This article is written to meet the following sections of the Standards:

BRCGS Food Safety Issue 84.14 Pest management
BRCGS Packaging Issue 64.11 Pest management
BRCGS Agents & Brokers Issue 3
Not applicable.
BRCGS Storage & Distribution Issue 46.6 Pest management
FSSC22000 Version 5.1ISO 22000:2018 8.2.4 d) PRP – pest control
IFS Food Version 74.13 Pest monitoring and control
SQF Edition 911.2.4 Pest Prevention

Programme

An effective and preventive pest management programme must be in place, the aim of which is to:

  • Prevent pest ingress through proactive proofing and preventive controls.
  • Detect pests through regular inspections.
  • Treat pests to eradicate pest ingress and infestation.

The scope of the programme must cover:

  • All areas of the site’s responsibility.
  • All pests identified through risk assessment.
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System management

Pest management must be applied through either, or a combination of:

  • A competent pest management contractor.
  • In-house management using appropriately trained on-site staff.

Training

Specific pest control training should be formally carried out by a nationally or locally recognised scheme, for both contracted personnel and in-house personnel.

Responsibilities

The pest management folder must detail who’s responsible for doing what activities, between the contractor and the site. For example, where evidence of pests – such as droppings is found, who’s responsible for cleaning up the evidence? It’s important that this is clear, as it’s common for this to get forgotten so nobody cleans it up. This results in the contractor or the site not knowing if there’s been any new activity, or if the debris remained from the previous time. It’s also important to establish who’s responsible for removal of bodies. Where toxic bait has been used there are particular requirements as to how the remains should be disposed of.

Pest contractor

Where the services of a pest management contractor are employed:

  • There must be a service scope which clearly defines the contracted activities.
  • There must be a contract which includes details of the procedures to be applied for pest ingress and infestation follow-up.
  • Responsibilities must be documented for the contractor and the site.
  • The service supplied must meet all applicable legislation.
  • The contractor must be able to demonstrate competence and evidence of this must be kept up-to-date.
  • There must be agreed methods of communication, including contact details for the site and the contractor.
  • Set dates for when review meetings will take place, which must be at least annually.
  • After each visit, the site representative and the contractor must review the results of the inspection.
  • The contractor must leave a report detailing any evidence of pest activity, actions taken and recommendations.

In-house pest programme

Where part or all of the pest management is conducted in-house, personnel must be appropriately trained, this includes those:

  • Carrying out inspections.
  • Determining and applying suitable treatments.
  • With responsibility for management of the system.

In-house management systems must ensure:

  • Responsibilities for relevant personnel are documented and understood.
  • That sufficient resources of labour, consumables and equipment are available.
  • That specialist knowledge is available when needed.
  • That the system is compliant to all applicable legislation.
  • Chemicals are controlled and facilities are provided for their safe storage.

Management system

A pest management system must be in place, which includes:

  • Risk assessment to define the scope and inspection schedule.
  • A site plan.
  • Inspection protocol, including follow-up procedures.
  • Safety data sheets, H&S information and instructions for the effective use of pest control chemicals.
  • Records.
  • Trending of results for continuous improvement.
  • Reviews.

Risk assessment

A risk assessment must:

  • Define the areas of the site’s responsibility.
  • Establish which pests are a hazard.
  • Assess the likelihood of those pest groups, causing a pest ingress or infestation issue, considering the age, design and location of buildings and equipment.
  • Consider any seasonal variations of pests.
  • Consider pest history on site.

The output from the risk assessment must determine the:

  • Number and type of monitoring points required.
  • Optimum monitoring locations.
  • Frequency of inspections based on risk.
  • Time required for inspections must be reflective of the work required and the size of the site.
  • Frequency and best timing of the pest survey.

Site plan

A plan of the site must be available which shows where each pest monitor is placed. This is usually done by highlighting each type of monitor with a different coloured spot, or shape on a site map. Each monitor should be numbered on the plan and the numbering must reflect the numbering on the actual monitoring points in their locations.

If the monitoring points are removed, moved or new ones added this should be reflected on the plan.

