f o o d & B e v e r ag e • c o n c e p t to d e l i v e r y • p r e s e n t to f u t u r e • f o o d p r o c e s s i n g .

c o m

Special Report
Mid-July 2013

Pest Control
and Food Safety
Even Pest Control Is
Changed by FSMA 2
5 Common Ways to Lose Points
on Your Pest Control Audit 5
The Pest That Came
in From the Cold 6
Sanitation Is Pest Control 8

Start u
 But many facilities in the food & beverage industry should consider the debate between fumigation and fogging.

Even Pest Control Changed by FSMA are still governed by audit standards requiring a formula-
based device placement scheme – or the plants lack trend-
ing data to support a reduction in device numbers. So it’s
The Food Safety Modernization Act and Global Food Safety Initiative best to check with your auditors for what is allowed. Also,
audits make processors rethink their pest management programs. many facilities are just more comfortable with a conserva-
tive program.
By Dave Fusaro, Editor in Chief, Food Processing Correct and efficient identification is the first step to
solving any pest challenge. Today, pest control experts are
Both approaches have their proponents. Neither leaves any re-
sidual chemical on surfaces, which in most cases is a benefit
but does not provide long-term killing power.
Fumigation probably is a more effective method, but
it requires a shut down of whatever work area is being
fumigated. Fumigation penetrates all cracks and crevices
and provides a high degree of certainty that every bug in
the room is dead. But it also penetrates packaging and

P
est management programs in the food & beverage pro-
cessing industry are increasingly inf luenced by food
safety audits and government regulations. Between the
two-year-old FDA Food Safety Modernization Act and third-
party audits that comply with the Global Food Safety Initiative
(GFSI), there are more rules and more prescribed steps to follow.
And a lot more record-keeping.
Just this January, FDA expanded the requirement for hazards
and analysis and critical control points (HACCP) programs to
food processors that previously were not impacted by the require-
ment. In the agency’s Jan. 16 addition to the Federal Register
(w w w.gpo.gov/fdsys/pkg/FR-2013-01-16/html/2013-00125.
htm), problems with both pests and pesticides are called out as
contributors to food safety incidents in the recent past.
Pest control has always been a part, although largely implied,
in federal food safety requirements, at least since the 1938 Fed-
eral Food, Drug & Cosmetic Act, says Zia Siddiqi, director of
quality systems for Orkin LLC (www.orkin.com), Atlanta. “But
now the FDA has become more specific about how pest infesta-
tion is a part of food contamination. And now the FDA has more
resources and its own power to shut down plants,” he says. As the
agency extends the HACCP requirement, “pest control clearly
should be a part of your HACCP program,” he says.
In another read of the January expansion of FSMA, “Pest
management in the future will pay heightened attention to prod-
uct transport vehicles, loading dock and non-food storage areas,
facility maintenance deficiencies that create pest and microbial
harborages and utilization of pest-sighting logs as part of pest
management trend analysis,” says Jerry Heath, product manager
and staff entomologist for Industrial Fumigant Co. (www.ind-
fumco.com), Lenexa, Kan.
Rodent management is one of those areas that has seen some
significant changes. Rodent bait packaging, distribution and la-
bels were revised in the past two years in response to concern for
exposures to children and non-target animals.
“Mitigation of non-target animal exposure had the most im-
pact on the food processing industry,” Heath continues. “Label
revisions in 2011 limited most outdoor rodenticide placements
to within 50 ft. of buildings. A number of shortcomings were
identified in EPA’s directive and, in remarkably fast action, the
labeling directive was revised to within 100 ft. of broadly defined
structures. Rodenticides with this new labeling were on the mar-
ket by late 2012.
