FSMA Changes Pest Control for Food Manufacturers

The Food Safety Modernization Act and Global Food Safety Initiative audits make processors rethink their pest management programs.

By Dave Fusaro, Editor in Chief

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Pest management programs in the food and beverage processing industry are increasingly influenced by food safety audits and government regulations. Between the two-year-old FDA Food Safety Modernization Act and third-party audits that comply with the Global Food Safety Initiative (GFSI), there are more rules and more prescribed steps to follow. And a lot more record-keeping.

Just this January, FDA expanded the requirement for hazards and analysis and critical control points (HACCP) programs to food processors that previously were not impacted by the requirement. In the agency's January 16 addition to the Federal Register, problems with both pests and pesticides are called out as contributors to food safety incidents in the recent past.

Pest control has always been a part, although largely implied, in federal food safety requirements, at least since the 1938 Federal Food, Drug & Cosmetic Act, says Zia Siddiqi, director of quality systems for Orkin LLC, Atlanta. "But now the FDA has become more specific about how pest infestation is a part of food contamination. And now the FDA has more resources and its own power to shut down plants," he says. As the agency extends the HACCP requirement, "pest control clearly should be a part of your HACCP program," he says.

In another read of the January expansion of FSMA, "Pest management in the future will pay heightened attention to product transport vehicles, loading dock and non-food storage areas, facility maintenance deficiencies that create pest and microbial harborages and utilization of pest-sighting logs as part of pest management trend analysis," says Jerry Heath, product manager and staff entomologist for Industrial Fumigant Co., Lenexa, Kan.

Rodent management is one of those areas that has seen some significant changes. Rodent bait packaging, distribution and labels were revised in the past two years in response to concern for exposures to children and non-target animals.

"Mitigation of non-target animal exposure had the most impact on the food processing industry," Heath continues. "Label revisions in 2011 limited most outdoor rodenticide placements to within 50 ft. of buildings. A number of shortcomings were identified in EPA's directive and, in remarkably fast action, the labeling directive was revised to within 100 ft. of broadly defined structures. Rodenticides with this new labeling were on the market by late 2012.

"Old-fashioned fence line baiting is prohibited unless within 100 ft., but the current labels have sufficient flexibility to allow rodenticide protection for the diverse kinds of facilities and outdoor storages food processors utilize," he continues.

GFSI-recognized programs are another huge motivator for better pest management programs. "In some ways, GFSI will have more impact on pest control than FSMA," says Siddiqi. While FSMA considers pest control a general recommendation of a HACCP program, "All the GFSI-recognized programs have very specific requirements for pest control," he says.

One change, thanks to most programs certified by GFSI, is the placement and spacing of rodent devices. Most pest management programs in the past followed a formula, placing them every so many feet, but most popular audit standards compliant with GFSI now allow for more flexible device placements based on known threats, ongoing inspection and history of activity.

"There have been examples where numbers of rodent control devices have been dramatically reduced, and pest management service has evolved to a more general inspection routine," says Heath.

But many facilities in the food & beverage industry are still governed by audit standards requiring a formula-based device placement scheme — or the plants lack trending data to support a reduction in device numbers. So it's best to check with your auditors for what is allowed. Also, many facilities are just more comfortable with a conservative program.

Correct and efficient identification is the first step to solving any pest challenge. Today, pest control experts are turning more and more to digital technology, specifically digital microscopes and digital photos as a reliable means for pest identification, says Patricia Hottel, technical director of McCloud Services, Hoffman Estates, Ill.

"Digital technology such as these allow entomologists, field personnel and plant managers the ability to work together to quickly and accurately identify pests of concern without sacrificing employee, product and facility safety," she says.

Also inside the plant, for widespread pest control processors should consider the debate between fumigation and fogging. Both approaches have their proponents. Neither leaves any residual chemical on surfaces, which in most cases is a benefit but does not provide long-term killing power.

Fumigation probably is a more effective method, but it requires a shut down of whatever work area is being fumigated. Fumigation penetrates all cracks and crevices and provides a high degree of certainty that every bug in the room is dead. But it also penetrates packaging and machines. Fumigation also has been dealt some setbacks by the EPA, which de-listed methyl bromide, probably the most popular fumigant. Other effective chemicals also have been removed.

For fogging, chemicals are sprayed in controlled areas. There is less penetration. The chemicals provide a quick kill, but dissipate more rapidly than fumigation, so downtime is greatly reduced. Sequential fogging treatments can eliminate or reduce the frequency of fumigations.

Heath notes that fogging can be done by pest control personnel or by a fixed fogging system.

This article originally appeared in the February 2013 issue of Food Processing Magazine.

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