With the Food Safety Modernization Act (FSMA) enforcement era well under way, food and beverage companies are intensifying efforts to upgrade their food safety defenses, with more rigorous worker training topping the list, Food Processing’s 16th annual Manufacturing Outlook Survey found.
Three out of four food professionals who participated in the survey indicated a greater emphasis on training as a food safety priority in 2017. Most of those respondents — and 41.4 percent of all survey participants — also say their companies are taking a hard look at pest control as an area for improvement.
Two-thirds of the survey sample indicated their plants have outsourced pest control responsibilities, making pest management the most frequently outsourced service. But out of house doesn’t mean out of mind, given the criticality of the task. Keeping production and packaging spaces free of insects, rodents and other uninvited guests is fundamental. Even if public health inspectors don’t shut a plant down, independent auditors take a dim view of deficiencies in this area: As much as 20 percent of food-safety audit scores are based on pest control.
Whether pest control is handled in-house or outsourced, past results are no guarantee of future performance. Continuous improvement is the only way to prevent backsliding. With that in mind, here are 10 ways to improve performance and outcomes in food-plant pest control.
1. Treat incoming materials as potential Trojan horses.
Some firms are going beyond certificates of analysis from suppliers to ensure that biological hazards are not entering through the receiving dock. The primary concern is raw materials, ingredients and primary packaging, but incoming shipments also can usher in rodents, insects and other pests.
Ron Harrison, technical services director at Atlanta-based Orkin Commercial Services (www.orkin/commercial.com), cites the pharmaceutical manufacturer that moved pallets of materials directly from the unloading dock to a clean room. With wooden pallets the dominant material carrier in food & beverage facilities, the likelihood that a pallet will contaminate processing areas is real.
2. Apply FSMA’s preventive controls approach to pest management.
Few if any changes in regulations or guidances for pest control exist in FSMA, but the corrective actions at the heart of the hazard analysis and risk prevention approach apply as much to current good manufacturing practices as they do to food safety. Preventive controls are a response to hazard analysis, and each analysis is specific to a particular facility and the types of products and ingredients made there.
Monitoring of light traps, rodent traps and other devices is a starting point for preventive control, but monitoring demands a framework, points out Patricia Hottel, technical director at McCloud Services (mccloudservices.com) in South Elgin, Ill. How those monitors are used and what circumstances trigger a corrective action must be defined, along with an acceptable threshold for detected pests.
Manufacturers should specify what results trigger a corrective action, she adds. If a rodent enters the building because a dock door was left open, that doesn’t mean the prevention system failed, only that procedures weren’t followed. On the other hand, chronically exceeding threshold levels of trapped beetles and cockroaches indicates the program isn’t working and requires change.
Root cause analysis is essential. “When a problem occurs, it’s a symptom, not a solution,” Hottel emphasizes. Understanding why it occurred is necessary before determining if the event exposed a fundamental weakness or a one-time event.
3. Foster collaboration and engagement.
A band makes better music than a soloist. Likewise, a collaborative effort involving sanitation, maintenance, quality assurance and other disciplines is more effective than fobbing responsibilities off on a single individual, be it a staff member or service company technician.
“A good New Year’s resolution would be to work on those relationships and have good communications,” advises Jerry Heath, an entomologist at IFC (www.indfumco.com) in Lenexa, Kan. “Everybody in the facility can be part of inspection.”
“The pest control program needs to be weaved in such a way that it isn’t somebody else’s problem,” seconds Dominique Sauvage, director-field operations & quality for Menomonee Falls, Wis.-based Copesan Services Inc. (www.copesan.com). “A lot of times, a service technician is hired to solve a problem, but without the participation of plant personnel, the problem likely will recur.”
4. Create a contingency plan.
The French minister of war thought the Maginot Line was an impenetrable defense. German forces found a way around it; a month later, Nazis were quaffing champagne on the Champs Élysée.
Yesterday’s outcomes don’t guarantee tomorrow’s success. “The unexpected is going to pop up at some time,” observes Richard Kammerling, president of RK Pest Management Services in Huntington Station, N.Y. Instead of a rote approach to inspection, personnel should challenge themselves with what-if questions while bracing for the unexpected.
“Plant assessments shouldn’t be routine,” he adds. “Who wants to check the same 100 traps the same way, every time?”
5. Tap into educational resources.
Pesticide fundamentals, pest-proofing a plant and the principles of integrated pest management all get their due, along with sanitation principles and pertinent laws and regulations, in an online correspondence course from Purdue University. Food Plant IPM is a noncredit course with an optional text, “Truman’s Scientific Guide to Pest Management Operations.”
