It’s almost here. Can you sense it? On Monday, September 19, 2016, the Current Good Manufacturing Practices (cGMPs) and Hazard Analysis and Risk-Based Preventive Controls for Human Food (PC) compliance dates take effect for medium-sized and larger food facilities that manufacture, process, pack, or hold human food. [cGMP compliance is also mandatory on September 16 for those that manufacture, process, pack, or hold animal feed.]
Make no mistake, the shift from a reactive approach to food safety to a preventive one is a huge difference. The gap between current food safety programs and PC compliance varies greatly from one company to another. For companies that adhere to Global Food Safety Initiative (GFSI) standards, the change may not be dramatic. However, regardless of your current food safety plan, it’s essential to use this time ahead of the compliance date to conduct a final review and ensure your plan is watertight.
IDENTIFYING & MITIGATING PEST RISK. The PC rule boils down to identifying hazards to food safety, developing preventive controls to mitigate – or, ideally, prevent – described hazards, and managing/verifying that the preventive controls are indeed effective. Pests are certainly among those known or reasonably foreseeable hazards for every possible facility I can imagine. How robust is your food safety plan when it comes to identifying pest risks and being able to successfully execute pest management plans?
The subpart B of the PC final rule makes it known how welcome pests are inside a food plant. “Pests must not be allowed in any area of a food plant.… 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.” The language leaves little doubt that eliminating pest risk is a key component of meeting Food Safety Modernization Act (FSMA) standards.
That being said, anyone with food plant or pest management experience can recognize that this is a stiff challenge considering the extreme variety of pests, whether insect, rodent, bird, mite, or otherwise, that can invade your facility from the outside or emerge inside your facility from a contaminated shipment or an employee.
So, what can you do to prevent what seems like the inevitable given the challenges of meeting a zero-tolerance expectation? Now more than ever, it’s essential that you have a true partnership with your pest management provider. If you haven’t already, take the time to go over your written pest management plan with your provider, in person, and identify pest management, sanitation, and behavioral practices that could pose a risk to food safety.
Your hazards should be specific by pest type and area within your facility, based on unique conditions and potential pest susceptibilities. Use the extensive knowledge you both offer to outline, in writing, what those reasonably foreseeable risks are for your facility.
Once hazards have been identified, develop specific prevention, action, and verification steps, and test them with various scenarios that could occur. Record what works and make those processes a standard part of the program. This, in conjunction with your ongoing history of conditions identified and corrective action plans implemented when a pest threat exists, will provide an excellent base to meet the FSMA requirement of a pest management component of the written food safety plan.
DOCUMENTED TRAINING. Along with the PC final rule and cGMPs comes the requirement that employees have documented training that includes preventive controls and food safety. Pest management needs to be part of that training as well. At the very least, all employees should be aware of how to properly document pest sightings so that valuable information reaches the pest management team. Your pest management provider should help you develop the right approach for your facility and team.
In general, collaboration with your pest management provider can really make the difference for you in meeting FSMA expectations – expect a consultative approach and willingness to discuss and refine your program for the best possible results. While onsite, your technician should be identifying sanitation issues, conditions conducive to pests, and even deviations from cGMPs they see at your facility because, as rodentologist Dr. Bobby Corrigan often says, “Sanitation is pest management.”
That’s not to say that it’s sufficient to rely on your provider to take care of everything. There are structural and behavioral issues that can be addressed only by your team – and FSMA further clarifies that the responsibility of the facility is yours to ensure they are addressed. If your pest management professional documents and communicates that a missing door sweep on an exterior door presents a risk of rodents entering the facility, and you don’t address it, you will be held accountable.
In order to fulfill the spirit of the requirements set forth by the preventive controls rule, start open communication between the food safety team, all employees of your facility, and your pest management provider now. Do not delay. With deadlines just weeks away, it’s the perfect time for action!
Deni Naumann is President of Copesan.