Is your BRC pest control contract compliant?
4.14 BRC PEST CONTROL
The whole site shall have an effective preventive pest control programme in place to minimise the risk of infestation and there shall be the resources available to respond rapidly to any issues which occur to prevent risk to products.
A BRC pest control programme is required, which minimises the risk of pests getting inside, to ensure that there is no risk of cross contamination to the product.
The BRC have now defined what they mean by an ‘infestation’. They have also stated that any site found to have an infestation, will automatically get a major non conformance, meaning a grade B would then be the best score you could achieve.
An infestation is defined as ‘evidence of pests breeding in the building or on site over a period of time’. The infestation is seen as a total loss of control, hence why a major non conformance is applied.
In reality the way in which this is going to be enforced will very much be down to the interpretation of the auditor. For example, it states in the building or on site – in the building is pretty straight forward, but the addition of the words ‘on site’ implies that external activity within the boundaries of the site is in scope. So it could be said that, ongoing external rat activity on the boundary to a river or railway line could be seen as an infestation and therefore cause a major non conformance, where clearly this is not a total loss of control. Personally I would hope that the auditors will apply this aspect of the standard pragmatically and keep it for instances where sites have clearly not tried to tackle problems, which could put the internal areas at risk and subsequently the production.
Pest activity on site, which is not classed as infestation, is termed as pest ingress – therefore these are pests which have managed to get inside but are not breeding inside.
(NEW) 4.14.1 If pest activity is identified it shall not present a risk of contamination to products, raw materials or packaging.
The presence of any infestation on site shall be identified in pest control records and be part of an effective pest management programme to eliminate or manage the infestation such that it does not present a risk to products, raw materials or packaging.
This is a new clause and personally I can understand why it has been added, as version 6 lacked a clause where a non conformance could be applied if the pest control programme was not effective – and so pest issues were apparent and not being eradicated.
However, it seems that the explanation by BRC of why this clause has been added is a little confusing. In the key changes document, BRC states that the new clause has been applied, so that if an infestation has been highlighted in the pest control records, which does not pose a risk to the product, and it is being tackled – it is thought to be effectively in control and so would not cause a non conformance to be applied.
Whereas, if we go back to BRC’s definition of an infestation, this is evidence of pests breeding in the building or on site over a period of time and that this is deemed to be a total loss of control. The new clause therefore seems contradictory in my opinion. The only way I could explain it is that it gives the auditor enough flexibility in the standard to be able to apply a non conformance that he/she feels is appropriate. Where a lack of control is apparent, then a major would be applied and where an infestation is highlighted but is being effectively controlled then no non conformance needs to be applied. I think the way it has been documented will cause confusion and I can imagine that there may be some heated debates in audits and subsequent appeals of non conformances.
So to comply with this clause you must ensure that:
- All pest activity is recorded in the records.
- Action is taken to address the issue.
- Action taken must be in a timely manner and the time must be appropriate to the level of risk. So for example activity where raw materials or product are open would be deemed as high risk and so action would be expected immediately, compared to an area of the building away from raw materials or product where the timescale could be within a few days.
- Results of the action taken is recorded.
- Follow ups are recorded and concluded.
5 Mice Breeding Facts
- A mouse can have a litter from about 2 months of age.
- A baby mouse is called a pup.
- Each litter can be between 4 to 16 pups.
- One mouse can have up to 8 litters a year.
- That means one female mouse can produce up to 128 pups a year!
4.14.2 The site shall either contract the services of a competent pest control organisation, or shall have appropriately trained staff, for the regular inspection and treatment of the site to deter and eradicate infestation. The frequency of inspections shall be determined by risk assessment and shall be documented. Where the services of a pest control contractor are employed, the service scope shall be clearly defined and reflect the activities of the site.
To explain this clause, it’s best to split it down into three parts:
- Who provides the pest control service.
- Frequency of inspections.
- Scope of the pest control programme.
We’ll take each one separately.
1. Who Provides the Pest Control Service
The service can either be provided by employing the service of a specialist pest control contractor or, by providing in house resource which is suitably trained.
If using a contractor, the contractor must be able to provide you with evidence of one or more of the following, to be able to show that they are capable of managing this service for you:
- Membership to a national trade association, such as:
BPCA (British Pest Control Association) http://www.bpca.org.uk
NPTA (National Pest Technician’s Association) http://www.npta.org.uk
- Certificate of training
The industry minimum standard for a pest control technician is RSPH/BPCA Level 2 in Pest Management. There is then a second technician’s qualification called BPCA Accredited Technician in Pest Control (was BPCA Diploma II).
Your biologist should have BPCA Certified Field Biologist.
Make sure you’ve got copies of the training certificates in the folder and make sure they’re up to date, as they do have an expiry date.
- Third party audit of their systems and their application (BPCA audit all of their members and NPTA do as well but only for their elite accredited members).
If you are running an in house pest control programme and providing your own resource you need to ensure that you meet the same standards, which includes training. The requirements are provided in more detail in 4.14.3 (note the BRC standard says 4.13.3, don’t let this confuse you its just a typo).
2. frequency of Inspections
The frequency of the inspections should be based on a risk assessment which takes into account the risks from the neighboring businesses, the building structure, the raw material and product being produced.
Ideally this risk assessment should also be used to determine which pests need to be included in the scope of the contract.
The frequency determined from the assessment would need to take into account the life cycle of the pests and also the scope of monitoring activity.
Your pest control contractor should be able to do this risk assessment for you, but make sure you specify that it must determine the type of pests covered in the contact and the frequency of inspections.
Also make sure you check it once they give it to you, although a contractor should know how to complete these type of risk assessments, I frequently see risk assessments completed by contractors which have totally missed the point.
Standard practice for contract frequencies are 8 inspections per year and 4 biologists visits (this includes a pest related hygiene audit).
3. Scope of the BRC pest control programme
Once the types of pests have been identified through risk assessment make sure that they are documented in a scope of the contract.
Ensure that this scope also covers the agreement about call out, including response times. Normally there would be different response times specified for internal and external activity, as the risks associated are obviously different.
Also include in the scope of the contract the follow up procedures for when treatments are required. For example for internal mouse activity where toxic bait is used you may expect every other day follow up inspections and these would continue until there has been 3 clear (no signs of activity) visits, then a further 7 day visit would be completed.
Everyone has a great pest control story or a watch out, I’d love you to share yours in the comments section below (please don’t name names!).
I’ll go first – when I was at college I worked in a small bakery with a guy who told me that when he was the junior baker, he had to come in first and heat up the ovens and bring the flour up from the cellar. Every day before he started work he’d go into the cellar and before turning on the light he would pick up a peel (a large round pizza type shovel) and hit the wall with it. He’d then turn on the light and there would be an imprint on the wall of squashed cockroaches! Ergh! How things have moved on!
We've tagged this article as: Pest management
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