One of the most common pest control non-conformances…

One of the most common non-conformances I see when I’m auditing is completion of documentation for pest control. Provided for you in this issue is a free document you can download and use for recording pest control follow-ups.

 

Following on from the previous pest control post – newsletter 11, we go through clauses 4.14.3 to 4.15.6.

4.14.3 Where a site undertakes its own pest control, it shall be able to effectively demonstrate that:
  • Pest control operations are undertaken by trained and competent staff with sufficient knowledge to select appropriate pest control chemicals and proofing methods and understand the limitations of use, relevant to the biology of the pests associated with the site.
  • (NEW) staff undertaking pest control activities meet any legal requirements for training or registration.
  • Sufficient resources are available to respond to any infestation issues.
  • There is ready access to specialist technical knowledge when required.
  • Legislation governing the use of pest control products is understood.

If you run an in house pest control scheme you must be able to provide evidence that the personnel involved are trained to the same extent that you would expect of a contractor. So make sure that personnel have the training outlined in section 1 of clause 4.14.2 – click here for this detail from this post . You’ll need to have copies of their certificates in the folder as evidence of their training. As the certificates have expiry dates make sure there is a plan for refresher training, so that you always have certificates that are in date.

There are legal requirements in the UK that you must adhere to if you are using pest control chemicals, under the Control of Pesticides Regulations (COPR). You must ensure that you understand the requirements and stay up to date with any changes – this is part of the training provided by the BPCA.  In Southern Ireland the HSA.ie enforces the EU Classification, Labelling and Packaging Regulation (EC) No 1272/2008.  Contact the IPCA for more details in Ireland.

Sufficient resource to run an in house programme must be provided, this is to ensure that the inspections are completed to schedule and any actions arising from the inspections are dealt with in a timely manner.

4.14.4 Pest control documentation and records shall be maintained. This shall include as a minimum:
  • An up-to-date plan of the full site, identifying numbered pest control device locations.
  • Identification of the baits and/or monitoring devices on site.
  • Clearly defined responsibilities for site management and for the contractor.
  • Details of pest control products used, including instructions for their effective use and action to be taken in case of emergencies.
  • Any observed pest activity
  • Details of pest control treatments undertaken.pest control non conformances

This is an area where I see the most non conformances when I’m auditing. It’s important to routinely check that your pest control contractor is keeping your records up to date and that they reflect the current system.  In theory you should be able to rely on your pest control contractor to do the right thing, but this isn’t always the case.  Check through the points below to make sure you’re documentation is compliant.

A plan of the site must be available which show where each 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 monitors in their locations. If the monitors 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 monitors are shown on the plan in the right places and that they are actually present.  Once you’ve done this, sign and date the plan to show that you’ve checked it and it’s correct.  Repeat this each time there is a change.

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

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

The contractor must provide safety data sheets/ 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 and make sure that the COSHH is available for all of the chemicals used. There should also be a list of the chemicals that the contractor may use, sheets should be available for these too.

Records must be kept of all inspections and also treatments. Where inspections are all clear (no issues found) it is essential that these are still positively recorded, as clear.

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. I often find this is where the records become 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. I would recommend a new record sheet being set up, to accompany the additional baits/monitors plan and the inspections being recorded on here. That way you can see the progress of the inspections 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.  I’ve provided you with a free document from our BRC QMS documentation pack to help you with this – download it here  – 4.14.2 Follow Up Pest Control Record V1

4.14.5 Bait stations or other rodent control devices shall be appropriately located and maintained to prevent contamination risk to product. Toxic rodent baits shall not be used within production or storage areas where open product is present except when treating an active infestation. (NEW) Where toxic baits are used these shall be secured. Any missing bait stations shall be recorded, reviewed and investigated.

Bait must be controlled to ensure that it does not contaminate the product. Bait is normally in block or gel form, but you can use it in other forms which would be more attractive to the pests, for example using grain or cereal and mixing it with toxin to treat an infestation in a site which manages cereal based products. This can make the treatment more effective but it does mean that it’s more risky as the product may be granular in nature and spill. It’s obviously not as visible if it does spill.

The bait boxes or monitors must be tamper resistant, meaning you shouldn’t be able to get into them without the necessary key – so that those that are not trained to touch the chemicals inside cannot do so.

Most retailer standards specify that all bait/monitors should be secured (this means attached to the floor or wall where they are placed), but BRC have now included in the standard that at least the toxic baits must be secured.

The standard also states that the monitors or bait boxes must be located in the correct places and these locations must be specified by specialist personnel, so if you use a contractor the contractor must specify this. I would suggest a little caution here, as some contractors will try to persuade you to have more baits or monitoring points than you need, because they can charge you for the installation of each and then an ongoing service charge for each. It’s difficult without pest control training to know if they’ve over spec’d for your site, but try take some time to look at the products that they’ve suggested. For example, the cost of an EFK (electrical fly killing unit) can vary from a standard one with no glue pad behind, up to expensive ones which have a glue pad behind, and a moving glue pad at the base with special screens to help all the insect ‘parts’ to stay inside the EFK. Do you really need an EFK and are these functions required if it is going to be located in a warehouse where all of the product is packed?  When locating internal rodent bait boxes or monitors, as a minimum these should be on either side of each external door.

4.14.6 Fly-killing devices and/or pheromone traps shall be correctly sited and operational. If there is a danger of insects being expelled from a fly-killing extermination device and contaminating the product, alternative systems and equipment shall be used.

This has been mentioned above, make sure the type of EFK fits the requirements for that area. When a fly is caught by an EFK the parts of the fly can be knocked out of the unit, so make sure you don’t have EFKs located near open ingredient or product, as you don’t want fly bits in it!

Also think about the locations of the EFKs, you generally only need them if there is an opening to outside, or where there is a risk of flying insect infestations internally due to the type of ingredients/products in use (e.g. vinegar or sugars). Make sure the contractor doesn’t locate the EFK on the wall opposite the outside opening (this is a common mistake), as during the night when the door is in use and open, this will only attract flies in. It’s better to locate the EFK on the same wall as the door, so that it can’t be seen from outside.

The bulbs in the EFKs have to be changed routinely as they dim over time. Make sure that your contractor has specified how often this is to be done in your service agreement and make sure they are recording it each time this is done.

Where moths are a risk moth pots will be in place, the pheromones need to be changed in this routinely, normally quarterly.  Your contractor should work to a colour coded system, that way you can tell at a glance if they have been changed.  The contractor should also record the changing of these in your records.

If you haven’t read our previous post on pest control, you can read it here – newsletter 11.  Also, don’t forget to download your copy of your free pest control follow up record sheet now – 4.14.2 Follow Up Pest Control Record V1

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