The Key to Meeting FSMA Sanitation Standards: A Cohesive Pest Management Program

With strict sanitation standards at the forefront of Food Safety Modernization Act legislation, food processing and handling facilities need to implement a proactive pest management program developed precisely for the pest concerns and vulnerabilities specific to their needs and buildings.

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Dr. Jim Fredericks, Chief Entomologist & Vice President of Technical and Regulatory Affairs, The National Pest Management AssociationDr. Jim Fredericks, Chief Entomologist & Vice President of Technical and Regulatory Affairs, The National Pest Management Association

The food industry is a complex network of businesses that supply most of the food we eat. Ranging from farming and food production to packaging and distribution, the food industry is increasingly one of the most scrutinized in the United States.

In 2011, the Food Safety Modernization Act (FSMA) was signed into law, creating a sweeping reform to U.S. food safety and giving the U.S. Food and Drug Administration (FDA) the ability to regulate the way food is grown, harvested and processed. Aiming to ensure the nation’s food supply is safe for human consumption, FSMA shifts the focus from responding to contamination to preventing it — making sanitation arguably one of the most important operational processes for food processing and handling facilities.

Working with a Pest Professional

With strict sanitation standards at the forefront of FSMA legislation, food processing and handling facilities need to implement a proactive pest management program developed precisely for the pest concerns and vulnerabilities specific to their needs and buildings.

In fact, meeting FSMA’s sanitation standards is only achievable through proper pest management practices. Rodent droppings, cockroaches and birds are not only signs of poor exclusion measures and sanitation, but these pests also pose a risk of contaminating food products that end up in restaurants and also the homes of millions of Americans. As the food industry can directly impact the health and wellness of the American public, it is important to ensure these pests are nowhere to be found.

To help food facilities introduce proper pest management practices necessary to comply with FSMA, the National Pest Management Association (NPMA), a non-profit trade association for the professional pest management industry, issued updated guidelines in late 2016. These guidelines better reflect changing regulatory requirements, new technologies and Integrated Pest Management (IPM) practices, and provide pest control professionals with a common resource for how to service food facilities.

Working with food facilities under FSMA, pest control professionals are now required to develop programs that comply with regulations and third-party audits. NPMA guidelines offer pest control professionals and food facilities a tool that has been developed and reviewed by experts in the structural pest management industry as well as several third-party auditors. With the participation of many different parties, the NPMA guidelines allow pest control companies following them to feel confident that the food facilities they service will meet or exceed any other standard concerning pest management in these settings.

Pest management programs developed for food facilities should include a results-oriented approach that focuses on trends, inspection and observation — meaning the program developed will be unique to the facility. The NPMA guidelines help pest control professionals better prepare food facilities for pest concerns under the umbrella of FSMA and provides information on:

  • How to survey, design and implement a customized pest management program for rodents, insects, birds and wildlife
  • How to monitor for rodents, insects, birds and wildlife and signs of these pests
  • How to embrace technological advancements that provide more effective and efficient integrated pest management programs
  • How to survey for infestations and areas that may pose a risk, including building maintenance, landscape maintenance, employee practices, incoming materials, process and shipping
  • How to store pest management products to be in compliance with government regulations and site-specific policies

Pest management professionals, in addition to developing a program to proactively monitor for and prevent pest problems, need to comply with any site-specific policies such as allergen control protocols or USDA Organic requirements. They also need to ensure every protocol is written down in a comprehensive plan that can be submitted during audits. These plans need to detail how and why certain measures are being taken to best show how the food facility is being proactive to prevent contamination. All facilities should ensure the same level of preventative controls are in place to prevent a dead rat as there are to prevent foodborne illnesses such as E. coli and Salmonella. This is doubly important as some pests can carry or spread foodborne illnesses.

Working with a pest control professional is essential to developing a pest management plan that will help facilities remain in compliance with FSMA regulations. All food facilities should ensure the pest professional they hire understands the NPMA guidelines and the sanitation requirements imposed by FSMA. Pest management plans are not one-size-fits all.  They must be customized to meet the specific facilities needs and pest concerns, and include proper documentation, including:

  • Incident reports
  • Labeling of pest control products
  • Development of a specific program for the food facility that discusses implementation and monitoring

Overall, pest management is a small, yet very important aspect of the FSMA sanitation regulation, and its impact can easily be overlooked. Even food facilities that have never had a pest problem need to develop a proactive program that focuses on prevention and will help mitigate any future pest problems.

By partnering with a pest management firm that utilize the NPMA standards, food facilities can feel confident they’ll remain in compliance with new FSMA regulations and third party audits.

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