As part of the educational programming offered at PACK EXPO International 2016 last week, the Food Safety Summit once again hosted the Food Safety Summit Resource Center. The Food Safety Summit Resource Center hosted 20 30-minute presentations on various topics related to food safety over the four days of PACK EXPO International 2016.
One of those presentations — FSMA Changes That Will Affect Your Pest Control Program — was delivered by Dr. Zia Siddiqi, Director of Quality Systems for Orkin.
According to the presentation synopsis provided by the Food Safety Summit ahead of PACK EXPO International 2016: "The FDA has shifted its food safety approach for facilities to Hazard Analysis and Risk-based Preventive Controls (HARPC). Learn the implications for your food safety and pest control programs, and the steps you should take to make sure you’re in compliance with the new Food Safety Modernization Act (FSMA) rule, which will be fully implemented by the end of 2016."
Food Manufacturing had the opportunity to correspond with Siddiqi after PACK EXPO International 2016, and asked him to provide the top takeaways from his presentation. Here is his written response:
The 2016 PACK EXPO International trade show was this past week, and I had the privilege to speak at the Food Safety Summit Resource Center on the Food Safety and Modernization Act (FSMA) and how its new provisions are changing the way we create food safety plans, and by extension, our pest management plans. There are many things to consider with the recent implementation of the Hazard Analysis and Risk-Based Preventive Controls (HARPC) guidelines, so I have put together some key takeaways from my presentation.
HARPC — A Shift from Reactive to Proactive
The new HARPC guidelines bring with them a shift to a preventive approach for food safety. Facilities now should be audit-ready at any time, with careful documentation at every step of the process. In terms of pest control, this means that you have to look at all of the possible pests that could potentially compromise your product and create a preventive plan to help keep them out.
HARPC breaks down into five key components:
- Hazard Analysis — assessing the potential risk factors around a facility
- Preventive Controls — creating and executing an action plan to address the risk factors
- Oversight and Management of Preventive Controls
- Monitoring — monitor the facility for any pest activity by scheduling regular inspection
- Corrective Actions and Corrections — If any deviation is found then a corrective action must be taken immediately with a plan for preventing action. One of the most common gaps is inspection of incoming supplies.
- Verification — On a periodic basis, verifying that the preventive control are working for each of the identified hazard (pest activity). This leads to the next two bullet points — recordkeeping and analyzing the trends.
- Recordkeeping and documentation — for each step of this process, plans should be documented and issues should be recorded along with how they were resolved
- Requirement to Reanalyze — reassessment of the plan whenever there is a significant change at the facility that might increase or introduce new hazards, or every three years
An Integrated Pest Management (IPM) program emphasizes preventive controls already, so for many facilities these new guidelines won’t require an entirely new plan. However, the increased emphasis on documentation of preventive controls and the results of implementation will require some tweaking in most cases.
Think Like a Pest and Assess Weak Points
An easy way to think about where to implement preventive controls is to think like a pest. Pests are constantly in search of food, water and shelter in order to survive — all of which your facility likely offers to them.
Pests are able to detect food particles at a distance, so they’ll be searching for uncovered food, crumbs and waste as a source of sustenance. The same is true for water sources. If there are areas of standing water, leaks or spills left for extended periods of time, pests will be able to detect them. As pests realize that a facility offers what they need, they’ll begin trying to get inside via any means possible, be it cracks, crevices and holes in the exterior of a building, or a doorway left open for them to travel through.
Thus, prevention and exclusion tactics are a crucial part of any food safety plan, and should be included as part of an IPM program.
In addition, the hazards to analyze have expanded to include biological, chemical, physical and radiological hazards; natural toxins, pesticides, drug residues, decomposition, parasites, allergens and unapproved food or color additives; naturally occurring hazards or unintentionally introduced hazards (pests would fall into this category); and finally, intentionally introduced hazards (including acts of terrorism).
The FDA and Preparing for an Audit
The audit requirements established by the FDA are updated frequently, so it’s a good idea to check the FDA website regularly for updates. Part of the new HARPC guidelines is that facilities should be ready for an audit at any time, with documentation on hand to fully explain their program.
During an audit, an FDA auditor will conduct their own hazard analysis and compare it to the one conducted by the facility. Because pest control can account for up to 20 percent of an audit, it’s recommended to include a written IPM plan in the contract with your pest management provider that details the following:
- Roles and responsibilities
- Qualifications of technicians
- Scope of service
- Appropriate response times
- Scheduled meetings to review the program
Keep this contract on hand along with records of service-related activities and monitoring trends, and you’ll be better prepared for an audit at any given time. When you can show monthly observations and historical pest trend data, you’ll be giving an auditor exactly what they’re hoping to see.
Dr. Zia Siddiqi is Director of Quality Systems for Orkin. A board certified entomologist with more than 35 years in the industry, Dr. Siddiqi is an acknowledged leader in the field of pest management. For more information, e-mail firstname.lastname@example.org or visit www.orkincommercial.com.