It’s a good idea to take a copy of the plan and walk the site to check that the monitoring points are shown on the plan in the right places and that they’re actually present. Once this has been done, sign (both the site and the contractor) and date the plan to show that it’s been checked it and it’s correct. Repeat this each time there’s a change.

If a treatment is required due to an issue or an infestation, any additional monitoring points need to be shown on a plan. Rather than amending the original plan, this can be done by creating a new plan which shows the monitoring points for that specific treatment. Again, these should be numbered on the plan and the numbering should be the same on the monitoring points in their actual locations. Ensure that when the treatment is over, that the contractor removes all the monitoring points and signs off the plan and records it as complete. You don’t want an auditor finding one of the monitoring points or even worse, toxic baits months later after the issue has been resolved (this happens a lot).

Protocol

A protocol is a set of rules that must be adhered to. A pest protocol is a set of rules that are applied when there are pest sightings or an infestation. This means you need to have a documented process (that’s agreed with your contractor) which states what the contactor will do when there’s an issue, for example – what the follow-up procedure will be. Typically, you have a different protocol for when there’s an issue inside and when there’s an issue outside.

Safety data sheets

The contractor must provide safety data sheets and COSHH information for all the chemicals used, so that in the case of an emergency the information is easily available. Check through the inspection and treatment records to identify what chemicals are being used and make sure there’s safety information for each one. Ideally, there should also be a list of the chemicals that the contractor is approved to use, as this helps to make sure that all the information is available.

Records

Records must kept for:

  • Inspections, recording clear inspections, any observed pest activity and any monitoring points that are missing or inaccessible.
  • Pest sightings.
  • Maintenance such as replacing bulbs or lures.
  • Application of pest control treatments and the products used.
  • Corrective and preventive actions.
  • Trending of results for continuous improvement.

The management system may be in hard copy on paper, or digital, as long as they’re accessible by the site. Personnel responsible for accessing online systems to retrieve digital paperwork must be trained sufficiently, so that they can find what they’re looking for.

Where treatments are applied or additional monitoring is put in place, this must be reflected in the records and inspections of these must be recorded. It’s common for the records in this type of situation to be confusing or lacking, so it’s important that you ensure that your contractor is recording this adequately. Many contractors will try to just use inspection reports to record the information, but this makes it very difficult to audit and for you to keep track of.

It’s a good idea to set up a record specifically for the issue. Include a map of where the monitoring points are and the checks of these. That way all the information is in one place, it’s easier to tell if the treatment is being effective and you’ll be able to see if the treatment being applied follows the frequency agreed.

Trending

Trending must be carried out on catch trays and activity identified at monitoring points. At a minimum, trending must be analysed:

  • Annually.
  • In the event of an infestation.

The aim of the trending and analysis is to establish if there are any problem areas on site, so that action can be taken.

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Monitoring

There must be regular inspections to monitor for pest activity. Monitoring and treatment equipment must:

  • Be located for optimum effectiveness.
  • Be located so that it doesn’t pose a risk to the product.
  • Not contain toxic bait in open product areas, unless specifically controlled and applied for pest ingress of infestation treatment.
  • Be tethered in place or located so that it will not move.
  • Be tamper resistant.
  • Not contain bait formulations which will spill and become a risk to product.
  • Be inspected frequently based on risk assessment and legislation (such as where live traps are used).

 

Frequency

The frequency of such inspections must be determined through risk assessment. Typically, inspections should be every six weeks as a minimum, but a greater or lesser frequency may be determined through the risk assessment.

A twelve month schedule of inspections must be in place.

Inspections

There are three main forms of inspection:

  • Manual.
  • Automated.
  • Partially automated.

Manual

Manual inspections need to be checked by qualified personnel, which is why this is typically done by the contractor. If staff are checking monitoring points manually, they also need specific pest control training.

Automated

Automated inspections are where the monitoring equipment will identify pest activity and transmit a signal to site staff or the contractor. Where automated monitoring is in place, this can reduce the frequency of inspections that need to be carried out. Manual inspections are still required at a lesser frequency, to ensure that monitoring equipment is working and to carry out a more detailed inspection for signs of pests.

