Plant Audits: A Team Effort

Last month you had two third-party audits, one by a consultant and the other by a big-name retailer to which you supply product. In general, the audits went well, but now you are scratching your head over some inconsistencies between the pest control sections of the audit reports. Are your bait stations properly placed or should they be closer together? Why aren’t your pest management provider’s standard services the same as those being audited?

Such inconsistencies in pest control specifications have been a bone of contention for plants for many years. In addition, there is a range of pest management service models used in the food processing industry from external contracting to in-house management. As a result, the National Pest Management Association (NPMA) decided to take the lead in addressing the inconsistencies by developing industry standards for pest management in food plants.

The resulting “Pest Management Standard for Food Plants” was introduced at the NPMA convention in late 2006, with an effective implementation date of January 1, 2007. The purpose of the standards, their introduction states, is to “provide minimum operational criteria for servicing food plants. … To provide tools for consistent service, while at the same time, being very cautious not to interfere with individual company protocols.” However, the introduction goes on to caution, the standards do not preempt governmental regulations or food plant standards, which may be more stringent.

In most cases, though, said Robert Baker, technical director of Clark Pest Control, Lodi, Calif., in his presentation on the standards at NPMA’s 2006 PestWorld Conference, these standards set the bar higher than is required in most audits and demonstrate a breakthrough of sorts for the industry, including consensus by and participation of pest management providers, pest product manufacturers and food processing auditors.

It’s not so much that any of the standards in the document are new, Baker explained, but that the standards have been put in writing. “The only difference is it’s now in writing. It’s now been memorialized into a standard that says if you’re going to do food plant pest control, you must do these things. They are no longer optional, no longer just a good practice; they are a standard.” In addition, Baker said, the standards were written in such a way as to apply to both contract pest management providers as well as in-house service.

AUDITOR RESPONSE. AIB International, ASI Food Safety Consultants and NSF Cook & Thurber were all on the development committee and have stated they will be adopting the standards in their auditing, although the timelines for implementation vary. NSF announced its decision at the conference and in a subsequent press release, stating that as part of the company’s expectations for inspections for 2007, it will adopt the standards effective January 1.

ASI expects to begin implementing the standards early this year, says President Tom Huge. Although there is a great deal of information in the standards, “95 percent is nothing new to the industry,” he says. And because ASI was on the committee, they’ve known of the changes, so he expects that the company will review the document “to make sure what we agreed on is in there,” then be ready to integrate them into their auditing.

Al St. Cyr, AIB’s head of food safety education, sees 2007 as a transition year during which the standards can be published and communicated and elements incorporated into the current audit requirements, forms and reports. He sees both the food processing and the pest management industries as benefiting from the uniform standards. For the food processor, “it will raise the level of performance required by the pest management provider,” he says. Because increased training will be necessary for some technicians, it will raise the level of expertise within the company, which he explains, “raises their ability to compete better in the marketplace and expand their opportunities. It’s a win-win. It benefits both.”

In addition, plants will be able to ask pest management companies if they follow the standards and if they are certified according to them. (NPMA expects testing and certification to be available to technicians later this year.) Reiterating that the standards and systems are not new, St. Cyr adds that the document does add justification criteria for standards; answering “Why?” and making them defensible. “This provides very clear, auditable criteria,” he says. “The data then is auditable. Ultimately who’s going to make or break this is the individual pest management technician and company,” St. Cyr adds. The goal is to have the industry manage it itself, with the result that, he says, “their performance and actions will speak louder than their words.” 

THE STANDARDS. The standards cover five topic areas: personnel, pest management plan, communication, recordkeeping and contracts, and National Organic Program, with the sections on personnel and pest management as “the meat” of the document, and communication as the next most important piece, Baker said in the presentation. As justification, each standard includes a paragraph describing the reasoning then defines the standard. Throughout the standard, documentation is a key emphasis, he added. “That’s a word you’re going to hear me use about a hundred thousand times now, from now to the end of this program, is documentation.” Some key points of the five sections include:

Personnel

• Documentation needs to include photo identification worn at all times while on site, unless plant personnel practices prohibit the wearing of badges. 
• Providers should wear uniforms which follow plant guidelines (such as hard hat and shoe requirements; chest pocket and jewelry restrictions; etc.). As Baker explains, “You [pest management companies] need to take it to heart and treat your technicians just as if they were an employee of that facility and make them meet the same requirements.” 
• With security as a major concern of food plants today, background checks should include a criminal check five years back, with checks maintained in the employee’s records.
• All service providers should receive a written copy of applicable food plant standards that they are required to read and sign acceding consensus. 
• Vehicles should be clearly marked with the company name, properly parked, licensed and locked, and a five-year DMV check should be conducted for all drivers, with an annual review.  
• All technicians should be trained in pesticide, equipment and food-plant-specific safety, and comply with all GMPs with documentation attesting to training and understanding.

