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Pest Control and Food SafetyEven Pest Control Is Changed by FSMA 2

5 Common Ways to Lose Points on Your Pest Control Audit 5

The Pest That Came in From the Cold 6

Sanitation Is Pest Control 8

Special RepoRtMid-July 2013

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Pest management programs in the food & beverage pro-cessing industry are increasingly inf luenced 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 require-ment. In the agency’s Jan. 16 addition to the Federal Register (www.gpo.gov/fdsys/pkg/FR-2013-01-16/html/2013-00125.htm), 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 Fed-eral Food, Drug & Cosmetic Act, says Zia Siddiqi, director of quality systems for Orkin LLC (www.orkin.com), Atlanta. “But now the FDA has become more specific about how pest infesta-tion 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 prod-uct 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. (www.ind-fumco.com), Lenexa, Kan.

Rodent management is one of those areas that has seen some significant changes. Rodent bait packaging, distribution and la-bels 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 im-pact 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 mar-ket by late 2012.

“Old-fashioned fence line baiting is prohibited unless within 100 ft., but the current labels have sufficient f lexibility to allow rodenticide protection for the diverse kinds of facilities and out-door 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 man-agement 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 f lexible 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 ser-vice has evolved to a more general inspection routine,” says Heath.

Even Pest Control Changed by FSMA The Food Safety Modernization Act and Global Food Safety Initiative audits make processors rethink their pest management programs.By Dave Fusaro, Editor in Chief, Food Processing

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 trend-ing 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 conserva-tive 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 di-rector of McCloud Services (www.mccloudservices.com), 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 con-cern 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 re-sidual 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 down-time 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.

laRgeR aniMalS MoRe than a nuiSancePest control for food companies typically addresses the interior of a food plant and involves insects and small rodents. At times however, plant managers must venture outside to deal with larger nuisance animals. This can include birds and bats nesting on building exteriors, geese congregating on lawns and problems with squirrels, raccoons and even feral pets.

If they are not kept away from buildings, these animals can become more than a nuisance, as their wastes can compro-mise food safety and sanitation. Different strategies and tools apply here, of course. These include decoys, traps, sonic disrupters and even lasers designed to keep the pests at bay.

“Research continues into safe, effective, toxin-free pest control methods,” says Chrissy Hansen, media coordinator at Bird-X Inc. (www.bird-x.com), Chicago. “In the bird-control field, a recent introduction is the use of laser technology for large areas such as warehouses and storage areas. Laser beams make these areas inhospitable to birds.”

Bird-X provides a full line of pest control services for interior insect and rodent control, but it specializes in birds, offer-ing sonic devices, spikes and visual scares. Those scares include decoys resembling owls, foxes and even coyote, and a product called Terror Eyes — a PVC balloon depicting the face of an owl.

If deterrents are not used (or do not succeed), removal of animals also becomes an issue. For this, Advanced Weapons Technology Inc. (www.humanecapture.com), La Quinta, Calif., offers a net-launching device that allows for the humane capture of nuisance animals. The Super Talon Net Gun propels a net over an animal so that it can be safely handled and removed. The company’s website features video demonstrations involving dogs, cats an alligator and an emu.

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PEST CONTROL DOWN TO A SCIENCE.PEST CONTROL DOWN TO A SCIENCE.PEST CONTROL DOWN TO A SCIENCE.TM

As an Orkin Man, I can tell you which pests carry the most bacteria and which ones will eat into your inventory. That’s because my career with Orkin started in a classroom, studying everything from FIFO to flour beetles.

I will start with a comprehensive inspection to diagnose your pest problem. Then, I’ll help you build a custom program for maximum protection and make sure your pest control is ready when the auditor arrives.

Whether it’s in our labs or at your loading dock,I know how important it is to be scientific. After all,food safety starts with science. Your pest control should, too.

Call 800-ORKIN NOW for a free inspection and

customized recommendation.With the ever increasing demands of our daily jobs,

sometimes it’s easy to lose sight of pest management details that can make a big difference during a third-

party audit, especially with the current focus on the Global Food Safety Initiative (GFSI). That’s why Orkin Commercial Services and NSF International teamed up on myauditprep.com – a sim-ple and free, web-based tool that counts down the days until your next audit and sends you reminders and tips on important milestone dates.