“Old-fashioned fence line baiting is prohibited unless within
100 ft., but the current labels have sufficient f lexibility to allow
rodenticide protection for the diverse kinds of facilities and out-
door storages food processors utilize,” he continues.
GFSI-recognized programs are another huge motivator for
better pest management programs. “In some ways, GFSI will
have more impact on pest control than FSMA,” says Siddiqi.
While FSMA considers pest control a general recommendation
of a HACCP program, “All the GFSI-recognized programs have
very specific requirements for pest control,” he says.
One change, thanks to most programs certified by GFSI, is
the placement and spacing of rodent devices. Most pest man-
agement programs in the past followed a formula, placing them
every so many feet, but most popular audit standards compliant
with GFSI now allow for more f lexible device placements based
on known threats, ongoing inspection and history of activity.
“There have been examples where numbers of rodent control
devices have been dramatically reduced, and pest management ser-
vice has evolved to a more general inspection routine,” says Heath.
turning more and more to digital technology, specifically machines. Fumigation also has been dealt some setbacks
digital microscopes and digital photos as a reliable means by the EPA, which de-listed methyl bromide, probably the
for pest identification, says Patricia Hottel, technical di- most popular fumigant. Other effective chemicals also
rector of McCloud Services (www.mccloudservices.com), have been removed.
Hoffman Estates, Ill. For fogging, chemicals are sprayed in controlled areas.
“Digital technology such as these allow entomologists, There is less penetration. The chemicals provide a quick
field personnel and plant managers the ability to work kill, but dissipate more rapidly than fumigation, so down-
together to quickly and accurately identify pests of con- time is greatly reduced. Sequential fogging treatments
cern without sacrificing employee, product and facility can eliminate or reduce the frequency of fumigations.
safety,” she says. Heath notes that fogging can be done by pest control
Also inside the plant, for widespread pest control processors personnel or by a fixed fogging system.
Larger Animals More Than a Nuisance
Pest control for food companies typically addresses the interior of a food plant and involves insects and small rodents. At
times however, plant managers must venture outside to deal with larger nuisance animals. This can include birds and bats
nesting on building exteriors, geese congregating on lawns and problems with squirrels, raccoons and even feral pets.
If they are not kept away from buildings, these animals can become more than a nuisance, as their wastes can compro-
mise food safety and sanitation. Different strategies and tools apply here, of course. These include decoys, traps, sonic
disrupters and even lasers designed to keep the pests at bay.
“Research continues into safe, effective, toxin-free pest control methods,” says Chrissy Hansen, media coordinator at
Bird-X Inc. (www.bird-x.com), Chicago. “In the bird-control field, a recent introduction is the use of laser technology for
large areas such as warehouses and storage areas. Laser beams make these areas inhospitable to birds.”
Bird-X provides a full line of pest control services for interior insect and rodent control, but it specializes in birds, offer-
ing sonic devices, spikes and visual scares. Those scares include decoys resembling owls, foxes and even coyote, and a
product called Terror Eyes — a PVC balloon depicting the face of an owl.
If deterrents are not used (or do not succeed), removal of animals also becomes an issue. For this, Advanced Weapons
Technology Inc. (www.humanecapture.com), La Quinta, Calif., offers a net-launching device that allows for the humane
capture of nuisance animals. The Super Talon Net Gun propels a net over an animal so that it can be safely handled and
removed. The company’s website features video demonstrations involving dogs, cats an alligator and an emu.

