The Food Safety Modernization Act (FSMA) has had wide-ranging implications throughout the food world. As organizations absorb these changes while also trying to continue to improve on their food safety plan in general, one area which tends to get overlooked is Pest Control and the important role of a Pest Control vendor in a food safety system.

As you look for ways to better align your pest management program with your food safety system, consider the following five key areas.

Comprehensive evaluation (or re-evaluation)

FSMA and your third-party audit standard would refer to this as a “hazard analysis.” A hazard analysis allows you to identify risk. This could be as simple as performing a pest control evaluation for the purpose of identifying possible entry points or conditions that could lead to a pest infestation. When done properly, this step helps you to shift your pest control design from reactive to preventative.

Setting actionable thresholds

In a healthy pest management program, you and the provider should be discussing the triggers that would initiate a next step to control. These thresholds are specific to each pest based on their risk to your facility. If the threshold is triggered, it’s also important that all members of your food safety team be alerted of the breach and involved in the control plan. FSMA’s design of this step is to ensure that everyone is working together pro-actively to address these situations before they become a food safety concern.

Preventative controls

The pest control program should be designed in a manner that the control solutions should be focused on the preventative measures that keep pests out, rather than just performing routine applications.

Monitoring

While the devices that are placed in and around your facility are key in the monitoring step, they should not be the only items that your pest control technician examines during scheduled visits. Pests can be introduced through shipments from other sites or even from employees, so careful inspections of the entire site are critical to preventing infestations.

Documentation or recordkeeping

The data collected from service tickets coupled with the relevant program elements are essential to show a true and accurate picture of the overall health and compliance of your pest management system. Your pest control technician may be fully capable of controlling pest problems, but if they are not extremely detailed and knowledgeable about FSMA, your audit score may suffer. The following are a few of the items that we see as recurring deductions from audits as it relates to pest control:

1. Service agreements not available for review in program documents or agreements fail to meet your specific audit standards.
2. Scope of work not provided, or the site not being serviced in a manner consistent with the written scope.
3. Service tickets missing or lacking the basic requirements set forth in your audit standard and/or as mandated by your specific state regulatory agency.
4. Device Maps not present in program documents or not accurate based on the current control devices installed.
5. Trend Reports not available for review. These reports provide key information on treatments performed and pest types. They are key indicators of the overall performance of your control program.
6. Annual assessments not performed as required. The annual assessments should be strengths and weaknesses of the program over the prior year and should be used to drive continuous program improvement.
7. Sighting Reports not available or not up to date. These logs are one of the key communication vehicles between your staff and the provider. It allows your team to document pest activity and requires your provider to sign off after an issue has been corrected. This document is key to closing the loop and providing visibility that issues have been resolved.
8. Verification of training and current licensing not provided in the program documents. As a requirement of any state’s regulatory agency, pest control vendors are required to stay current on training in order to maintain their license and certification. Copies of those documents must be in their program manuals. While it’s not required, it is highly suggested that you work with a provider that has training and certifications in food safety as well. Topics like GMP, PCQI, and others demonstrate that your provider understands the role pest management plays in several of your prerequisite programs.

Focusing on these five areas will ensure that your pest control program isn’t the reason you fail an audit.