While developing the tips for myauditprep.com, Orkin and NSF inspectors identified five of the most common ways food facilities lose pest control points. With pest control counting for up to 20 percent of a total audit score, be on the lookout for these common but avoidable traps.

1. No documentation of changes to service or materials since contract was signed. After a contract is signed, it is easy to forget to document changes in service or materials that evolve over time. If any elements of the current service or materials used do not match the original signed contract, be sure you have documentation of the changes and why they were made. It is also a good idea to include a written “roles and responsibilities” list that delineates the responsibilities of plant personnel vs. the pest management provider’s personnel.

2. No record of actions taken as a result of the annual pest control assessment. Your auditor likely requires that an annual facility assessment be performed by your pest management pro-vider. Be sure your records include corrective actions indicated by the assessment AND proof that these corrective actions were actually taken. Not closing this loop properly is a common way to lose points on your third-party audit.

3. Missing proof of training for pest management profes-sionals. Auditors may require any or all of the following. Your pest management professional may be trained in all of these, but do you have the proof on hand? This is a commonly missing piece.

• A copy of the certification or registration document for each person who performs pest management services in the facil-ity, if such certification is required by local regulations.

• Written evidence of the IPM service provider’s training in the proper and safe use of pest management materials.

• Verification of GMP training for anyone responsible for providing pest management services.

4. Pest sighting and trend reports don’t correspond to cor-rective actions taken. Be sure any pest activity recorded in a pest-sighting log and/or in trend reports have corresponding doc-umentation of corrective actions taken to address them. It is com-mon for facilities to lose points for having one without the other.

5. Records of light trap and pheromone trap inspections, but no records of insects found or corrective actions taken. Auditors typically require all services provided to light and pheromone traps to be documented, including the types and quantities of insects found in light traps. Many facilities omit documentation of the types and quantities of insects found in insect traps. Even if they include this data, they still could lose points if they do not have proof of corrective actions taken based on light trap inspections. Be sure you have documentation of all three: 1) services performed, 2) findings of each service AND 3) any actions taken.

Looking for more? Visit myauditprep.com and enter the date of your next third-party audit. We’ll send you – and anyone else you choose – timely pest control reminders that will help you on your path to heightened audit scores.

5 Common Ways to Lose Points on Your Pest Control AuditBy Jim Bail, Director of Technical Services, Food Processors Program, NSFAnd Zia Siddiqi, Ph.D., B.C.E., Director of Quality Systems, Orkin LLC

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P est control is an important consideration for food manufac-turing facilities at any time of the year. But as summer ends and winter approaches, food plant managers need to change

their focus and strategy if they want to keep insects and rodents out of their plants.

“Depending on geographical location, winter can provide some relief from exterior pest pressures. However, certain parts of the U.S. will see year-round pressures from outdoor insects,” says Patricia Hottel, techni-cal director at McCloud Services (www.mccloudservices.com), Hoffman Estates, Ill.

“There are definitely some seasonal pest differences in the temperate climates. There are several types of fall invading pests to expect as sum-mer comes to a close. Several of these pests invade structures in search of a place to overwinter,” she says.

In agricultural areas, the harvesting of crops can spark changes in pest behavior, even before the mercury begins to drop. And there are other seasonal forces at work.

“Ants are one of the insects we see early in the spring in northern cli-mates,” Hottel says. “Filth flies, small flies and stinging insects like yellow jackets, hornets and paper wasps, peak in July and August.”

Pests that can become more of a nuisance in the fall/harvest season include:

• Rodents, including field mice• Boxelder bugs• Brown marmorated stink bugs• Foreign grain beetles• Multicolored Asian lady beetles• Cluster flies“Each season brings different opportunities for pests to find food, wa-

ter and shelter within or around food processing, packaging or handling facilities,” adds Dale Bauerkemper, vice president of operating companies at Wil-Kil Pest Control, Wisconsin, and Holder’s Pest Solutions, Texas. Both are part of Copesan (www.copesan.com), Menomonee Falls, Wis.