t Previous page 2 3 Next Page u

As an Orkin Man, I can tell you which pests carry
the most bacteria and which ones will eat into
your inventory. That’s because my career with
Orkin started in a classroom, studying everything
from FIFO to flour beetles.
I will start with a comprehensive inspection to
diagnose your pest problem. Then, I’ll help you
build a custom program for maximum protection
and make sure your pest control is ready when the
auditor arrives.
Whether it’s in our labs or at your loading dock,
I know how important it is to be scientific. After all,
food safety starts with science. Your pest control
should, too.
Call 800-ORKIN NOW for a free inspection and
customized recommendation.
PEST CONTROL DOWN TO A SCIENCE.
TM
t Previous page
5 Common Ways to Lose Points
on Your Pest Control Audit
By Jim Bail, Director of Technical Services, Food Processors Program, NSF
And Zia Siddiqi, Ph.D., B.C.E., Director of Quality Systems, Orkin LLC
W
ith the ever increasing demands of our daily jobs,
sometimes it’s easy to lose sight of pest management
details that can make a big difference during a third-
party audit, especially with the current focus on the Global Food
Safety Initiative (GFSI). That’s why Orkin Commercial Services
and NSF International teamed up on myauditprep.com – a sim-
ple and free, web-based tool that counts down the days until
your next audit and sends you reminders and tips on important
milestone dates.
While developing the tips for myauditprep.com, Orkin and
NSF inspectors identified five of the most common ways food
facilities lose pest control points. With pest control counting for
up to 20 percent of a total audit score, be on the lookout for these
common but avoidable traps.
1. No documentation of changes to service or materials
since contract was signed. After a contract is signed, it is easy
to forget to document changes in service or materials that evolve
over time. If any elements of the current service or materials
used do not match the original signed contract, be sure you have
documentation of the changes and why they were made. It is also
a good idea to include a written “roles and responsibilities” list
that delineates the responsibilities of plant personnel vs. the pest
management provider’s personnel.
2. No record of actions taken as a result of the annual pest
control assessment. Your auditor likely requires that an annual
facility assessment be performed by your pest management pro-
vider. Be sure your records include corrective actions indicated
by the assessment AND proof that these corrective actions were
actually taken. Not closing this loop properly is a common way
to lose points on your third-party audit.
4 5 Next Page u
3. Missing proof of training for pest management profes-
sionals. Auditors may require any or all of the following. Your
pest management professional may be trained in all of these, but
do you have the proof on hand? This is a commonly missing piece.
• A copy of the certification or registration document for each
person who performs pest management services in the facil-
ity, if such certification is required by local regulations.
• Written evidence of the IPM service provider’s training in
the proper and safe use of pest management materials.
• Verification of GMP training for anyone responsible for
providing pest management services.
4. Pest sighting and trend reports don’t correspond to cor-
rective actions taken. Be sure any pest activity recorded in a
pest-sighting log and/or in trend reports have corresponding doc-
umentation of corrective actions taken to address them. It is com-
mon for facilities to lose points for having one without the other.
5. Records of light trap and pheromone trap inspections, but
no records of insects found or corrective actions taken. Auditors
typically require all services provided to light and pheromone traps
to be documented, including the types and quantities of insects
found in light traps. Many facilities omit documentation of the
types and quantities of insects found in insect traps. Even if they
include this data, they still could lose points if they do not have
proof of corrective actions taken based on light trap inspections. Be
sure you have documentation of all three: 1) services performed, 2)
findings of each service AND 3) any actions taken.
Looking for more? Visit myauditprep.com and enter the date
of your next third-party audit. We’ll send you – and anyone else
you choose – timely pest control reminders that will help you on
your path to heightened audit scores.
The Pest That Came
in From the Cold
Seasonal approaches to pest control
can prevent a cold-weather invasion.
By David Phillips, Technical Editor, Food Processing
P
est control is an important consideration for food manufac-
turing facilities at any time of the year. But as summer ends
and winter approaches, food plant managers need to change
their focus and strategy if they want to keep insects and rodents out
of their plants.
“Depending on geographical location, winter can provide some relief
from exterior pest pressures. However, certain parts of the U.S. will see
year-round pressures from outdoor insects,” says Patricia Hottel, techni-
cal director at McCloud Services (www.mccloudservices.com), Hoffman
Estates, Ill.
“There are definitely some seasonal pest differences in the temperate
climates. There are several types of fall invading pests to expect as sum-
mer comes to a close. Several of these pests invade structures in search of
a place to overwinter,” she says.
