Maintaining proper documentation of pest management programs is a top priority for many food processing facilities, however, it can inadvertently be neglected during busy, high-stress situations. With the updated Food Safety Modernization Act (FSMA) mandating documentation be even more organized, detailed and accessible, along with assigning harsher penalties if a facility doesn’t comply with these new mandates, quality assurance (QA) and facility managers need to be sure they know the steps to accurate documentation.
When it comes to documentation, QA and facility managers must remember: accuracy, consistency and thoroughness. This means you must document the situation so the auditor can visualize the exact steps that were taken to resolve the pest control issue, including when there is a pest incident or pest control failure. To do this, a food processing facility’s documentation must:
- Show that a pest management program is in place to intervene and eliminate pest threats
- Describe the pest issue and what the response was to the issue
- Document the effectiveness of the response
- Document that the risk to the facility has been mitigated
Documentation is one of the most important parts of maintaining a pest-free food processing facility. To ensure you complete the four steps above, there are two key documentation tools that should be utilized to ensure you provide auditors with accurate and consistent data – logbooks and service reports.
Logbooks, the Pest Control Handbook
A facility’s logbook is the food processing plant’s pest control handbook. It contains all the essential pieces of information employees and pest management professionals need in order to ensure accuracy and consistency. This is the tool auditors will use to ensure the facility has a professional pest management program in place. The logbook must contain the following information:
- All applicable business and applicator licenses
- Certificates of insurance
- Proof of training in GMPs
- Service specifications
- Device map
- Service reports from past services
- Trending reports
- Annual facility assessment
- Current materials list of the pest control products approved for use in the facility. This list should include the product’s tradename, manufacturer, EPA registration number as well as the product label and safety data sheet (SDS).
Now that the auditor knows a pest management program is in place, they must see the preventative steps being taken, the pest issues, the responses, the effectiveness of the responses and documentation when the issue has been eliminated. All this information should be included on the service reports and service reports should be in the logbook.
Service Report Expectations
Many remember the service report as a basic summary of the pest control services done during each visit. On these service reports in the past, pest management professionals could simply scan bar codes on bait stations or note basic sanitation issues, however, with today’s FSMA mandates, pest control services performed must be identified in much more detail.
Service reports now require the five W’s – who, what, when, where and why. A pest control professional must specify:
- Who they spoke with
- What pests/conducive conditions were found
- Why pests/conducive conditions exist
- What corrective actions were taken
- When corrective actions took place
This amount of consistent detail allows auditors and QA or facility managers to visualize the service that was provided so they can understand the pest management program and ensure compliance at the facility.
Check the Data
While it is up to the pest management company to accurately document their visit on the service report, the QA or facility managers must also ensure it is correct, as the auditors will look to them if something is wrong. QA and facility managers should be sure that the following information is included in the collected data before the pest management technician leaves the facility.
Check the Pest Thresholds
The pest threshold is the number of pests or the amount of pest damage allowed before corrective action is made to eliminate the pest. QA and facility managers should be sure this is accurately monitored and recorded to ensure the threshold is not reached. If the threshold is reached, check if the pest management technician has provided a specific recommended response to the situation. This response should be a step-by-step plan on how to lower the pest activity for this area so it reaches the appropriate threshold once again.
Inspection of Pest Vulnerable Zone (PVZ)
QA and facility managers should also be aware of pest vulnerable zones throughout their facility. These areas require additional inspection due to increased pest pressures. These areas usually include, shipping and receiving and points of entry at the facility. The zones are barcoded by the pest management company and then scanned during visits to verify that each site is inspected. All findings, even those that don’t indicate pest activity, must be documented.
Take Corrective Action
If pest activity is observed in any area in the facility, no matter how small it may seem, a corrective action must be taken. This corrective action can be taken by either the pest management company or the facility, however, it should be properly documented.
Auditors look for who was responsible for the corrective action, what actions were taken and when, as well as the results of the corrective action. Documentation should be extremely detailed, especially the results. Auditors want to know if the corrective action worked, and if it didn’t, what the next steps were to achieve pest elimination.
Accurate, Consistent and Thorough Data
As you can see, documentation is all about the details. When possible, develop creative tools that help visualize your pest management program so auditors can truly understand how your system works for your facility. Using the latest technology, such as Google maps, you can illustrate where the bait stations are located around your facility, and demonstrate how your pest management program is up-to-date and complies with the FSMA mandates.
Remember that if you didn’t write it down, it didn’t happen in the eyes of the auditor. Be sure every finding is documented with extreme accuracy by your QA and facility team, and by your pest management technician. Detailed reports are the most effective tool in ensuring pest control and protecting your brand.
About the Author
Shane McCoy is the Director of Quality and Technical Training at Wil-Kil Pest Control (www.wil-kil.com), a regional pest management company providing quality pest management for commercial and residential properties throughout the Upper Midwest. Shane has been in the structural pest management field since 1995. He is an Associate Certified Entomologist (ACE), has an associate’s degree in environmental control, bachelor’s degree in workforce education and development, and he is currently pursuing his master’s degree from the University of Nebraska. Shane has published numerous articles in professional trade magazines and regularly performs pest management training for clients, pest management associations and staff. He is also the chair of the Copesan Technical Committee and a contributing author to PCT’s (Pest Control Technology’s) Guide to Structural Pest Management, including the chapters Pest Management in Warehouse and Distribution Facilities and Pest Management in Apartments and Multi-Family Housing. Wil-Kil is a member of Copesan Services, a national network of pest management professionals specializing in commercial pest control and food safety services. Shane can be reached at firstname.lastname@example.org.