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From: Food Quality & Safety magazine, August/September 2014

Pesty Food Management

by Jim Fredericks, PhD, and Missy Henriksen

Proper pest management plays an important role in ensuring the safety of the nation’s food supply, especially inside food processing and storage facilities. In fact, several recent cases of food contamination have been traced back to facilities with pest problems. Although FDA regulations allow for a trace amount of insect parts in processed food, active pest infestations in facilities can easily result in contamination of food products.

One of the largest and most expensive food recalls in the U.S. occurred in 2009, when FDA officials discovered that the Peanut Corporation of America (PCA) had been distributing shipments of peanut-based products that were contaminated with Salmonella bacteria.

Inspections of the PCA plant revealed clear violations of basic Good Manufacturing Practices, or GMPs, including damage to the roof, which allowed rainwater to leak into the production area; mold growing on the ceilings; large gaps throughout the structure, allowing rodents easy access to the plant; and cockroaches throughout the facility.

During their investigation, federal officers also unearthed emails between PCA executives, which showed they had knowledge of the conditions in this plant and were also aware that the products had tested positive for Salmonella over a two-year period. Because of PCA’s lack of pest prevention and action in resolving infestations, the contaminated products led to a major national outbreak of Salmonella poisoning, affecting 700 people in 46 states. Nine of those cases were fatal.

PCA filed for bankruptcy and closed its doors amid a series of lawsuits. However, the case continues, as former PCA executives are scheduled to go on trial for a 76-count indictment by the U.S. Department of Justice.

In PCA’s case, structural issues and extreme pest infestations led to both serious harm of customers and the eventual shutdown of the company. Under the Food Safety Modernization Act (FSMA), the FDA has the authority to shut down facilities in which they find these types of safety violations. For this reason, proper and specific documentation of periodic pest inspections and proper sanitation practices will become increasingly important in determining compliance with the facility’s food defense plan.

Implementing a Plan

Applying a pest management plan into a standard operating procedure is the only way to make sure that facilities will consistently pass inspections and continue to manufacture safe products for consumers.

An effective pest management plan will vary by company and by facility, due to factors such as the type of food stored and manufactured, building structure, surrounding environment, and weather conditions.

To best comply with new regulations under FSMA, facility managers in decision-making positions should begin by consulting with their pest control company of record. If a specialized plan is already in place, the discussion can involve possible updates to the existing plan, as well as improved procedures for implementation, reporting, and recordkeeping.

If a preventative pest management plan is not already in place, facility managers are encouraged to work together with their pest control company to identify potential threats and how to best address them. The main elements of a good pest management plan are prevention, compliance, and response. By working through these steps, plant managers can be sure they are protecting their products and abiding by FDA regulations.

Prevention involves regular inspections and reporting of potential threats at a facility, implementing preventative treatments designed for the facility in question, and creating a set of procedures to maintain proper cleaning and sanitation of production areas. By scheduling, at minimum, monthly inspections, operators and their pest control partners will be able to quickly recognize and treat any potential pest problems.

The risks of ignoring even one sign of a pest infestation are higher than any company can afford.

Since FSMA gives the FDA the authority to perform surprise inspections in addition to a set schedule, as well as increased access to records that indicate whether or not safety measures have been implemented, and high-quality food testing by third-party laboratories, ongoing compliance will be one of the most important aspects of the new regulations. These measures are designed to make food companies more accountable for enacting and recording the measures they take to ensure food safety. Keeping updated and accurate records is essential to properly complying with new regulations. These records should include pest control procedures, the schedule of inspections, the status of employee training, and improvements in sanitation.

The final piece of an effective pest management plan is the development and implementation of an action plan should a facility face an infestation. In the majority of cases, this will involve partnering with a pest management company to quickly and completely eradicate an infestation. Signs of a pest infestation are not always obvious to the untrained eye, but can easily be uncovered by professionals who are trained to look for such evidence. In an ideal world, facilities would never have to implement these response measures, but due to the risks pests pose to both public health and companies’ reputations, being prepared for the worst-case scenario is the best option.

The Bottom Line

The negative media coverage and loss of faith from consumers as a result of a Class I recall due to contamination can cause irreparable damage to a company’s reputation, as well as the food industry’s reputation at large.

As the U.S. food industry has a direct role in ensuring the safety of the country’s food supply, companies that fail to comply with FSMA will pay a heavier price than ever before. Between the potential shutdown of facilities, fines levied by the FDA, costs of a recall, and loss of future business, the risks of ignoring even one sign of a pest infestation are higher than any company can afford. Developing a preventative plan is far easier and more beneficial to all involved than relying on a crisis management plan after the problem arises.

By implementing proper pest management programs, companies are protecting the public from the harmful effects of pests as well as protecting the interests of their business. When prevention becomes the norm, the negative attention that is often directed at the issue of food safety failures will subside, allowing public confidence in the food industry to continue to grow. For these reasons, pest management, now more than ever, is a necessity within the food industry.


Dr. Fredericks is chief entomologist and vice president of technical and regulatory affairs and Henriksen is vice president of public affairs for the non-profit National Pest Management Association. Reach Dr. Fredericks at jfredericks@pestworld.org.

Deadlines

Although the final implementation of FSMA was scheduled for June 2015, a recent agreement between the FDA, the Center for Food Safety, and the Center for Environmental Health set a staggered schedule for the following four regulations:

  • Preventative controls for human and animal food: August 30, 2015
  • Imported food and foreign suppliers and produce safety: October 31, 2015
  • Food and fee transportation: March 31, 2016
  • Intentional adulteration of food: May 31, 2016

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