Q. I manage a medium-sized pest control company that does business with several food plants being audited by SQF and BRC. When I go to meetings, I hear stories about how much extra work these audits cause with increased documentation and corrective action reports. Would you give me some idea of what I am supposed to do?
A. I agree there are many different stories about these audits. One reason is that it is sometimes difficult to get your hands on the standards documents. Those who do get them realize that there really are no unusual demands placed on them by these audits.
One thing to understand is that these audits originated in Europe and definitely have an ISO feel to them. Some of the European wording can be misinterpreted. I can assure you that following the procedures established for good pest management practices will allow you to make it through one of these audits with flying colors. Following are some things you may want to consider.
Do you have a signed contract that outlines the level and scope of services you will be providing? Are the responsibilities for each party outlined and understood? Is someone at the facility placed in charge of the overall program, and do they interact with you on a routine basis? Do you conduct assessments to confirm that your programs meet the needs of the facility? Are all services and applications thoroughly documented? If you can answer “yes” to these questions, you are already doing what is required.
As far as the documentation and tracking of the corrective action issues, this is where some confusion exists. You, as the contractor, are responsible for bringing issues related to the pest management program to the attention of the plant. It is clearly stated in the standards that the facility is responsible for initiating and tracking progress on the corrective action(s) that must be taken. These corrective actions likely will involve things that you will be responsible for doing and documenting, but you are not in the driver’s seat.
Most GFSI auditors do not spend a significant amount of time searching through the programs, because most are not experts in the field and leave it to the plant to manage. A simple review of documentation either will tell them what they need to know or it won’t. It is your responsibility to make sure technicians clearly document their activities in their reports.
Few, if any, guidance documents exist that can be used as a reference model for establishing an effective IPM program. The AIB Consolidated Standards section 4.0 provides comprehensive guidelines as do the NPMA Standards for Pest Management of Food Plants. Having either of these as your recognized standard for establishing your program allows you to easily defend your activities if they are aligned with either of these documents.
The GFSI requirements seem to be a simplified version of either of these documents, which is okay since their main focus is on the viability of food safety programs rather than pest management.
The author is Head of Food Safety Education, AIB International. Do you have a question for Al St. Cyr? If so, e-mail him at astcyr@aibonline.org.
