By Courtney Brein, Linda Golodner Food Safety and Nutrition Fellow As the Linda Golodner Food Safety and Nutrition Fellow at the National Consumers League, I work on a wide range of food safety and nutrition issues. While, on the food safety front, the topics on which I focus run the gamut, ultimately, they all share a common purpose: improving the safety of the food that American consumers purchase, serve, and eat. Due in part to a string of recent foodborne illness outbreaks, and in part to an administration that has chosen to prioritize improving food safety, the environment is ripe for making significant changes to – and expansions upon – the mechanisms currently in place for protecting our food supply. More than a year ago, President Obama created a White House Food Safety Working Group co-chaired by Secretary of Health and Human Services (HHS) Kathleen Sebelius and Secretary of Agriculture Tom Vilsack. The group has recommended a public health focused approach to food safety that prioritizes prevention and strengthens surveillance and enforcement, among other measures. On the Congressional front, FDA food safety modernization legislation passed in the House last summer and is slated to come to the Senate floor soon. The United States Department of Agriculture (USDA) recently set new performance standards for Salmonella and Campylobacter in young chickens and turkeys, in an effort to help prevent tens of thousands of illnesses every year. To help consumers stay up-to-date on recalls and other food safety issues, HHS and USDA launched www.foodsafety.gov last September. The list goes on. Central to the creation of an effective food safety system is the assurance that measures are in place to protect products at every step of the way along the path from “farm to fork,” as the saying goes. While regulations and inspections help to ensure the safety of food grown on farms and produced in factories, and consumer education helps to reduce cross-contamination and unsafe cooking practices in the home, the area in between – the transportation of food from production to purchase point – remains largely overlooked and under-regulated. Several months ago, NCL Executive Director Sally Greenberg and I began to wonder what role, if any, the pallets used to transport food might potentially play in the contamination of the food supply. Our first tip-off was McNeil’s recall of Tylenol and several other products this past December and January. The company linked the moldy, musty odor – and the unpleasant side-effects it caused in many individuals who consumed the products – to the wood pallets that were stored in the area where these products were made. According to McNeil, when a chemical used to treat the pallets started to break down, another chemical called TBA formed in the air and contaminated the products. When we realized that these pallets were, at least generally speaking, the same as the ones stacked behind many grocery stores, we started to wonder why the shipping platforms that transport food were being stored outside, and if there were any regulations governing the use of pallets. Our research revealed that pallets are, in fact, more or less overlooked in the regulatory sphere. We decided to conduct exploratory testing of the pallets used to transport food, to determine whether the issue warranted a call for FDA’s consideration. We’ve been at this a long time – NCL first drew attention to potentially harmful products in 1904, when NCL volunteers staffing a booth at the 1904 St. Louis World’s Fair demonstrated to fairgoers that canned green beans touted by food processors as a labor-saving home product were adulterated with green dye. More than 100 years later, we continue this work; this past December, the League called on the FDA to investigate a “sweetened dried cranberry” product that our commissioned lab tests found to be mostly sugar, and made of cranberry skins rather than whole cranberries as advertised. For this investigation, we tested pallets in the Miami/Tampa area and in Houston. We located a highly regarded lab that gave us strict instructions on taking samples and shipping them back, which we followed to the letter. Many of the pallets I saw – and tested – were really dirty, sullied with items ranging from bird droppings to fish scales. They were stored outside, exposed to the elements, and easily accessible to rodents, insects, and birds. I became intimately familiar with these shipping platforms – both wood and plastic – and the precise, methodical way in which one takes samples to send to a lab. In all, we took samples from 35 plastic pallets and 35 wood pallets in each metropolitan area, totaling 140 samples. We had no idea what our results would be. As it turned out, our findings were significant – and alarming. The lab found E. coli on 10 percent of the 70 wood pallets we tested, and on 1.4 percent of the 70 plastic pallets. The lab report also revealed the presence of Listeria on 2.9 percent of the wood pallets, half of which further tested positive for Listeria monocytogenes. None of the plastic pallets tested positive for Listeria. High aerobic plate counts, which reflect unsanitary conditions of the pallets, were found on both types of pallets, with approximately one third of the wood pallets and one fifth of the plastic pallets showing the high counts. While our exploratory testing included only a small number of pallets, we think it gives some indication that the sanitation and safety of the pallets used to transport food in the U.S. deserve a closer examination. This past Tuesday, therefore, the League sent a letter to FDA Commissioner Margaret Hamburg, sharing our findings, urging the agency to do its own testing, and calling on FDA to set standards that will help to ensure that pallets are cleaned and stored properly, thus minimizing the possibility that they will be implicated in the spread of foodborne illness. Additionally, we videotaped our testing – check it out.