In this issue we look at the remaining clauses in the pest control section of BRC Food Standard, around tackling a pest infestation, recording and pest awareness training.

Clause 4.14.7

In the event of infestation, or evidence of pest activity, immediate action shall be taken to identify at-risk product and to minimise the risk of product contamination. Any potentially affected product should be subject to the non-conforming product procedure.

On the discovery of a pest infestation (remember BRC defines this as large numbers of pests, breeding on site over a period of time – if you haven’t read that yet, I’d recommend you read it first – One of the most common pest control non conformances), the following should be implemented:

  1. If the pest infestation is found in a manufacturing area, the production must be stopped if the product is at risk.
  2. Any raw materials, work in progress materials or finished product must be assessed immediately for contamination. Any affected materials must be dealt with immediately so they do not spread the infestation or contamination.
  3. A thorough inspection must take place and corrective action must be put in place.
  4. Any manufacturing areas affected must only resume production if the infestation is being dealt with and it does not pose a risk to the product.

All the actions taken and the decisions made must be recorded so that there is full traceability on the incident, from the point at which it was highlighted to the point in which it is closed out.

Clause 4.14.8

Records of pest control inspections, pest proofing and hygiene recommendations and actions taken shall be maintained. It shall be the responsibility of the site to ensure that all of the relevant recommendations made by its contractor or in-house expert are carried out in a timely manner.

This clause is straight forward, it requires that you have evidence of all the inspections (including follow up treatments) carried out.

These records should detail:

  • The date.
  • Who carried out the inspection or treatment.
  • The result of each monitoring point inspection – if it was clear, or if it was not clear what was found.
  • Any treatment that was carried out, including the chemicals used.
  • Any further actions required by the pest controller.
  • Any further actions by the site.

5 Mouse Infestation Facts

Pest Management

  1. Mice live in nests and will build them out of any fairly soft material such as insulation or paper. They usually choose a warm place to build their nest and look for cavities to build it into.  Wall cavities, in the mechanics at the back of water dispensers or snack machines are some of their favourite places.
  2. Mice can dislocate their skulls in order to squeeze through very small holes, they can get through a 5mm diameter hole – so if you can get the tip of a pen in a hole a mouse can generally get through!  A mouse hole that is used regularly (or easily) will be at least 2 – 3cm in diameter.
  3. Mice are nocturnal, if they are seen during the day it’s usually an indication of an infestation of a fairly high population.
  4. They don’t normally travel far from their nest to find food, usually 6 to 9 metres. When exploring they don’t worry about new objects, they just move around them.
  5. When moving they tend to stick to the outside edge of the room, following the walls.

Where there are further actions, which need completing either by the contractor or the site, it is the sites responsibility to ensure that these get completed and the records are updated to show the actions taken and the date it was completed.

Reporting of follow up treatments is one area that these records are always lacking. When a treatment is started I would highly recommend that you get your contractor to create paperwork just for that treatment. The paperwork needs to show a plan of the site, detailing where the new/additional monitors or baits have been placed. There should also be a record sheet that lists these monitors or bait points, so that the date and result can be recorded in columns next to each (as you would for normal monitoring). This way, if you are following a specific treatment process, you can see easily how many clear visits you had and also that the visits comply with the timings specified (every two days etc).  In the last newsletter I provided you with a free template – 4.14.2 Follow Up Pest Control Record V1  from our (soon to be launched) BRC Food documentation pack, which will help you ensure your pest control contractor documents follow ups for infestations correctly, if you missed it you can get it in here – One of the most common pest control non conformances

Clause 4.14.9

An in-depth, documented pest control survey shall be undertaken at a frequency based on risk, but as a minimum annually, by a pest control expert to review the pest control measures in place.

The survey shall:

  • Provide an in-depth inspection of the facility for pest activity.
  • Review the existing pest control measures in place and make any recommendations for change.

This cause was covered previously by John Simmons – Pest Control with John Simmons

The timing of the survey shall be such as to allow access to equipment for inspection where a risk of stored product insect infestation exists.

I won’t go into a great deal of detail on this, as John already talked about it in his guest post.

But just to be clear, the ‘survey’ that the clause here is requesting, is the typical biologists visit. Most contracts are based on 8 routine inspections and 4 biologists visits. The standard now says that only 1 rather than 4 biologists visits are required.

Make sure when your biologist has done your report that you go through the actions with him or her (better still go round with them during the inspection). They should leave you a written copy to start working on, so you don’t have to wait until the final report is sent through. When you do get the report make sure that the actions taken are detailed against each action and signed off.

Where you have a risk of SPI (stored product insects) the clause specifically states that the timing of the biologists visit must be organised at a time when a thorough inspection can take place. For example, in bakeries where they have a lot of airborne flour around the mixing area may suffer from SPI at high level, it would be necessary for the biologist to carry out their inspection during non production so that they can get above the mixer.

Clause 4.14.10

Results of pest control inspections shall be assessed and analysed for trends on a regular basis, but, as a minimum:

  • In the event of an infestation.
  • Annually.

This shall include a catch analysis from trapping devices to identify problem areas. The analysis shall be used as a basis for improving the pest control procedures.

If your contractor provides records of your monitoring/bait points in table format, with a new column for each date, then this will give you a trend of activity anyway for most pests. However, there also needs to be a trend of EFK results (as in counts by type), by area and by year. This way you can see if you have a problem in a particular area, with a particular type of fly or during a particular time of the year. Once you have this information in chart form so you can review it, make sure you do carry out a review and make sure you record the conclusions that are made. Where there is a trend you just put corrective action in place to improve the trend.

Clause 4.14.11

Employees shall understand the signs of pest activity and be aware of the need to report any evidence of pest activity to a designated manager.

This was a new clause in V7, and requires that everyone on site must understand their responsibilities for pest control, so:

  • They know how their actions can impact on the site (leaving doors open, not cleaning up spills etc).
  • That they must know what signs to look for as an indication of pest activity.
  • That they must report all signs of pests immediately so that they can be actioned.

To do this make sure you either document this information in a procedure or a training tool (such as a tool box talk) and once trained, get all members of staff to sign up to it. It’s a good idea to include this in the induction too for all new staff. Don’t forget agency staff too.

I have been covering Pest control for BRC section 4.14 over a couple of the recent issues, you can read these here:

One of the most common pest control non-conformances

Is your BRC pest control contract compliant?

If you have any questions or comments about tackling pest infestations, leave us a comment in the box below.

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