FSMA Changes Pest Control for Food Manufacturers

June 14, 2017
The Food Safety Modernization Act and Global Food Safety Initiative audits make processors rethink their pest management programs.

Pest management programs in the food and beverage processing industry are increasingly influenced by food safety audits and government regulations. Between the 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.

FSMA applies to virtually every food & beverage processor in the country. In a 2013 note in the Federal Register, the FDA noted that problems with both pests and pesticides were contributors to food safety incidents in the recent past.

Pest control has always been a part, although largely implied, of federal food safety requirements, at least since the 1938 Federal Food, Drug & Cosmetic Act. In a reading of the January 2013 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 2011 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 says.

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

One change, thanks to most programs certified by GFSI, is the placement and spacing of rodent devices. Most pest management programs prior to the 2013 changes 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 and 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 of pests 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.

For widespread pest control inside the plant, 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, a few years back. 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.

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