Solutions typically include blocking ingress and chemical treatments, but there are some new technologies in the market.

“Although chemical applications can offer some immediate relief, environmental control methods that drop the relative humidity levels, removing the water pests need to survive, are required for real long-term resolution,” says Bauerkemper.

Paying attention to landscaping also can limit opportunities for outdoor critters and insects to find their way indoors. The latest tech-nologies for eradication are focused on disrupting reproduction, says Hottel. McCloud has recently introduced such a product that helps control moths.

“The pheromone mating-disruption products for Indianmeal moths and related species are relatively new and making a dramatic impact on the way we perform stored-product moth control,” Hottel says. “These products are working exceptionally well in impacting stored-product moth infestations.”

In pest control, an industry that has traditionally relied heavily on hazardous chemicals, these kinds of innovations represent a way to go “green.” They are also especially pertinent for food-industry clients, who must be more careful than other companies when it comes to internal environmental issues.

“Just as our world has seen technology advance exponentially in re-cent years, being green today is merely one small step compared to what green, sustainable practices will mean five or 10 years from now,” says Bauerkemper. “While we may still need pesticides, the components and use of them could be completely different.”

Food processors are accustomed to working with very specific govern-ment regulations, and for food manufacturing pest control, an example of this can be found in the area of documentation.

“The third-party food safety standards and regulatory changes are having the greatest impact on documentation requirements,” Hottel says. “Documentation has always been important but it has taken a new emphasis with more detailed information required. For example, trap captures have always been required documentation but we see increase demand for proof of written protocols and detailed documentation show-ing that the protocol has been followed. ”

Another regulatory change has eliminated the use of a specific fumigant – methyl bromide. “There are still some use patterns that have not been suitably replaced by alternative fumigants or strate-gies,” Hottel notes. “The food industry, pest management manufac-turers and pest management industry have been working to continue to find alternatives.”

Recent service elements that Copesan has introduced include RapidTrax, which enhances communication through electronic data collection including barcode validation and real-time web access to pest management programs.

Some new services also have interplay with seasonal strategies that a plant manager and a pest control provider will follow, says Randy Allen, regional manager with Wil-Kil Pest Control.

“With our electronic data collection abilities, we can look at trends and prepare proactive solutions for seasonal pest issues,” Allen notes. “For example, common sense dictates that rodents, particularly mice, move inside during the winter. However, when we run the data for food pro-cessing facilities, we often find that rodent activity starts much earlier, in late August, in Wisconsin.”

The Pest That Came in From the ColdSeasonal approaches to pest control can prevent a cold-weather invasion.By David Phillips, Technical Editor, Food Processing

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may need to be checked and addressed. Your pest professional is a great resource for identifying such conditions, but the facil-ity’s employees spend far more time in all areas of the building and will notice more items that may need attention. Effective pest prevention focuses on early interven-tion to find and stop pests before they be-come established, and everyone plays a role in this goal.

Here are some aspects of good sanita-tion practices that focus on pest preven-tion and that need to be included in the overall sanitation program:

• Attract Fewer Pests. Much attention is focused indoors for pest manage-ment and rightfully so, but outside

is where many pests issues originate or begin. Are the plants in the land-scaping attractive to ants? Do they provide cover for rodents close to the building? Do the tree branches brush against the building? Is grain spillage allowed to accumulate and sit? How often is the dumpster and surround-ing area cleaned? Is it located too close the building? Is the building equipped with bright white metal ha-lide lighting (highly attractive to in-sects) or yellow sodium vapor lamps (attract far fewer insects)?

• Minimize Harborages. More areas in which to hide near a building increase the chances of pests finding their way

inside. Are any items piled up next to the building? If so, these should be stored as far from the building as possible and up on racks, not on the ground. Is heavy, ground-covering vegetation next to the building? If so, it should be removed. Any tall grass or fields next to the building? If so, these need regular mowing.

