Pest Management: Following in FSMA’s Footsteps

From there, remember that proactively preventing pests is a team effort between company leadership, employees, and the pest management professional. Throughout this process, it’s important to be on the same page, so communicate frequently. And don’t forget to record your efforts every step of the way—your hard work won’t matter unless you can prove it.

Of course, in order to determine what the pest issues are and if they are close to or at the threshold, you need to monitor. Monitoring and constant improvement will help a company remain compliant with FSMA guidelines. When doing so, careful documentation is key. While it can seem tedious, one shouldn’t overlook the value of monitoring and analysis as a management tool. Collecting data and putting it in context can be an effective way to prioritize pest control efforts.

A detailed analysis will account for normal seasonal cycles, deficiencies in maintenance, exclusion, sanitation and harborages, just to name a few. This analysis can also help improve pest control efforts by prioritizing areas needing attention, especially when your staff is limited by time or resources.

That’s why careful documentation is critical, as it will help demonstrate compliance with FSMA standards. It can also help you stay audit-ready at a moment’s notice.

The Paperwork

There are six key documents to keep on hand.

1. Food safety plan. The most important piece of documentation, the overarching food safety plan should be updated regularly. The plan should be a comprehensive document detailing all activities to ensure the safety of food during manufacturing, processing, packing and holding—and now—shipping as well. It should include a list of your facility-specific potential hazards, preventative controls and corrective actions taken to mitigate those risks, along with monitoring and verification procedures.
2. List of service changes. A food safety plan needs to be dynamic. But when modifications are made to meet the ever-changing needs of a facility, keep careful records of how and why the plans have changed. As you work to stay one step ahead of changing pest pressure, you’ll need to be agile and adapt your plan quickly. Document all changes made.
3. List of monitoring devices/traps. A food safety plan should include a map documenting all monitoring equipment, traps, and other devices used in the facility to reduce the likelihood of pests. Note the locations and activity levels of pests around each. A trend report from the collected data can help advise changes to the food safety plan. A pest management professional can help with this, as they should be noting activity each time they inspect the property. The historical data from pest monitoring devices and the corrective actions associated with any issues will show any third party that pest issues are taken seriously, which puts you in a great situation from the start. Monitoring devices also work as a warning system for developing pest issues, which is key to a proactive approach.
4. Annual assessments. Each year, review the food safety plan and current food safety program. Annual assessments note problem areas and help set goals for the coming year. It will help to demonstrate year-over-year improvement and show a long-term commitment to pest management. It’ll also demonstrate that pest issues in a facility aren’t lingering over time.
5. Sighting reports. Anytime a pest is spotted within the facility, it should be documented in a pest sighting log. The report should include information about the location of pests within the facility, who found them, and the number of pests spotted. Photo evidence helps with identification, so obtain a close-up picture of the pest(s) if possible. Ensure the pest is correctly identified by a professional and any corrective actions (if necessary) are documented. Record activity levels in the area over time to ensure the problem has been resolved.
6. Proof of training/certification. You know that your pest management professional is trained and certified, but a third party doesn’t. To demonstrate a provider’s expertise, keep on hand a valid license or certification document, written evidence of the pest management professional’s training, and documentation of internal training on IPM and Good Manufacturing Practices.

Case Study

Let’s bring all of this together with a case I dealt with recently. There was a large commercial bakery that started having a German cockroach issue. This was not one of the identified potential risks because it had not come up in the past. After thorough inspections, the problem was found mostly within a wall void. The employee breakroom was located on the other side of that wall. Once the cockroaches were treated, the food safety plan was updated to reflect the newly identified risk: employees bringing in cockroaches on personal items. Corrective actions were implemented: training of employees, better sanitation in the breakroom, and door seals from the breakroom to the processing areas were sealed. New thresholds were set and monitoring devices were put in strategic areas to monitor the area and verify that the corrective actions were working. The written IPM plan was also updated and everything was documented.