Pests often leave trails. Droppings, sebum stains, dead insects and various other unpleasant markers serve as proof that they are there (and often, clues as to how they got there and how to stop them).
There’s another type of trail they should leave, with human help: a paper one. Better still, a digital one.
Record keeping is an integral part of pest management. A regularly updated record, accessible by both the service provider and the client, forms the core of a pest management program. It keeps track of what’s been seen and done and often points the way to future action. It’s also needed to satisfy the various auditors who will want to know how a plant is coping with pest problems.
“Record keeping is vital. It’s an absolute,” says Dominique Sauvage, senior director of quality, training and field operations at Copesan Services. “It’s really not open for discussion – it has to be done. That record is a story, and if we haven’t told that story, we have failed.”
Pest management programs often extend for years, Sauvage says, and it’s unrealistic to expect anyone to carry those details in their heads.
“First of all, it’s a legal requirement, and of course all the major audit systems are going to be looking for it,” says Chelle Hartzer, technical services manager for Orkin Pest Control Services. “Second, it’s a great way to validate how things are going.”
At a minimum, pest management records should include a map of all devices located throughout the facility; logs of service visits, with full names of the technicians; descriptions and amounts of what each trap caught, by specific species; an overall pest management report, updated at least annually, preferably quarterly; and all relevant licenses and insurance documents. If any pesticides are applied, the record should have a full account of them, including name and EPA number.
Other things to document include plans for ongoing programs and newer projects; schedules for personnel, cleaning, inspection and maintenance; deficiencies found in operations or the physical plant; follow-up reports on completion/corrections; and a log of pest sighting by plant employees.
Regarding the last, employees should be trained in how to spot and log pests. “The pest-sighting log is a great way for the client to communicate back to the pest professional what they’re seeing when that professional is not there,” says Chad Gore, market technical director and entomologist for Rentokil Steritech.
Tracking the cause
Recordkeeping is vital because pest problems surge and ebb according to numerous factors, including structural issues, sanitation issues and procedures, employee behavior, seasonal variations and many more. Good records are necessary to correlate the appearance, and disappearance, of pests with these factors, to establish that they are in fact the cause.
“For example, say you are monitoring for Indian meal moths and you had a spike in your warehouse,” Hartzer says. “You inspect and determine which product is infested and needs to be disposed of. You should see a decline in trap numbers from then on to verify that your corrective actions worked.”
It’s important to keep track of exactly what kinds of pests the traps are catching, down to the species of insect. Different insects enter, congregate and behave differently and pose different kinds of threats.
“I’ve had a couple of situations where the client was well aware that they had a certain type of pest, but they just didn’t track it at all in their pest management records, which I just thought was weird,” said Mark VanderWerp, training director for Rose Pest Solutions, speaking at a seminar June 27 organized by McCloud Services.
Raw numbers of pests caught in a glue or pheromone trap are not enough, VanderWerp said: “You need to know what bugs are present, when, so you know what’s going on. Are the numbers going up? Are they going down? Are your control efforts working? A lot of that stuff gets back to your documentation. If you don’t have good documentation, then you don’t know.”
Solutions as well as problems need to be documented. Again, correlation is the goal: It’s necessary to show whether a problem abated after a solution was applied, by how much, and if it recurred.
“We also have to look at what did we do?” Sauvage says. “Why did we do it? What are the next steps? Did we apply pesticide? Where did we apply it? How much did we apply? What was the name of it? What was the targeted pest?”
Documentation, especially of actions in response to problems, is especially important to satisfy outside auditors.
These fall into three broad categories. A food processor’s large retail or foodservice customers may send auditors, their own or employed by a third party, to a plant to ensure that the products they’re buying are free of pest infestation. Other customers may rely on certification from organizations like AIB International. And then there’s the FDA.
All three kinds of auditors want pretty much the same kinds of information. “Each will likely have their own checklist or audit form(s). Generally, they will all be interested in many of the same things,” says Jerry Heath, product manager and staff entomologist for Industrial Fumigant Co. or IFC. “A complete and well-organized pest management service notebook, or electronic version, often starts the process off on a good note, setting the stage and suggesting that things are orderly and under control throughout.”
The three kinds of auditors might focus on slightly different things, Gore says.
“A customer of that food processing client may be looking for things that only relate to the product that they are having that food manufacturer create for them,” he says. “But they’re also concerned about the integrity of the operation – what kinds of things are done in that operation that influence their product.”
The FDA is likely to look at factors in light of the Food Safety Modernization Act (FSMA), Gore says.
“As part of FSMA, they also want to see proactive steps taken to manage pests in a facility,” he says. “They want to see risks and hazards identified, and how you’re going to mitigate them should those issues pop up.”
Don’t fudge the record
It occasionally happens that, when a pest problem is detected, a plant manager may be tempted not to enter it into the pest management record to avoid “leaving a paper trail.” Pest control experts unanimously say this is a terrible idea.
“I’ve definitely come across this before, someone doesn’t want to ‘get in trouble’ or get someone else in trouble when it comes to pest issues,” Hartzer says. “However, without documentation, those problems can’t be fixed and they typically get worse and worse over time.”
Speaking at the McCloud seminar, Meaghan Meyer, vice president of food quality and safety for CraftMark Bakery, said that an attitude like that would put a crimp in communication with the pest management provider.
“I would never want to put somebody who is doing work in my facility in a situation where I think they can’t do their job effectively,” Meyer said. “So if I were to go to Dan [Collins, McCloud’s regional technical director] and say ‘Dan, great, I hear what you’re saying, but can you please not document that. I don’t want the paper trail,’ it’s an awkward situation for him to be in. He really shouldn’t be listening to that nonsense.”
Heath of IFC recalls a case of mouse infestation in wall insulation that lasted more than 15 years, partly because a pest management technician’s observations were squelched. “A lot of risk, drama and aggravation could have been avoided over the years if the rodent harborage issue had been addressed head-on,” he says.
As for legal liability, the situation could very well get worse if it comes to light that a problem was kept out of the record. “I can tell you the legal issue will be compounded like nothing they’ve ever seen when they actually go in and they find out that you’ve been fudging the system,” Sauvage says.
Food processors should keep in mind that pest problems are widespread and just about inevitable, and that other parties – government inspectors and customers – won’t blame processors if they exist. But they will blame them for a lack of action.
“We’re guaranteed at any point that there will be an issue at a food plant. It’s just the nature of the business,” Sauvage says. “Auditors want to see, did you solve on your own, what corrective action did you take, how long did it take to correct, and have you had subsequent issues?”
An effective pest control program is a partnership that requires effective communication between the pest control provider and the client – of which good record keeping is a manifestation.