In agricultural areas, the harvesting of crops can spark changes in pest
behavior, even before the mercury begins to drop. And there are other
seasonal forces at work.
“Ants are one of the insects we see early in the spring in northern cli-
mates,” Hottel says. “Filth flies, small flies and stinging insects like yellow
jackets, hornets and paper wasps, peak in July and August.”
Pests that can become more of a nuisance in the fall/harvest season
include:
• Rodents, including field mice
• Boxelder bugs
• Brown marmorated stink bugs
• Foreign grain beetles
• Multicolored Asian lady beetles
• Cluster flies
“Each season brings different opportunities for pests to find food, wa-
ter and shelter within or around food processing, packaging or handling
facilities,” adds Dale Bauerkemper, vice president of operating companies
at Wil-Kil Pest Control, Wisconsin, and Holder’s Pest Solutions, Texas.
Both are part of Copesan (www.copesan.com), Menomonee Falls, Wis.
Solutions typically include blocking ingress and chemical treatments,
but there are some new technologies in the market.
“Although chemical applications can offer some immediate relief,
environmental control methods that drop the relative humidity levels,
removing the water pests need to survive, are required for real long-term
resolution,” says Bauerkemper.
Paying attention to landscaping also can limit opportunities for
outdoor critters and insects to find their way indoors. The latest tech-
nologies for eradication are focused on disrupting reproduction, says
Hottel. McCloud has recently introduced such a product that helps
control moths.
t Previous page 6 7 Next Page u
Pest management
is food safety
“The pheromone mating-disruption products for Indianmeal moths
and related species are relatively new and making a dramatic impact on
the way we perform stored-product moth control,” Hottel says. “These
products are working exceptionally well in impacting stored-product
moth infestations.”
In pest control, an industry that has traditionally relied heavily on
hazardous chemicals, these kinds of innovations represent a way to go
“green.” They are also especially pertinent for food-industry clients, who
must be more careful than other companies when it comes to internal
environmental issues.
“Just as our world has seen technology advance exponentially in re-
cent years, being green today is merely one small step compared to what
green, sustainable practices will mean five or 10 years from now,” says
Bauerkemper. “While we may still need pesticides, the components and To achieve food safety at HACCP standards, pest control has to go beyond just
use of them could be completely different.”
Food processors are accustomed to working with very specific govern- reactive pest treatment. That’s why Terminix® Commercial takes an Integrated Pest
ment regulations, and for food manufacturing pest control, an example Management approach.
of this can be found in the area of documentation.
“The third-party food safety standards and regulatory changes are
having the greatest impact on documentation requirements,” Hottel Our technicians work with your staff to develop a strategy that denies pests
says. “Documentation has always been important but it has taken a new food, water, harborage and access. We help teach your employees to spot pest
emphasis with more detailed information required. For example, trap
captures have always been required documentation but we see increase activity. And when treatment is necessary, we go beyond the norm, deploying
demand for proof of written protocols and detailed documentation show- resources like RapidFreeze® for chemically sensitive areas. From cockroaches
ing that the protocol has been followed. ”
and flies to rodents, birds and more, Terminix Commercial understands that food
Another regulatory change has eliminated the use of a specific
fumigant – methyl bromide. “There are still some use patterns that safety is not just about getting pests out. It’s about keeping pests out.
have not been suitably replaced by alternative fumigants or strate-
gies,” Hottel notes. “The food industry, pest management manufac-
turers and pest management industry have been working to continue
Terminix CommerCial advanTages:
to find alternatives.”
• ScanMaster ® Tracking – Our handheld system provides reports
Recent service elements that Copesan has introduced include
instantly and accurately to your online account portal
RapidTrax, which enhances communication through electronic data
collection including barcode validation and real-time web access to pest • RapidFreeze – Our innovative non-toxic pest control solution
kills pests and their eggs with a freezing spray of CO2
management programs.
Some new services also have interplay with seasonal strategies that a • Fly control – We customize a solution with advanced tools like
Insect Light Traps and our natural sprays
plant manager and a pest control provider will follow, says Randy Allen,
regional manager with Wil-Kil Pest Control.
“With our electronic data collection abilities, we can look at trends
and prepare proactive solutions for seasonal pest issues,” Allen notes. “For ConTaC T Te rminix Com m e rCial Today.
example, common sense dictates that rodents, particularly mice, move
inside during the winter. However, when we run the data for food pro- 1.800.Terminix | TerminixCommercial.com
cessing facilities, we often find that rodent activity starts much earlier, in
late August, in Wisconsin.”
© 2013 The Terminix International Company Limited Partnership. All rights reserved.

