By Lisa Lupo
The Food Safety Modernization Act (FSMA) specifies pest management as a preventive control. But what does this mean to the food processing facility — particularly in relation to exclusion practices? At its simplest, it means that it is better to combat pests prior to entry than to control them after they have established residence.
“Prevention is all about taking proactive steps to eliminate or minimize risk by eliminating conducive conditions before they occur, and preventing problems,” said Drew McFadden, director of marketing for Xcluder. Exclusion is one of the simplest and most cost effective ways to prevent pests.
It is because of the stringent standards for producing a product for human ingestion that food facilities have intensive needs to control pests, added Julie Konowitz, Mars Air Systems vice president of foodservice sales and corporate marketing. “An inability to control pests can drive the facility into violation, resulting in fines, and can also mean the loss of permanent market share when infractions occur. Exclusion practices are essential to stay in regulatory compliance and maintain confidence of their buyers.”
Pest proofing with sanitation provides the best long-term pest management program. As explained in Pest Prevention by Design by primary authors Chris Geiger and Caroline Cox, “Relatively simple design features can substantially reduce long-term pest control costs in buildings and landscapes, while also cutting the health and environmental impacts of pesticide use. However, pest preventive tactics are rarely included comprehensively at the design stage of buildings. While various lists of these tactics have been compiled, most have been piecemeal and none have been subjected to rigorous review.” It was for that very reason that this Authoritative Guidelines for Designing Pests Out of Structures was published by the San Francisco Department of the Environment and the International Code Council.
Although intended primarily for city properties and institutional kitchens, the 88-page guidebook provides a number of practical applications for food processing facilities as well. In fact, some are very simple and applicable to any building, such as using sealant and steel wool rodent blocking. “But those simple things can go a long way, even for a small business,” Geiger said.
DESIGNING IN PREVENTION. While it is simplest to design pest prevention into a facility when it is built, there are a number of techniques that can be applied during facility modifications and expansions, or simply by inspecting the facility for and correcting pest-conducive conditions.
“There really is a role for a quality pest management provider doing an inspection at the outset before the building is built,” Geiger said. The provider can identify surrounding area issues and make recommendations. For example, he said, if concrete block is used in construction, the hollow blocks can easily become a highway for rodents. It’s not difficult to seal them, but, he said, it must be done properly. Roof overhangs, eaves, and decorative trellises also should be avoided as they are highly attractive to birds. These are a particularly problematic when placed above entryways, he said, explaining,“That’s one place you really don’t want people tracking in bird crap.”
If, on the other hand, you are in an older building, you need to be aware of the attraction that plant life on or near the structure can have for pests. For example, he said, “English ivy is rat heaven. It gives them food, water, and shelter — all in one.”
Thus, whether you are building new, modifying existing, or making improvements for pest prevention, “number one is to get a good, complete inspection,” Geiger said. “Buildings are so different that you really need a trained eye looking for problems and potential problems.” There also are checklist apps, but Geiger doesn’t see these as very valuable because, he said, “there are always things that wouldn’t have been picked up by a checklist.”
An inspection enables you to customize preventive techniques and practices to your site. Some areas for consideration include:
- Doors. Installing air curtains above entryways helps inhibit flying insect entry. Air curtains can protect any door and are often used because they provide a chemical-free, consistent solution that is out of the way of foot traffic and movement patterns, Konowitz said. Because rodents can gnaw through inadequate door sweeps or dock seals, rodent-proof door sweeps and seals should be installed on exterior entry doors, garage and dock doors, and dock levelers, McFadden said.
- Cracks and Holes. A complete assessment should be made of every possible opening larger than a ¼-inch diameter in the facility and of the best way to seal and close those openings, McFadden said. The most common rodent entry points include: exterior doors, garage and loading dock doors, air vents, and points where electrical, water, gas, sewer, and HVAC lines enter the building.
Exterior Conditions. Ensure the exterior of the building, especially around the foundation, is free from harborage areas such as shrubs and ground cover, and eliminate any “bridges” to the roof such as overhanging trees.
Trash. “Placement of refuse or recycling is a pretty important design consideration,” Geiger said. It should be away from the processing area but accessible enough to be easily cleaned.
Storage. Eliminate cardboard boxes as much as possible, Geiger said. “Corrugated boxes are ideal for cockroach harborage.”
ONGOING MAINTENANCE. “We tend to think of structures as static and unchanging, but the reality is that through use, age, and exposure to the elements, they are constantly changing. Windows break, pipes rust, concrete and mortar deteriorates; these and a host of other things can create new rodent access points at any time,” McFadden said. Because rodents and other pests are always seeking and creating ways to get into a building, successful exclusion requires ongoing vigilance and upkeep.A worst-case scenario would be an unnoticed rodent infestation, potentially resulting in fines or a facility shut-down, business disruption, clean-up and remediation expenses, and damage to the business’ reputation, he added.
“Considering the risks involved, it’s easy to see how ignoring issues can be a very expensive proposition, far more than simply addressing them immediately.” But, whether designing, renovating, or maintaining a facility, McFadden said, “Make sure that all parties involved, including builders, architects and subcontractors, understand the goal and have clear direction on acceptable methods and materials.”
Also, Konowitz said, “In today’s environment, a compelling driver in solution adoption is the degree to which the solution is perceived to be toxic or not, organic or not, and least likely to cause cellular harm.”
Whether seeking preventive control for improvement or maintenance, food facilities want solutions that comply with regulatory demands, are economical, contribute to its sustainability objectives, are easy to set and forget, and don’t impose arduous upkeep on facility management. “When solutions provide other benefits, such as energy savings, and also eliminate the need for facility space for the adoption of the solution, as an air curtain does, the product becomes much more favored,” she added.
CHEMICAL REDUCTION. Proper design and exclusion can significantly reduce a facility’s reliance on pesticides and rodenticides. “If the rodents can’t get in the building, there is little incentive for them to stay in the area. As a result, the need for exterior baiting is significantly reduced,” McFadden said.
Geiger believes there are too many people still doing perimeter spraying at food facilities rather than implementing exclusion techniques. “It may not be illegal, but it’s not a great thing,” he said. Additionally, in agreement with McFadden’s statements, he said, “If you’re not providing a home for pests, they won’t be establishing themselves in these spaces, so you won’t have as much need for chemicals,” Geiger said.
“Rodents that are habituated to the building are smart. They know there is food there and they will try to get back in,” Geiger added. So if you’re not preventing pest entry, “no amount of sprays or baits will solve the problem,” he said. “The pests will always come back.”
The author is Editor of QA and can be reached at firstname.lastname@example.org.