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.
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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 emailed 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 logbook 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 its 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 a 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 Good Manufacturing Practices, 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. Keep the materials list current and 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.