Voices: Regulatory Issues
Controlling the Pest Problem At Food and Beverage Manufacturing Plants
A food illness outbreak may not shut down a plant, but woe to the processor who fails to maintain a rigorous pest control program.
Go big or go home is an American mantra, and nobody goes bigger than the U.S. of A. when it comes to pest control.
Pest control is a $14.4 billion global business, estimates U.K.-based Rentokil Initial plc, and half of that spending occurs in North America. A big chunk supports food and beverage pest programs. Little wonder, then, that acquisition-fueled growth in recent years vaulted the firm’s Rentokil North America subsidiary into the No. 3 position among pest control service providers, once Rentokil stitched together a national network from its Reading, Pa., beachhead.
Eliminating termites in homes or bedbugs from hotels differs from the specialized skills and knowledge needed to prevent pests from feasting in a food plant. While all national pest control companies extend their services to the food industry, they compete with thousands of specialists in helping the 79,844 registered U.S. food-handling facilities establish and maintain programs.
Speaking of the majors, Richard Kammerling, founder of RK Pest Management Services, Huntington Station, N.Y., says, “They may be great pest control contractors, but does all the necessary information filter down to the technicians? You can’t train them if they first don’t have knowledge about the specific problems a facility faces and the habits and life cycles of the pests they’re dealing with.”
Flora or fauna, once an organism’s life ends, it becomes food for other creatures. Be it livestock, grain, fruit or vegetable, the materials of food production are at risk until they are processed and packaged. Materials at rest are targets, and pest control programs are the sentries that keep lower life forms at bay.
The largest food companies have the resources to shoulder that protection task in-house, and the smallest firms do it out of financial necessity, but most food processors today rely on outside experts to either guide their pest control efforts or manage an integrated pest management (IPM) program, experts say. Pest control is a prerequisite program, one of the building blocks of HACCP and the prevention-oriented approach to food safety mandated by the Food Safety Modernization Act (FSMA).
Referring to the Food, Drug and Cosmetic Act, James Sargent, director of technical support for Copesan Services Inc., Menomonee Falls, Wis., points out, “It was against the law in 1938 to have pests in the processing area. Now that is being expanded to the whole plant, including areas such as the machine shop.”
Gauging FSMA’s impact on food facilities’ pest programs requires conjecture, although the adoption of stricter third-party food safety standards already has had a positive effect. Instead of prescribing the spacing of rodent traps near doors and along the perimeter of buildings, independent auditors are granting plant operators discretion to target hot spots and reduce placements where traps aren’t really needed.
“Auditors used to come to plants with a tape measure, deducting points if there weren’t traps every 20 feet,” says Zia Siddiqi, director of quality systems at Orkin Commercial Services in Atlanta. “Those days are gone.”
To bring some consistency to audits, the National Pest Management Assn. (NPMA) convened a meeting of Global Food Safety Initiative (GFSI)-sanctioned standards organizations. BRC has adopted the association’s pest management standards, and SQF and other standards-owners are considering similar harmonization. In its 2013 standards revision, NPMA notes the need for “a more results-oriented approach” to pest control based on trends, inspection observations and the expertise of specialists.
“Most pest control programs will comply with FSMA,” believes Patricia Hodell, technical manager at McCloud Services, South Elgin, Ill. -- although pet food manufacturers and animal feed producers may struggle, and tobacco companies, which previously were not under FDA jurisdiction, are approaching FSMA requirements with some trepidation.
About one-third of food plants currently are certified under one of the GFSI standards, according to Food Processing’s 2014 Manufacturing Survey, and Hodell says those operations are committed to continuous improvement. Simply controlling and killing pests is not enough: An effective program includes forensics work to determine how pests gained access in the first place.
“I don’t perceive FSMA having a direct impact on pest management,” seconds Jerry Heath, product manager at Industrial Fumigant Co., Lenexa, Kan. “But the impact of the GFSI standards has been very significant. That’s where the specialized documentation and monitoring techniques have emerged.” Individuals responsible for checking traps must be able to correctly identify insect species, track trending information and capture other data. “Everything depends on monitoring and trending,” he adds.
