What would you do if you saw a bird in your facility? What would your employees do? What would FDA do?
In the Preventive Controls rule of FSMA, FDA specifically defines pests as referring to “any objectionable animals or insects including birds, rodents, flies, and larvae.” In relation to that, the rule states that “pests must not be allowed in any area of a food plant.” This is because, as FDA explains in the rule, “Areas of the food plant (such as a cafeteria) that are not directly involved with production may nonetheless be a source of contamination (e.g., if there are pests in that area).”
Further to that, the rule states, “Effective measures must be taken to exclude pests from the manufacturing, processing, packing, and holding areas and to protect against the contamination of food on the premises by pests.”
With FSMA specifically naming birds as pests, pests being prohibited from any area of the food plant, and effective exclusion measures required, you can expect that an FDA inspector bird-sighting would have the same impact as any other non-compliance, e.g., a 483 citation.
From that, it follows that if you, or an employee, see a bird in your facility, action must be taken for removal and further exclusion efforts.
THE PROBLEM. Because of the beauty of songbirds and the common practice of having birds as pets, they are often perceived to be harmless and even desirable. But, in actuality, said Bird-B-Gone Bird Expert Scott Swanson, birds are no different than rats when it comes to the potential of contamination, and they should be treated the same as any other pest.
“Most people are shocked to discover that pest birds and their debris can carry over 60 known transmittable diseases,” Swanson said, naming Salmonella, E. coli and Histoplasma as three key disease vector birds can transmit. “With these risks in mind, employee safety, inventory damage, work stoppage and consumer health come to the fore as areas of primary concern,” he said.
Add to that the regulatory issues, such as the lack of a written Integrated Pest Management program and/or the failure to include birds in this plan, which he has seen as common mistakes of food facilities, and the concern deepens. “With FSMA compliance audits on the rise, now is the time to develop your bird control plan,” Swanson said.
While FDA is unlikely to cite a plant for exterior birds (unless they are so numerous as to be a known issue), a bird in your plant is most likely to have made its way in from the exterior. In fact, the most common mistakes seen by William Kern, Jr., associate professor of entomology & nematology at the Ft. Lauderdale Research and Education Center, are trespassing birds coming in through open doors, and facilities’ failure to use devices to prevent bird or insect entry.
Along with simply not having preventive devices, there are issues of employees “turning off air curtains, propping doors open, leaving loading doors open, etc.,” he said.
As such, a lack of processes or procedures relating to the regular inspection of the environment, perimeter, and rooftop of the facility is a common issue Swanson’s company has seen.
THE SOLUTIONS. From physical and sensory deterrents to habitat modification and employee training, there are a number of long-standing, as well as newly innovative, ways to keep birds from being a contamination risk.
Established Deterrents. The first step in control of pests that come from the exterior is to avoid attracting pests in the first place. In relation to birds, the best deterrents make the area physically or sensorially uncomfortable for roosting or breeding. Some well-established pest-bird deterrents include:
- Physical deterrents, such as bird spikes, electrical tracks, and transparent gels, can keep birds from roosting on ledges, sills, and overhangs, while netting can block them from entering through eaves and other openings, and keep them from settling on rafters and beams. Keeping birds from getting to areas they have or would like to roost, perch or nest, forces them to move to other locations — away from your facility.
- Sensory deterrents also can dissuade pest birds from nesting or roosting on your property. If you disturb their senses through sight or sound, you can effectively scare birds away. While plastic decoys (such as hawks, owls, snakes, eye balloons, etc.) and reflective surfaces can have some impact, they need to be moved regularly or the birds will become accustomed to them and ignore them.
- Habitat modification also can go a long way in bird control: Seal holes and gaps, mend cracks, etc., to eliminate bird access points and reduce potential nesting areas. Clean up bird droppings and nesting materials, as these attract other birds to the area. Keep trash areas clean and bins tightly lidded, discourage employees from feeding birds, and remove any feeders to reduce food sources that attract the birds.
New Innovations. In addition to these well-established bird deterrents are some new innovations that are proving to successfully limit bird presence and intrusion. Among these are:
- Lasers. Kern has seen an increased use of lasers for bird harassment. Birds perceive an approaching laser beam as a physical danger from which they are humanely repelled, flying away to take up residence elsewhere. Laser-beam technology can repel pest birds over great distances; is most effective at sunrise and sunset and in overcast, rainy, or foggy weather conditions; and generally takes about a week for the birds to see the area as unsafe and avoid your property.
- Aromatic Bird Repellents. Methyl anthranilate systems are increasingly being used to repel birds. This non-toxic, grape-extract system releases a fine mist into the air which irritates the birds’ senses through entry in the eyes, nose or mouth, discouraging their entry, roosting, or nesting in the area. Because it is a food grade material, and it is recognized by the FDA as a safe substance, the aromatic repellent can be used in areas that are often hard to treat. Some systems are programmable, allowing the treatment to fit to the facility’s schedule.
- Drones. Advancements that have been made in remote-control drones have resulted in a vast array of uses — including that of scaring off birds. With some looking just like predators (e.g., hawks) while others retain the standard helicopter drone appearance, the new bird control drones are used to disperse flocks and discourage resettling.
- Artificial Intelligence (AI). The newest advancement in drones is a system which uses AI and machine learning (ML). Fully autonomous, it can identify species to drive away pest birds, Swanson said. The system uses a protective perimeter of motion sensors to automatically detect and deploy AI-driven ground or aerial drone technology.
EMPLOYEE TRAINING. No bird management program will be successful without the cooperation of employees, which is why education is critical. Without an understanding of the “why” of bird management, employees are more likely to feed birds outdoors, allow doors to be left open, and ignore a bird seen roosting in the rafters — any of which can lead to contamination of your product.
“Education remains your most valuable asset when it comes to protecting your employees and the public from the health risks pest birds present,” Swanson said. Thus, it is important to incorporate bird control into your integrated pest management program, have mechanisms in place to drive accountability, and ensure a thorough understanding of the issues of fecal contamination as a source of E. coli and Salmonella.
“Public health should be one of every employees’ considerations and goals,” Kern said. “A single bacterial contamination incident can cost a manufacturer an entire year’s profit and cause severe and long-lasting public relations impact.”
FINAL WORDS. While installing deterrents and working with a pest control partner can help you manage bird intrusion, “don’t assume that hiring a pest management company will solve all bird problems,” Kern said. “Follow their recommendations for structural modification and employee behavioral issues.”
Additionally, Swanson said, “Whatever you do, don’t ignore the problem. Entrenched bird control issues are infinitely more complex and costly to solve. Make the commitment to keep your employees and customers happy and healthy, have a plan in place, and head off issues before they start.”