the understanding that the problem is not the material where the manufacture of the pallets, but in their system of management consisting of all operators in the food chain are the owners of pallets and the exchange to every movement of the goods.
We propose the immediate prohibition of the exchange of pallets, the entire time that exists in the market companies whose order and your business is put at the disposal of the companies loaders brackets effectively treated. Likewise, we propose to prohibit the transportation of the wood supports in paleteras located in the basement of the trailers and semi-trailers.
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