Hide the roaches
Besides an emphasis on prevention and corrective actions, FSMA gives FDA expanded power to inspect processing facilities and order a shutdown if inspectors uncover serious deficiencies. A demonstration of that new power was provided in fall 2012, when FDA suspended the facility registration of peanut processor Sunland Inc. in Portales, N.M., after the plant was linked to a salmonella outbreak.
USDA’s Food Safety and Inspection Service already had that authority, although the agency often is slow to exercise it. A March 2013 salmonella outbreak that sickened more than 400 individuals is an example. The antibiotic resistant strain was tied to three Foster Farms poultry facilities, two in Fresno and one in Livingston, Calif. That touched off a series of inspections. However, no product recalls or disciplinary actions initially were taken.
But noncompliance citations were issued in September, November and December of last year when inspectors observed cockroaches in the Livingston facility. When live roaches were seen on a poultry handling tub and a sink adjacent to a production line Jan. 8 of this year, a suspension notices was issued. “Poorly maintained facilities and equipment that are not maintained to prevent entrance of pests, such as cockroaches, rats and flies, can and do harbor food borne pathogens,” the shutdown notice stated. The plant reopened briefly before Foster Farms voluntarily suspended operations while it implemented new safety measures.
Suspension of a facility’s registration occurs infrequently, but processors are remiss if they don’t respond to failures in a prerequisite program. Fumigation — pest control’s nuclear option — should be part of the Livingston prescription, but prevention should be the main focus. How the cockroaches are entering the building, where they are breeding, what their food sources are and where the failures in standard sanitary practices exist are among the questions that need to be answered. Once remediation is done, a comprehensive IPM program with buy-in from maintenance, sanitation, food safety and pest control personnel can prevent a reoccurrence.
Methyl bromide used to be the fumigant of choice, although its availability is extremely limited (dirty little secret: a black market feeds illegal applications). Phosphine is the go-to option, but it is very corrosive and can cause serious problems with electrical components, copper pipes and other materials, and some target pests are developing immunity. Carbon dioxide and sulfuryl fluoride, sometimes combined with heat, are options, but fumigation as an IPM action tool occurs infrequently in processing facilities.
“Nobody fumigates three or four times a year anymore,” observes IFC’s Heath, and some processors with rigorous control programs have done away with fumigation entirely. When it is necessary, “many food companies have a protocol to use an insect growth regulator (IGR)” in conjunction with the pesticide, adds Tim Larson, Rentokil’s quality assurance manager.
Companies typically establish threshold levels for acceptable intrusions, such as the number of flying insects in a light trap. If that level is exceeded, remediation is done and a follow-up review determines the effectiveness of the corrective action. “In a bakery, you are going to have Indian meal moths, you are going to have flour beetles,” Orkin’s Siddiqi points out. “You have to establish what is acceptable and then react if that level is exceeded.”
Rodenticides are falling out of favor in IPM circles, partly out of environmental stewardship concerns but also because a trap provides more information about invasive mammals than poison.
Some entomologists suggest processing plants are approaching near-zero tolerance for pests, although the term IPM was created partly to avoid suggesting that pest control results in pest elimination. Rodents and insects are inevitable when grain is stored. While IPM professionals point to the continuous improvement emphasis in GFSI standards as an indication that adulteration levels are shrinking, FDA’s defect action levels have not been adjusted. Those levels are determined by sampling.
In the case of wheat, there cannot be more than 32 insect-damaged kernels per 100 grams; beyond that, the wheat might be acceptable for animal feed but not human consumption. An estimated 1-2 percent of U.S. stored grains is destroyed each year by pest contamination.
The hit-list for pests at a grain elevator or storage bin is short compared to the buffet line that forms once grain is milled. Cleaning procedures filter out much of the insect parts that may be present, but live creatures now must be kept in check. “Documentation is a strong part of third-party audit requirements,” McCloud Services’ Hodell points out, and effective IPM is based on scrupulous records.