Partially automated

Monitoring devices which are partially automated, will detect pest activity and will trigger a visual device on the outside of the equipment. A manual check is then required, to visually check the monitoring device to see if it’s been triggered. This can be carried out by staff who have been trained to complete this task, however they don’t need specific pest management training.

Pest survey

This survey is also known as a biologists visit, as it’s typically carried out by the biologist provided by the contractor. It’s an in-depth survey that must be carried out:

  • At a frequency based on risk, and at least annually (good practise is four times a year).
  • By a pest control expert (trained to biologist level).
  • To review the effectiveness of the pest programme.
  • During scheduled down-time to allow for equipment to be opened and inspected.
  • When there’s the greatest risk of pests, for example at seasonal highs.
  • To provide any recommendations for improvement.

Pest awareness

Staff on site must be trained to understand:

  • The signs of pest activity.
  • How pests can get inside (pest ingress).
  • What can happen if there’s a pest issue – to product and to the hygiene of the area.
  • That they must report any evidence of pest activity and how to do this.

Reporting pest activity

There must be a procedure for reporting of pest activity, which includes who activity must be reported to and relevant responsibilities. This can be written into the pest protocol.

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Infestation and ingress

Let’s explain the difference between infestation and ingress first.

  • An infestation is where there’s evidence that pests are breeding inside, or where they’ve been breeding outside for a long period of time.
  • Ingress is where there’s evidence that pests have come inside. This tends to be an isolated incident.

If the auditor finds that you have a current infestation problem when you have your audit, you’ll be given a major non-conformance, as an infestation is seen as a loss of control. Which means, you’ll only be able to get a B grade at best.

Infestation

If a pest infestation is identified:

  • A risk assessment must be documented, and mitigations implemented to ensure that the infestation doesn’t pose a risk of contamination to materials or products.
  • An investigation must be completed to establish if product or materials have been affected and where this is the case, the non-conforming product procedure must be applied.
  • Where product is released following investigation, the release must be authorised by a competent person.
  • The presence of pest activity on site and any subsequent actions must be recorded.
  • A programme of treatment must be implemented in a timely manner to eliminate the infestation.
  • Root cause analysis must be completed to establish why there was a loss of control within the pest management system and preventive actions applied.
  • Where the pest management system is contracted, a review meeting must be held with the pest contractor – to ensure that the root cause analysis can be completed effectively, any learnings are shared and also preventive actions are applied and closed out thoroughly.

Ingress

Where pest ingress is identified, immediate corrective action must be put in place. A risk assessment must be carried out to assess the safety of the materials and product that may have been affected. The incident must be recorded along with the corrective action and any follow-up required.

Corrective and preventive actions

It’s the responsibility of the site to ensure that all the relevant recommendations made by the contractor are implemented in a timely manner and closed out effectively. Missing monitoring points must be investigated, and action taken. Where inspections are prevented due to access issues, these must be investigated, and action taken.

Proofing

There must be sufficient proofing in place to minimise pest ingress, including:

  • Proofing so that birds can’t enter buildings or roost above loading or unloading areas.
  • Sufficient proofing of doors, windows, ducts and cable entry points to prevent access to rodents.

Access

Storage must allow access to walls for cleaning, inspection and treatment. Products must be stored to minimise the risk of infestation. Any stock held for prolonged periods must be inspected at a set frequency, and at least quarterly to detect any signs of pest activity. Records of inspections shall be maintained.

Electric fly killing units (EFKs)

These must be fully operational and not located near open product. Where there’s a risk of insects being expelled from a device and contaminating the product, alternative controls must be used. The bulbs in EFKs must be replaced at a set frequency and this must be documented.

Lures

Lures such as pheromone, must be replaced following the manufacturers guidelines. Replacement must be documented.

Review

Management meetings must review:

  • The overall results and trends of inspections.
  • The effective close-out of recommendations, corrective and preventive actions.
  • The results of the pest survey.

At a minimum, this review must be conducted annually (or sooner in the event of an infestation). The dates for when the review meetings will take place must be scheduled. A review of the risk assessment must also take place:

  • When there are changes to the buildings or processes which could have an impact on the pest programme.
  • If there’s been a pest infestation.
  • At least annually for continuous improvement purposes.
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