Representatives gathered to discuss the NASFM's draft Code Application Bulletin, which could have significant consequences for companies that use or receive pallets.

In a news item posted on March 4, 2009, MMH reported that the National Association of State Fire Marshals (NASFM) had drafted a proposal to alter existing compliance standards for pallets. Opponents maintain the change would have significant negative consequences for companies that use or receive pallets, including product manufacturers, agriculture, trucking companies, warehouses and retail stores.

NASFM held a public hearing March 12, to discuss the implementation of its proposal - a two-grade increase for fire ratings of wood block pallets and a re-examination of ratings for all other wood pallets. In attendance was the National Wooden Pallet and Container Association (NWPCA) delegation of 44 members, non-members and staff, along with end user companies Kroger, Nestle and Kraft. Plastic pallet companies Orbis and iGPS also participated, as did a number of insurance representatives and fire safety consultants.

In a statement following the meeting, the NWPCA said in part, “… the NASFM committee that developed the draft CAB had not been aware of, or did not fully consider, existing compelling and credible fire-test data on various wood species and composite wood products. This existing data, along with more recent fire-test data on composite blocks and composite block pallets, all helped to demonstrate that wood pallets of different species, forms and composite wood products remain a benchmark product within the storage commodity classifications proscribed in NFPA 13. NFPA 13 is the design and installation standard for automatic fire sprinkler systems that is published by the National Fire Protection Association (NFPA), an organization responsible for developing and updating fire safety codes and standards.”

Director of codes and standards for the Canadian Wood Council (CWC), Rodney McPhee, is a member of the NFPA Committee on Sprinkler System Installation Criteria, which is one of the NFPA technical committees responsible for developing the requirements in NFPA 13. McPhee attended the meeting and submitted comments to NASFM in which he suggested that the NFPA 13 committees “…did not intend such definitions would exclude a wood pallet being considered a wood pallet if it included components manufactured using some composite wood materials… Such a statement can only be substantiated through a request for a formal interpretation from the NFPA 13 Committee or through a technical change to the NFPA Standard.”

McPhee also told NASFM representatives that certification or “listing” of all wood pallets by species was unnecessary because industry fire testing had indicated that, while there were some variations, the fire properties of different wood species and composite wood products fell within a common range of safety considered to be at the benchmark level.

The meeting resulted in a number of immediate next steps:

• NASFM agreed to remove its draft CAB proposal from its Web site and to assemble a working group comprised of stakeholders to resolve technical issues and to ensure its completeness and accuracy prior to publication.
• NWPCA will pursue the idea of requesting from NFPA 13 a formal interpretation (FI) or tentative interim amendment (TIA) regarding the definition of a wood pallet.
• CWC, in conjunction with the American Forest & Paper Association (AF&PA), will submit industry data on fire testing of different wood species.
• Sonoco has already submitted to NASFM its fire-testing data on composite block pallets.
• NWPCA staff will work with NASFM staff to coordinate current and future safety issues impacting the wood pallet and container industry.

The NASFM board of directors is scheduled to meet April 1, and intends to hold a final vote on the proposal at its annual conference, June 19-21. If the proposal is approved, non-compliant companies will then need to make the necessary upgrades.

Of utmost concern to NWPCA is the continued threat of the mandating of “listing” of all wood pallets, which could lead to variety of new challenges, including a one-size-fits-all pallet design, decreased safety of supply chain workers, diminished unit load protection, wood supply problems and possible international trade retaliation.

Additional points of interest related to the potential implementation of the proposal include the following:

• If the NASFM proposal is adopted, it will change several areas of the material handling industry. Many distribution centers will be forced to upgrade their sprinkler systems or consider a change to a non-flammable pallet like steel.
• Because of the facility changes, companies could also incur additional indirect costs, as they may need to change their packaging styles to fit the new pallet models/materials.
• Managers would have to work closely with their local fire marshal to determine how any changes would affect their facility.
• Most facilities do not currently have the proper sprinkler systems in place to conform to the proposed standard. If not, they will need to upgrade their sprinkler systems to remain compliant. Some safety engineers are estimating costs near $2 billion for one complete facility upgrade.
• The steel pallet industry stands to benefit because steel pallets are non-combustible. The current standard is based on a traditional wood stringer pallet with metal fasteners. Because steel pallets are non-flammable, they are assumed to exceed the requirements of the current standard. 
• Certification organizations may create a separate standard for the use of steel versus wood or plastic pallets. Currently, steel pallets are grouped with wood stringer pallets in terms of the standard for sprinkler coverage in buildings, meaning the benefits of steel are not specifically being considered within the standard. 
• Fire and safety organizations will potentially become more interested in how steel pallets affect the burn rates of materials stored in a warehouse. They may also be more interested in whether or not people save money on the cost of sprinkler system designs and installation or insurance savings by using steel pallets.