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Documentation: A Secret Weapon for the Audit
Proper Documentation is a Must for a Successful Audit
by Zia Siddiqi, Phd
One hundred forty: It is the magic number for an American Institute of Baking (AIB) audit. A score below 140 on any one of the five categories the AIB reviews in their “Consolidated Standards for Food Safety” will result in a score of “unsatisfactory” for the entire audit. One of those categories is pest control, which auditors across the board – from AIB to Silliker to government and customer audits – regard as an important practice to ensure food safety.
During their assessment of food and beverage processing plants, food safety auditors will examine the plant for evidence of a formal, written pest management program, preventative and control treatments and proper documentation of the program. Of these three must-haves, documentation best demonstrates the plant’s commitment to effective pest management, as updated and accurate records leave auditors a paper trail with which to evaluate the program.
Pest Management Documentation
Auditors typically focus the majority of their attention on the pest control service records. These documents include service reports describing all treatments provided during the pest management provider’s visits. Service reports will note the sources and causes of any pest infestations and indicate actionable items for the pest management provider and plant management.
Auditors also will ask to review detailed documentation of pesticide usage at the facility. The service records should include a list of approved pesticides, material safety data sheets (MSDS) for each product and detailed records on their use.
The plant must keep a log of all pesticide applications, with the trade name and active ingredient of the pesticides; dates, times and sites of applications; quantities applied; methods of application; targeted pests; and the name and current and valid state certification/license number of the applicator. Not only will auditors inspect the entirety of this information, but they also will verify that the Environmental Protection Agency (EPA) approves the pesticide for use in a food processing plant. A food plant also may have an internal approved list of pesticides.
Other required documents include detailed floor plan schematics showing the location of all pest traps, the original service contract, and the pest management provider’s liability insurance records and business license.
Fortunately, reputable pest management providers stay abreast of the latest audit requirements and can provide all of this information. Pest management professionals also recommend keeping all pest control documentation in an organized logbook. After each service inspection, the professional should add that visit’s service report to the logbook. Frequent updating and monitoring of the documents in the logbook will ensure the accuracy of the information in case of an unannounced audit.
Common Documentation Mistakes
Pest control documentation does not account for the total score of the pest control inspection, but processing plants with detailed, accurate records routinely score higher than those without them. The following common documentation mistakes can result in markdowns:
- Out-of-date trap layout map – All traps inside and outside the facility must be numbered and represented on the trap layout map. The schematic should include all bait stations, mechanical traps, glue boards and pheromone traps, among others, and must be updated with every change.
- Out-of-date insurance liability forms and applicator licenses – Pest management providers renew their liability insurance yearly, and applicators’ licenses must be renewed every few years as well. The logbook should include the current proof for both.
- Failure to keep pesticide labels and MSDS on file – All pesticides applied must be labeled and approved by the EPA.
- Incorrect pesticide usage – Materials designed to treat ants, but used for a cockroach infestation, will send up a red flag. For AIB audits, missing lot numbers for each pesticide.
Other Audit Preparation To-Dos
Pest management programs at processing plants are in constant flux due to changing seasons and operations. Providers recommend scheduling monthly or quarterly meetings to discuss the current program and any alterations that might affect pest management (e.g., changes in facility management, structural and employee practices). During these meetings, closely review all documentation for inaccuracies.
Facilities should work with their pest management providers prior to a scheduled audit to ensure that all requirements are in place and functioning. Check all traps and baits for pests and examine the plant for signs of infestation – droppings, exoskeletons and, especially, live insects or rodents.
If numerous auditing agencies review a processing plant, keep in mind that each agency has different requirements. The National Pest Management Association is currently working with third-party auditing agencies to develop universal pest control standards for all auditors.
After each audit, plant managers should meet with their pest management providers to review any deductions and create an action plan to rectify the causes. By never making the same mistake twice, facilities ensure better scores with each passing audit.
Dr. Zia Siddiqi is quality assurance director for Orkin, Inc. A Board Certified Entomologist with more than 30 years experience in the industry, Dr. Siddiqi is an acknowledged leader in the field of pest management. Dr. Siddiqi can be reached at firstname.lastname@example.org.