A proposal by the National Association of State Fire Marshals (NASFM) 
to radically alter existing compliance standards for pallets would cost 
billions of dollars to already struggling industries, and will not improve safety.
The move, being fast-tracked by NASFM, would have significant negative 
consequences for all companies that use or receive pallets including product
manufacturers, agriculture, trucking companies, warehouses and retail stores.


The National Fire Protection Association (NFPA) and the International Code 
Council develop fire and electrical codes; neither has made code changes 
related to pallets, but NASFM is in the process of "re-interpreting" the 
long-established codes and proposing new compliance measures, which they
will encourage their members, senior fire officials from each state, to
adopt.


"Our industry supports standards that will contribute to workplace safety,
" said Bruce Scholnick, President and CEO of the National Wooden Pallet
and Container Association (NWPCA). "But to date, the NASFM has presented
no body of evidence to suggest the need for such changes. It seems to us
the massive costs that would result to companies already economically 
stressed require a technical justification for the reinterpretation of codes
around which warehouse sprinkler systems have been designed and installed
 - and that are working." 
      

According to the federal government's U.S. Fire Safety Administration,
the vast majority (83.5 percent) of all civilian fire fatalities occur
in the home (2007). According to the Centers for Disease Control (CDC)
which tracks fire deaths: Smoking is the leading cause of fire-related
deaths; four out of five fire deaths occurred in homes; in 2006 there
were a total of 2,580 home fire deaths.  Compare that to the average 
number of fire fatalities in warehouse properties which, according to
Allbusiness.com, is fifteen - the specific cause of these are not 
available and may well be smoking-related just like home fires.  
"Given the data, it appears the codes established by the National Fire
 Protection Association for wood pallets, and the compliance measures 
taken by warehouse industries are effective," said Scholnick.
      

Despite the success of existing codes, NASFM is proposing a two-grade
increase for fire ratings for wood block pallets and says it will 
re-examine ratings for all other wood pallets.  Compliance would require
warehouses to spend enormous amounts for new sprinkler systems. 
"I was told by a safety engineer from a national food distributor the cost
to his company would be approximately $2 billion, and that's just one company
," said Scholnick.
      

In addition to increased fire ratings, the NASFM draft enforcement standard
proposes a new certification requirement for all pallets.  "Because of the
vast number of wood species used and the component variations such as wood
thickness of deck boards and such, this simply would not be possible," said
Edgar Deomano, Ph.D., NWPCA Technical Director.  


Of the 1.2 billion pallets in circulation in the U.S., 93% are wood, less than
1% are certified.  "This requirement would obviously provide a lucrative new
revenue source to a certification entity," said Scholnick.  "But it would be
at the expense of businesses trying to stay afloat in a troubled economy."

There are a number of issues that have not been addressed by NASFM.  

How does NASFM consider the certification of alternative materials such 
as corrugated pallets?

Millions of wood block pallets enter the U.S. each year from hundreds of
countries. What method does NASFM propose regarding the certification 
of those pallets?

What does NASFM propose doing with the 1.2 billion pallets currently 
moving through the U.S. supply chain that have not been certified - 
some of which are wood, some of which are plastic pallets with deca-bromine
fire retardant, some of which are plastic without a fire retardant?  

How does NASFM propose certifying each pallet design in combination with
each wood species?  Does NASFM recognize that if it cannot accommodate
the variations in this natural material it will eliminate the 5,000+ companies
employing in excess of 60,000 workers in the entire wood packaging industry?

And, then there is the health issue of using deco-bromine in plastic pallets.
A plastic pallet company has noted in its own life-cycle analysis that its
newly-manufactured pallets use 3.4 pounds of the fire retardant deca-bromine.  

The company's early pallets did not contain a fire retardant.  Few plastic
pallet manufactures use the fire retardant. How will fire personnel recognize
treated and non-treated plastic pallets in warehouse stacks?

Is NASFM aware that firefighters are very concerned about the health 
risks related to the use of deca-bromine? How safe is the use of the large
 quantity of deca-bromine on the health of first responders or the general public?

Is NASFM aware that Maine and Washington states have already banned the use of 
deca-bromine fire retardant in products using quantities measured in grams 
rather than the 3.4 pounds in these plastic pallets. Ten other states (Alaska,
California, Connecticut, Hawaii, Illinois, Maryland, Michigan, Minnesota, New York,
and Vermont) are in the process of banning the chemical.  

NASFM is holding a public hearing March 12 at the offices of Underwriters Laboratory
in Northbrook, Illinois to discuss implementation of its proposals.  It intends,
at its June 19 conference, to encourage its members to implement the proposals. 

"The NASFM proposal would likely drive a number of companies away from cost-effective
, safe and environmentally sustainable wood pallets even though there is no credible
data for the need to do so," said Scholnick.  "Further, it would throw a tire iron
in the wheels of U.S. commerce with no measurable gain in safety.  NASFM developed
this interpretation of existing code in isolation without understanding the full 
complexity inherent in a global supply chain.  It has developed a solution where 
there was no problem.  We are hopeful we can persuade NASFM to work in collaboration
with wood packaging and warehouse industries now and in the future to implement 
effective compliance options that are proportionate to the goal."

For more information contact Bruce Scholnick at 703-519-6104.

SOURCE  National Wooden Pallet and Container Association