Moving Blankets vs. Thermal Pallet Covers Ryan Rush 410-825-8300 Rrush@univpack.com

Soft Costs Reusable Moving Blankets Thermal Pallet Covers Required training for all current associates and new employees When is a blanket considered “dirty”? When should it be thrown away? What if the blankets appears to be clean, but gives off an odor? What if the blankets become overly saturated for an extended period of time? Micro bacteria? Record keeping New regulations require transportation equipment records shall be maintained for a minimum of 12 months Documented training of all employees Lost or Stolen Blankets New Equipment Cleaning Requirements Minimal training for all current warehouse employees and new warehouse employees Thermal Pallet Covers are one time use No variables on cleanliness No required record keeping

US Code of Federal Regulations (416.4 – Sanitary Operations) (d) Product must be protected from adulteration during processing, handling, storage, loading, and unloading at and during transportation for official establishments. Most recently checked for updates, November, 26, 2016, hyperlink is below: https://www.fsis.usda.gov/wps/portal/fsis/topics/regulatory-compliance/compliance-guides-index/sanitation-performance-standards/sanitation-compliance- guide/!ut/p/a1/jZFRb8IgFIV_yx762ELFGbu32mSZnbYxyzbkxaCllKUFAmiX_fqx-jKNbl6e7sl34J4LIAADIulBcOqEkrT96clkA1dwEicZzGHsz7xAL- OnvEBwhDyw_g2USfzogbdV-ZxlcFqgG_1XKoX_-fMbHhiZZbbkgGjqmlDIWgG8U51uBZU7FvK9qJj1esU-AbZUCjekDzUztTLdAFlHZUVNZU- I81vAOyB_zlOOz4ELCzsC1zfiI_NWbYffWadyi6Y-m2E1M8xEe-PlxjltHwIYwL7vI64Ub1nkhw3gJUujrAP4lAS6e8Vfi1ky_7hvD4v07hurTzcD/#416.4

Sanitary Transportation of Human and Animal Food (Docket No Sanitary Transportation of Human and Animal Food (Docket No. FDA-2013-N-0013) Department of Health and Human Services Final Rule effective as of June, 6, 2016. Establishes final requirements of sanitary transportation practices for those that are engaged in the loading, unloading, and transportation. Expands on the implementation of the Sanitary Food Transportation Act of 2005 (2005 SFTA) and the Food Safety Modernization Act of 2011 (FSMA) Expands on implementation of practices to reduce /eliminate the risk of inadequately cleaning vehicles and equipment between loads and otherwise properly protecting food during transportation. https://www.federalregister.gov/documents/2016/04/06/2016-07330/sanitary- transportation-of-human-and-animal-food

Sanitary Transportation of Human and Animal Food (Docket No Sanitary Transportation of Human and Animal Food (Docket No. FDA-2013-N-0013) This is an updated rule effective June, 6, 2016 by The Department of Health and Human Resources / FDA regarding the sanitary transportation of human and animal food. All companies have 12 months to comply and practicing these procedures by June 6, 2017. This rule states that reusable blankets should be considered equipment because they are coming in direct contact with food. Table 7 sub, 1.906 specifies that this “equipment” has to be adequately cleanable if its going to be reused. Response 94, reinforces that this “equipment” has to be cleaned. “Appropriate cleaning practices will be followed”. This talks about the need for maintaining a policy and record keeping for the cleaning of the reusable moving blankets (equipment). This statement reinforces this record keeping, “Shipper must develop and implement written procedures adequate to ensure that vehicles and equipment are in appropriate sanitary conditions for the transport of food”. Reusable moving blankets will need to be stored in a “manner that prevents it from harboring pests or becoming contaminated in any other matter”. Section 1.908 (c) (1) states that the “loader” (forklift operator) determines weather or not the blanket is adequately clean to be used. Table 8, 1.908, carriers must have written procedures that specify cleaning, sanitizing and inspecting equipment.

Liability, Cross Contamination (Allergen) Moving Blankets The possibility exists of cross contamination or as the FDA quotes, “the unintentional incorporation of a food allergen”. Imagine a delivery of peanut oil and peanuts to a local restaurant. The pallets next to oil has a moving blanket on top. The oil is slightly leaking out of the container and gets on the floor of the truck. After the final delivery is made the moving blankets are accidently placed on top of this peanut oil. The next day these same blankets are used to cover up apples and bananas for delivery to a school. The oil from the blankets transfer to the fruits. These fruits are supposed to be properly washed, but are not, they are put out and a child with a peanut allergy ingests peanut oil resulting in a food related allergy attack.

Liability, Contamination of Third Party Blankets Your driver is delivering to a warehouse one day. The receiving party gives your driver their reusable insulated blankets instead of yours. How were the reusable insulated blankets stored? When was the last time these reusable insulated blankets cleaned? What is the SOP for these specific reusable insulated blankets? Have any food allergens, cross-contacts, pests, or other containments come in contact with the reusable insulated blankets?

Benefits of Thermal Pallet Covers Minimum training for all current warehouse employees and new warehouse employees Thermal Pallet Covers are one time use No variables on cleanliness No required record keeping Ryan Rush 410-825-8300 Rrush@univpack.com