• Deny Entry. Exclusion is by far the most important strategy in deny-ing outdoor pests from invading buildings. Do all doors have tight weatherstripping along all edges? Do employees prop them open for ventilation? If so, are they equipped with tight-fitting screen doors? Are cracks in the foundation and exte-rior walls sealed, especially at pipe and cable penetrations? Has the roof been checked for potential pest entry points (or activity)?

• Moisture Management. Moisture is the key to insect pest survival. Does water pool on the grounds outside? If so, such areas should be leveled or filled in. How are floors and equipment cleaned inside – with water under pres-sure? If so, does water pool anywhere or seep into and under walls? Where water seeps and sits supports certain flies and cockroaches.

Successful pest management and preven-tion is a cooperative effort requiring open lines of communication for identifying, reporting, and correcting conditions that may support pests or allow them access to enter the building. Food facilities should work with their pest management provider to design programs suited to that particular building’s needs and be open to adjusting the plan when necessary.

Good sanitation practices are an important component for a high-er standard of living and drive

many of the regulations in food stor-age, production, and preparation as well as medical care and many other areas of modern life. Good Manufacturing Prac-tices mandate food production facilities create and maintain comprehensive sani-tation programs. HACCP is designed to prevent biological, physical, and chemi-cal contaminates from adulterating food products, and the sanitation program plays a major role in any facility’s HACCP program.

To most people, sanitation means cleaning up or keeping areas clean or sani-tary. To those in food production, a sani-tation program is much more. To those who are responsible for pest management, sanitation is pest control.

Pest management is a prerequisite program under GMPs, and a food facil-ity may choose to conduct their pest pro-gram in-house or contract some or all of it to a professional pest control company. It is obvious why pests need to be con-trolled, as their presence can compromise a HACCP program, lead to regulatory ac-tion, and damage a company’s reputation. What may be less obvious are all the steps necessary to prevent pest infestations in the first place, and these begin long before a pest management professional comes into play.

Think of pest management as a series

of parts represented by circles. The larg-est circle by far is Prevention. The sec-ond, medium-sized circle is Monitoring, and the third and smallest circle is Treat-ments. Many pest management programs are designed such that the Prevention and Treatments circles are reversed. Such pro-grams are reactive in nature and are not suitable for an effective HACCP program. The ideal program focuses on Prevention.

Facilities need to be proactive, and pre-vention begins as raw food products reach a facility and then follows the production process to the packaging and storage of finished product shipment to the custom-er. Pest prevention needs to be built into every step of this process to deny pests the things they need to survive: food, water, harborage, and access. What each particu-lar pest species needs varies, and each food facility needs to understand which pests are of most threat and design their sanita-tion program to include preventive steps.

Stored product beetles live in the actu-al raw dry ingredients used in most foods. Some species target the whole grains and may be delivered with the corn, wheat, barley, etc. while others develop in the facility, breeding in spilled grains, grain dust, and other such accumulations. Some others may attack ingredients such as spic-es and other additives. Any one of these can be delivered into the facility by the supplying vendor so the first step in pre-vention is interception.

Interception involves spot inspections

of incoming supplies to look for pest ac-tivity. Most facilities practice intercep-tion inspections, and some do it better than others. Infested products should be rejected and suppliers may need to be ex-amined to determine whether a consistent pest risk is involved. Along these same lines, truck trailers, box cars, etc., used by facilities shipping their finished products should have periodic inspections to help prevent shipped products from becoming infested in route to the customer.

The facility Master Cleaning Schedule should be adhered to and adjusted accord-ingly based on findings. For example, a pest professional or facility crew may find a particular area continually accumulates grain dust, spillage, or moisture and that pests have been found breeding in such locations more than once. Such find-ings identify an area as a potential “pest hazard,” and steps should be taken to ad-dress them. Under HACCP, the facility should decide if structural modifications or procedural modifications may remedy the conditions supporting the pests or whether simply increasing the frequency that the area is cleaned would suffice to prevent future activity.

A proactive sanitation program should include training employees on recognition of the key pests and awareness of condi-tions that support pests or may allow pests to enter. Lines of communication need to be established where any employee can re-port not only pest activity, but items that

Sanitation Is Pest ControlBy Stoy A. Hedges, BCE; Terminix International