Your facility has most likely already implemented changes to abide with Food Safety and Modernization Act (FSMA), so now is a great time to check on how things are going as it relates to your pest management program.
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FSMA regulations mandate a shift from a reactive to preventative approach with a heavy emphasis on documentation. A pest management program should mirror this preventative aspect of FSMA. An integrated pest management (IPM) program will look at all factors that may affect a facility. It should be a targeted plan to not only deal with pests, but to prevent them and minimize their impact before they become a problem. The Preventative Controls for Human Food Regulation within FSMA requires that food plants have a written preventative pest management plan. Think about the last time you reviewed your overall IPM plan for your facility. Whether you have a pest management provider or perform your own in-house pest management, a review should be done on a yearly basis or when conditions significantly change.
Chances are that this IPM plan has been given a cursory glance at the end or beginning of the year, the date changed, and the program has continued similar to previous years. Take some time to really go through the plan, check the data and trend reports from the last 12-24 months, and see what’s working and what’s NOT working. Look for ways to make the entire program more effective and as preventative as possible. FSMA aims to prevent issues in the food system and the IPM program uses an entire toolbox of methods to do just that with pest issues.
In order to prevent, facility managers must do their best to predict where future infestations might occur. In other words, a program needs to stay one step ahead of the pests trying to invade your facility.
Specifically, be prepared to answer anything that could be considered a “reasonably foreseeable biological, chemical, and physical hazard.” If something is contaminated, it no longer matters if it occurred naturally or intentionally. You must have documentation of your efforts. This doesn’t mean you need to scrap the food safety plan developed to meet Hazard Analysis and Critical Control Point (HACCP) standards, but you’ll need to make modifications with the help of a Preventive Controls Qualified Individual (another new requirement).
To ensure a food processing facility is meeting all of the requirements necessary, there are a few crucial steps that need to be taken.
Path to Compliance
Most pest management companies offer a free initial inspection, so take advantage of it! A full inspection of the facility should be done at least annually, even if you haven’t dealt with an infestation in the past year. You never know what pests could be lurking behind the scenes, especially if you’re keeping a lot of product stored in the facility. Be sure that pests haven’t compromised the packaging, or an infestation could spread quickly.
After the initial inspection, staff training is a must. A few employees cannot be expected to monitor an entire facility but assigning all employees a specific role (based on their job function) can lead to quicker discovery of pest problems. Many pest management providers offer complimentary employee training programs to teach facility staff the signs of pest infestations. By doing so, individuals feel empowered to call out the danger signs, which will enable you to get ahead of pest issues faster. Think of it like this: If you’re coaching a soccer team, you wouldn’t send six players out at the start of a game when you’re allowed 11. All your employees are key players when it comes to detecting pests.