Pest Management Plan

• Rodent control programs tend to be one of the areas of greatest variation among providers and auditing agencies. These new standards base programs on thorough inspection, history and a newly developed “depth matrix.”
• In the inspection, technicians need to survey all internal and external areas for rodents, evidence of activity, maintenance or sanitation issues and other conditions conducive to rodent infestation. A summary of observations, potential infestation and recommendations is to be documented and made to the plant.
• “History now is going to have a much greater impact on the rodent control program than I think it ever has in the past,” Baker added. “In the new standards, history is as much a part of today’s service as are the active levels you find in the stations you went and observed.” History would include interviewing of plant contacts as well as review of the logbook. “Talk to these people,” Baker said. “It’s part of the process of getting to know your facility.” 
• A depth matrix, based on sensitivity and history, was developed for the standards to provide justification for rodent equipment placement. A sensitivity score is attained by charting rodent history of an area against conditions to determine the potential for infestation which then provides guidance for frequency of service and spacing of stations. “It’s really trying to put a little bit of logic behind these numbers and not trying to pull numbers out of the air based on nothing,” Baker explained. “That’s the most radically different part in the whole standard. Everything else we do is pretty basic,” he said. 
• The insect program, Baker said, is “basic, basic IPM.” Before any pesticide is applied, the service provider needs to implement techniques including source determination, harborage elimination, mechanical alteration and other non-chemical practices (such as light management). In addition, any application that is used must not contaminate any food product or surface. 
• The standards recommend weekly service of insect light traps and monitoring and categorizing of any catch to determine if there is a concern and, if so, how it should be addressed. Bulbs should be changed according to manufacturer’s directions, but at least annually. “This is probably the number one most neglected thing our industry does across the board.”
• Standards also address bird and wildlife management and weed control. Whether the service company provides weed control or not, Baker says, the technician should inspect for conditions conducive to pests and document recommendations. 
• To ensure all sightings, evidence of conducive conditions are documented and can be addressed. The pest management provider should train plant personnel in the use of the logbook. “I’d have it at the top of the list of things to try to get them to do,” Baker said.

Communication

• “This is not an ‘us and them,’ it’s a partnership,” Baker said. “The documentation and communication with the customer is really growing under this new standard.” This means all pest and pest management activity, service, etc., is to be documented and available to the plant within a reasonable amount of time.
• Trend reports, Baker said, are one of the most under-used tools available to the industry, but he sees them as becoming much more significant in the future. “Looking at those trends to evaluate not only where you have been but where you are going is going to be heavily factored in the [pest management] future.”

Recordkeeping and Contracts

• Labels, MSDSs, sighting logs, licenses, certifications – all are important to have on-site, complete and up to date. 
• Prior to completing any work in a food plant, a signed contract specifying service, frequency, terms, etc., must be in place – unless specifically waived by the plant.

National Organic Program (NOP)

• This section “in essence, just acknowledges the National Organic Program, because the NOP is a set of standards itself that were put together by USDA,” Baker said. The standards acknowledge that if a provider is servicing an organic facility, that they follow NOP guidelines. 
• The standards do add, however, that all documentation required by NOP be up to date and include documentation of the escalation process.

In addition to the five sections, the standards document includes appendices with a Model Inspection Report and relevant FDA GMPs. While the standards bring consistency to food plant pest management service and provide general guidance by which pest management providers should operate, they can not provide for every specific incident, occurrence or plant design or condition. Flexibility on the part of both the provider and plant management and employees is a key to a successful program.

As Baker noted in discussing the communication essential to the rodent program, “As these standards go, you have to have this as part of the dialogue because there is going to be that flux that you’re going to see. … so there’s some logic you’ll have to use as well as some common sense.”  QA