The QA manager at a large food processing facility spots signs of possible rodent activity—gnaw and rub marks on shipping pallets, and some droppings on the exterior of his facility—and lets the technician from his pest management provider know about it while the tech is performing his normal service visit.
Eager to satisfy the client and eliminate the problem, the technician installs two additional bait stations in the area where the activity was reported and continues his service visit.
Back in his truck, the technician completes his service report but, because the visit ran long, he is in a hurry and inadvertently forgets to record that he installed the new stations. The service order is filed, the technician moves on, and the client does not immediately review the e-mailed service order because he has a budget meeting for which to prepare.
The seemingly harmless actions of the technician and QA manager could cost them both dearly if an auditor or government inspector notices stations that are not recorded in the pest log book or marked on the facility map. It could result in the facility being written up or even failing an audit, which could be costly on several fronts.
The moral of this tale is that in today’s business climate properly documenting all pest management and food safety related actions within a food processing facility is a must and incidental oversight isn’t an excuse.
Documentation has always been an important part of a food processing facility’s operations, but now the Food Safety Modernization Act (FSMA) mandates documentation be even more organized, detailed, and accessible.
A food processing facility’s documentation must produce the following trail of information for auditors and inspectors:
- Show that a pest management program is in place to intervene and eliminate pest threats;
- Describe the pest issue and what the response was to the issue;
- Document the effectiveness of the response; and
- Document that the risk to the facility has been mitigated.
The documentation provided by a pest management professional and the QA manager for the facility will be closely scrutinized by regulators and auditors. If there is a pest incident or failure, the documentation needs to show that the facility and their pest management partner did everything in their power to prevent it and that the failure has been acted upon and the desired results (i.e. pest elimination) achieved.
While pest management professionals are accountable for their work, food processing clients are ultimately responsible for the pest management program within their facilities. A big part of that responsibility is documentation.
Key Documentation Tools
Two of the most important elements in the documentation process are the logbook and the service order. These two items are the brushes that paint the picture of what is happening at your facility when it comes to pest management.
Logbook. A facility’s logbook includes all the essential pieces of information that a QA or facility manager and their pest management vendor needs. It contains all applicable business and applicator licenses, certificates of insurance, and proof of training in GMPs, food plant procedures, and FSMA.
The logbook should also include a materials list of what pest control products are approved for use in the facility. The product’s tradename, manufacturer, and EPA registration number, as well as product label and safety data sheet (SDS) would also be in the logbook. It is important to keep the materials list current and is best to have both the technician and client contact sign off on the list each time a product is added or removed.
Service order. The service order used to be a basic summary of what was done during that visit to the facility. The new FSMA mandates have changed all that.
No longer will simply scanning barcodes on bait stations or noting basic sanitation issues cut the mustard. The devil is in the details and today’s service order must be heavy on the details.
Pest management technicians now include greater detail sharing who, what, where, when, and why of their service. They detail who they spoke with, what pest-conducive conditions were present, and what corrective actions were taken.
A good service order will always detail what product was used, how it was used (i.e. crack and crevice, spot treatment, bait station application, etc.), and where in the facility (i.e. a crack and crevice treatment in the shaker room corner) it was applied.
The comments section of today’s service order allows facility managers to visualize the services provided and keep track of the progress of their overall pest management program.
Content Rules the Day
It is not enough to just capture data today. It is about capturing the right data. Data that will help predict pest trends and allow pest professionals and QA managers to develop a proactive response—is what really matters.
When pest control companies pull together documentation for a facility, technicians concentrate on the following items: pest thresholds, pest vulnerable zone inspections, and corrective actions.
By collecting data in these three critical areas, pest control companies can accurately portray—often in real-time—the current condition of the facility’s pest management program.
Pest thresholds. A strategic pest threshold paired with corresponding corrective action plans is the foundation of a proactive pest management plan. Collecting and monitoring data on pest thresholds identifies established action thresholds and provides a specific recommended response to a situation. If a threshold has been exceeded, the action plan provides a step-by-step game plan on how to react to the pest activity.
Pest vulnerable zone (PVZ) inspections. PVZs are areas in a facility that require additional inspection because of the likelihood of increased pest pressure. Pest pressures tend to be heightened in areas that have historically seen pests, such as those determined by trending reports, or areas that are at a higher risk for infestations because of their business function, such as receiving and production areas. PVZs are barcoded in the area and scanned for verification while performing the inspection and, of course, all findings are documented.
Corrective action. If a pest-conducive condition (i.e. damaged door sweep or opening in the roof) or pest activity, like rodent droppings or fly larvae in a drain, is observed, corrective action must be taken by either the pest management vendor and/or the facility.
Documenting the corrective action that was taken accomplishes several tasks:
- It creates a “paper trail” for tracking who was responsible for carrying out the corrective action;
- It details what actions were taken and when; and
- It outlines the results of the corrective action—something auditors pay close attention to when completing their audits.
The Big Picture
Continuously documenting specific and prescriptive comments allows QA managers and pest professionals to conduct a deeper dive into the real reasons behind a pest threat.
Detailed documentation also helps create a level of transparency and accountability. Using the latest in handheld and digital technology (i.e. Google maps of where all the bait stations are located around your facility or characteristics of neighboring properties that could be creating conducive conditions) allows pest professionals to share information instantaneously with not only the local facility management, but also corporate QA contacts located across the country.
In the post-FSMA era, something that is not written down, simply didn’t happen in the eyes of an auditor, inspector, or the court. Establishing and following proactive documentation protocols will not only keep your facility compliant and improve efficiency in operations, it will protect your brand and your bottom line.
McCoy, the director of quality and technical training at Wil-Kil Pest Control, is an Associated Certified Entomologist and has been in the structural pest management field since 1995. Reach him at firstname.lastname@example.org.