Sanitation Is Pest Control
By Stoy A. Hedges, BCE; Terminix International
G
ood sanitation practices are an
important component for a high-
er standard of living and drive
many of the regulations in food stor-
age, production, and preparation as well
as medical care and many other areas of
modern life. Good Manufacturing Prac-
tices mandate food production facilities
create and maintain comprehensive sani-
tation programs. HACCP is designed to
prevent biological, physical, and chemi-
cal contaminates from adulterating food
products, and the sanitation program
plays a major role in any facility’s HACCP
program.
To most people, sanitation means
cleaning up or keeping areas clean or sani-
tary. To those in food production, a sani-
tation program is much more. To those
who are responsible for pest management,
sanitation is pest control.
Pest management is a prerequisite
program under GMPs, and a food facil-
ity may choose to conduct their pest pro-
gram in-house or contract some or all of
it to a professional pest control company.
It is obvious why pests need to be con-
trolled, as their presence can compromise
a HACCP program, lead to regulatory ac-
tion, and damage a company’s reputation.
What may be less obvious are all the steps
necessary to prevent pest infestations in
the first place, and these begin long before
a pest management professional comes
into play.
Think of pest management as a series
t Previous page
of parts represented by circles. The larg-
est circle by far is Prevention. The sec-
ond, medium-sized circle is Monitoring,
and the third and smallest circle is Treat-
ments. Many pest management programs
are designed such that the Prevention and
Treatments circles are reversed. Such pro-
grams are reactive in nature and are not
suitable for an effective HACCP program.
The ideal program focuses on Prevention.
Facilities need to be proactive, and pre-
vention begins as raw food products reach
a facility and then follows the production
process to the packaging and storage of
finished product shipment to the custom-
er. Pest prevention needs to be built into
every step of this process to deny pests the
things they need to survive: food, water,
harborage, and access. What each particu-
lar pest species needs varies, and each food
facility needs to understand which pests
are of most threat and design their sanita-
tion program to include preventive steps.
Stored product beetles live in the actu-
al raw dry ingredients used in most foods.
Some species target the whole grains and
may be delivered with the corn, wheat,
barley, etc. while others develop in the
facility, breeding in spilled grains, grain
dust, and other such accumulations. Some
others may attack ingredients such as spic-
es and other additives. Any one of these
can be delivered into the facility by the
supplying vendor so the first step in pre-
vention is interception.
Interception involves spot inspections
8 9
of incoming supplies to look for pest ac-
tivity. Most facilities practice intercep-
tion inspections, and some do it better
than others. Infested products should be
rejected and suppliers may need to be ex-
amined to determine whether a consistent
pest risk is involved. Along these same
lines, truck trailers, box cars, etc., used by
facilities shipping their finished products
should have periodic inspections to help
prevent shipped products from becoming
infested in route to the customer.
The facility Master Cleaning Schedule
should be adhered to and adjusted accord-
ingly based on findings. For example, a
pest professional or facility crew may find
a particular area continually accumulates
grain dust, spillage, or moisture and that
pests have been found breeding in such
locations more than once. Such find-
ings identify an area as a potential “pest
hazard,” and steps should be taken to ad-
dress them. Under HACCP, the facility
should decide if structural modifications
or procedural modifications may remedy
the conditions supporting the pests or
whether simply increasing the frequency
that the area is cleaned would suffice to
prevent future activity.
A proactive sanitation program should
include training employees on recognition
of the key pests and awareness of condi-
tions that support pests or may allow pests
to enter. Lines of communication need to
be established where any employee can re-
port not only pest activity, but items that
may need to be checked and addressed.
Your pest professional is a great resource for
identifying such conditions, but the facil-
ity’s employees spend far more time in all
areas of the building and will notice more
items that may need attention. Effective
pest prevention focuses on early interven-
tion to find and stop pests before they be-
come established, and everyone plays a role
in this goal.
Here are some aspects of good sanita-
tion practices that focus on pest preven-
tion and that need to be included in the
overall sanitation program:
• A ttract Fewer Pests. Much attention
is focused indoors for pest manage-
ment and rightfully so, but outside
is where many pests issues originate
or begin. Are the plants in the land-
scaping attractive to ants? Do they
provide cover for rodents close to the
building? Do the tree branches brush
against the building? Is grain spillage
allowed to accumulate and sit? How
often is the dumpster and surround-
ing area cleaned? Is it located too
close the building? Is the building
equipped with bright white metal ha-
lide lighting (highly attractive to in-
sects) or yellow sodium vapor lamps
(attract far fewer insects)?
• M inimize Harborages. More areas in
which to hide near a building increase
the chances of pests finding their way
inside. Are any items piled up next
to the building? If so, these should
be stored as far from the building as
possible and up on racks, not on the
ground. Is heavy, ground-covering
vegetation next to the building? If so,
it should be removed. Any tall grass or
fields next to the building? If so, these
need regular mowing.
• D eny Entry. Exclusion is by far the
most important strategy in deny-
ing outdoor pests from invading
buildings. Do all doors have tight
weatherstripping along all edges?
Do employees prop them open for
ventilation? If so, are they equipped
with tight-fitting screen doors? Are
cracks in the foundation and exte-
rior walls sealed, especially at pipe
and cable penetrations? Has the roof
been checked for potential pest entry
points (or activity)?
• Moisture Management. Moisture is
the key to insect pest survival. Does
water pool on the grounds outside?
If so, such areas should be leveled or
filled in. How are floors and equipment
cleaned inside – with water under pres-
sure? If so, does water pool anywhere or
seep into and under walls? Where water
seeps and sits supports certain flies and
cockroaches.
Successful pest management and preven-
tion is a cooperative effort requiring open
lines of communication for identifying,
reporting, and correcting conditions that
may support pests or allow them access to
enter the building. Food facilities should
work with their pest management provider
to design programs suited to that particular
building’s needs and be open to adjusting the
plan when necessary.