Grain elevators and storage operations are the front line in the war against pests. They also are the incubators of new technical weapons and control strategies. A handful of entomologists specializing in stored grain protection are developing biologically based controls to deliver products free of insects and insecticide residues.
Bio-based solutions usually cost more, allows Thomas Phillips, professor of entomology at Kansas State University in Manhattan, Kan., but the payback from protection also is increasing. “Grain prices have gone up dramatically in the last eight years,” notes Phillips. “Farmers are buying new trucks for the family.”
Insect growth regulators that prevent a species from reaching maturity and procreating have been used successfully for 40 years in stored grain, but they are not popular in bakeries, dry cheese storage and other food production settings because people associate dead insects with effectiveness. Pheromones, on the other hand, have emerged as a popular procreation disrupter. Pheromones have been identified for almost 40 species, but only half of them are commercially produced.
“The chemistry is so complicated and difficult to synthesize,” says Phillips. Each pheromone mimics the chemical signals that an insect sends to attract the opposite sex. Use of pheromone traps, on the other hand, requires EPA approval and handling by licensed individuals. Some entomologists have reservations about this use. “Zero does not mean zero in this case,” says Phillips, only that the moth hasn’t been detected.
“A pheromone trap is really a detection device,” adds Sargent of Copesan. “It’s like a thermometer. A thermometer doesn’t control the weather, and a pheromone trap doesn’t control pests.”
Barcode technology and tracking software have given entomologists another tool to deploy. After scanning the code on a particular trap or monitoring station, the program poses a series of questions, and the technician provides the requested feedback. The programs also allow technicians to map where light traps and other monitoring and capture devices are positioned throughout the facility.
“Tremendous amounts of data are collected, and the computer does the number crunching,” IFC’s Heath explains. “Those systems have been invaluable for identifying problems areas, where structural repairs are needed, and hot spots of activity.”
Thermal imaging with infrared cameras and even X-ray is occasionally used to expose hiding places inside wall cavities and other out-of-sight areas, though hardware cost limits their use. Rentokil rolled out a high-tech mousetrap called RADAR, which euthanizes rodents with CO2 gas, but it has only been deployed in pharmaceutical facilities, banks and medical offices, according to Matthew Lawless, technical innovation manager. An enhancement called PestConnect provides electronic messaging when the trap is activated, but that service currently is only available in the UK.
Portable heaters that gradually raise the temperature to 120-150° F in isolated areas of a facility to dehydrate and kill insects are alternatives to centralized systems that attempted to heat the entire plant. Instead of chemical fumigants, heat treatment is an excellent option, suggests RK Pest Management’s Kammerling, as is “frozen snow.” Pellets of frozen CO2 are injected into cracks and crevices, resulting in a similar outcome to heat.
Borrowing a technique used to inspect sanitary lines, pest managers are snaking miniature cameras into lines and wall cavities to spot cracks that afford an entry point to the facility. Vacuum pumps are sometimes used to evacuate oxygen in tent-like pouches holding pallet-loads of incoming materials. “That hasn’t taken off, but a few people in the organic industry are using it,” Phillips reports.
“There’s a lot of good technology,” Kammerling summarizes, “but it all comes down to the inspection.”
The polar vortex that sent shivers through the eastern half of the country this winter had entomologists cheering, given the cold’s inhibiting effect on pests. Still, when warmer weather returns, stink bugs, crazy ants and psocids will be on the march, and pest managers will have to document what preventive steps they’ve taken and adjustments they’ve made to keep them away from the nation’s food supply.
“Every year is different,” reflects Heath, and the methods of control, licensing requirements and regulatory oversight are changing, as well. The good news is the science is advancing, and fewer pests are taste-testing raw food, even as the use of pesticides recedes.
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A food illness outbreak may not shut down a plant, but woe to the processor who fails to maintain a rigorous pest control program.