“Pest ID, biology and behavior and their importance in preventing and managing pests are extensively covered,” according to Professor Gary Bennett. “I do believe our course would provide the kind of foundation needed to be a ‘qualified individual.’” Inasmuch as FSMA stipulates that risk assessments be conducted by qualified individuals, his final point is important in establishing the science-based prevention that the act requires.
AIB International offers a similar program. Additionally, a number of seminars and other live events attract manufacturing personnel as well as pest-control technicians. One of the biggest is Pest Invasion, an annual seminar scheduled April 25 in suburban Chicago and presented by McCloud. This year’s event is expected to draw more than 350 attendees.
Another is the 25th edition of IPM for Food Plants, a June 7-8 seminar in Hershey, Pa., presented by RK Pest Management Services (www.rkchemical.com).
“There are essential texts -- National Pest Management Assn.’s Field Guide App, Truman’s Guide, the Handbook of Pest Control — plus online and correspondence courses, industry publications and conferences to increase your pest management knowledge,” advises Copesan’s Bennet Jordan, director-technical support & regulatory compliance. “As your knowledge increases, you can better communicate your thoughts on your program and work to implement improvements.”
6. Conduct a critical site assessment.
While site assessments are a first step in establishing a pest control program, conditions change with the seasons and over time. Don’t leave it up to a service technician to make a critical assessment of the area surrounding the facility: An orchard in an adjoining parcel will attract rodents, some of which might pay your plant a visit.
A facility nestled in the bottom of a valley is particularly prone to unexpected invasions, depending on wind velocity and the season. Positive air pressure inside the plant can help keep out windblown insects. Air curtains and door sweeps also are worth considering.
7. Address issues promptly.
Cracks in exterior walls, leaky pipes and other maintenance issues demand corrective action, and service technicians are duty bound to detail them in their reports. Unfortunately, some plant managers believe the solution to a slow response is to direct technicians to stop including the issues in their reports to eliminate a paper trail.
That’s not going to happen: to do so would be an act of professional negligence. “In the past, repairs have been looked at with different degrees of urgency,” allows IFC’s Heath. “Under FSMA, there can’t be a cavalier response.”
8. Groom a junior entomologist.
Regardless of whether a service company’s technician visits weekly or if pest management is handled in-house, a staff person with an understanding of pest biology and the ability to identify different insect species is a valuable asset. A college degree isn’t necessary, but some combination of classroom or correspondence training and field work can produce a measure of in-house expertise.
“There has to be a qualified individual to oversee activities,” points out Paul Curtis, manager-technical services for Memphis-based Terminix International Co. (www.terminix.com). “If someone is well versed in good manufacturing practices and general sanitation requirements, that’s a start. They don’t have to be an entomologist, but they should have gone through validated training and education.”
Sustainability programs that include zero waste to landfill and recycling initiatives can have a direct impact on pest management, he adds. Familiarity with those efforts, along with scrupulous record keeping and an ability to conduct a risk assessment when problems occur, help define a qualified individual.
9. Don’t overlook worker welfare areas.
FDA lists the Dirty 22, a most-wanted list of birds, rodents and insects that pose the greatest danger and are the most likely source of pest problems in food plants. But other pests can be carried in on workers’ clothing or in their personal belongings. A robust pest-control program accounts for that possibility.
Bed bugs are an example. “We find them all the time in locker rooms,” Orkin’s Harrison acknowledges. Cafeterias and rest rooms are additional landing spots for strange and exotic pests not commonly associated with food processing.
10. Take advantage of the latest tools and tactics.
Walking tours are a necessary part of any management program to identify problem areas and assess what types of pests are entering the premises and where. They are spot checks by their nature and leave unanswered questions when the breach occurred.
Low-cost sensors that detect when a trap is activated provide real-time data. Pinpointing the date and time a rodent was captured is valuable intel.
Pheromones originally were categorized as monitoring tools for specific insects. Today, they are migrating to control tools, disrupting mating patterns. The bad news is that pheromones for every type of insect found in food plants don’t exist. The good news is that the list of available pheromones continues to grow.
UV lamps typically are used in light boxes used to attract flying insects. Conversely, LED repulses most of them. That makes the LED wavelength an excellent choice for exterior light standards aimed toward the facility.
FSMA may have nothing new to say about pest control, but it is an essential element of any food-safety program. Given the intensified focus on food safety, best practices and continuous improvement in keeping pests at bay is a good rule of thumb for all food and beverage companies and not just the two in five where upgrades are being made.