Want to stay one step ahead of the U.S. Food and Drug Administration (FDA) and your next audit? Be proactive.

The Food Safety and Modernization Act (FSMA) has been in effect for over a year, and that means compliance with Hazard Analysis and Risk-based Preventive Controls (HARPC) is a must. As part of your food safety plan, you must demonstrate a proactive approach to protecting your grain products. All plans should include a pest management program, as pests are an unpredictable and common threat to products. Not only are FSMA regulations active at this point, but the FDA continues to expand its support for states to fully implement and enforce regulations. While this latest addition does not directly affect grain products, it shows there is no time to waste. Food safety programs should have been updated yesterday, but the second-best time to start revising your plans is today.

Let’s start with the basics. HARPC has many stipulations that trickle down to pest management. Generally, it can be broken down into the following characteristics, with pest-related implications each step of the way:

  1. Hazard analysis. Conducting an inspection is the first step in any pest management program. A professional will identify the hazards (pests) and the high-risk areas in your facility where they may take residence. This can allow you to get ahead of potential pest issues before they evenoccur.
  2. Risk-based preventive controls. The key here is simple: be proactive. Once risk areas are identified, take immediate action. The longer you wait, the more likely pests will establish themselves and become a bigger, more expensive problem for your facility.
  3. Monitoring. Devices are a great way to keep an eye on pest populations around the facility, but don’t overlook the value of training. Employees can be a big help in detecting and reporting on pest invaders.
  4. Corrective actions. If pests or conducive conditions are spotted within a facility, that’s important to know. But, corrective actions are the key to then eliminate the problem. Once completed, ensure a protocol is in place to monitor results over time.
  5. Verification. Regular service visits with a pest management professional will verify corrective actions are working. If a strategy isn’t working, the approach needs to be adjusted. In addition, every facility should have an annual assessment including a pest trend analysis to highlight areas for improvement.
  6. Supply chain. While not specific to pest management, don’t forget about incoming goods. It’s never a bad idea to inspect shipments before bringing them inside the facility.
  7. Record keeping and documentation. Everything done to proactively prevents pests and deal with current pest issues should be recorded. Auditors need to see an effective program is in place, and documentation will help demonstrate consistent improvement.
  8. Reanalysis. Conditions change, and your plan should change too and adapt to new issues and concerns.

You also need to be aware of the pests most likely to put your proactive food safety plan to the test. Consider how each pest you face can be prevented and think through how the tactics you implement measure up to FSMA’s HARPC regulations. There are always proactive tactics to help prevent these pests, which will be necessary to keep them from feeling at home inside your facility. Here are some examples you might encounter in your facility and how the steps in HARPC can apply.

Lesser grain borers

These pests can be tough to spot, especially since the immature stages are inside the individual kernels of grain. The only visual cue you will get is when you see the adults after they emerge. They’re only about a tenth of an inch long. From egg to adult, these pests only take about 25 days to mature under ideal conditions. Also, look for distinctive holes in the kernels where the adults have chewed out.

So, the identified hazard is the lesser grain borers, the next step is the preventive controls. They prefer warmer temperatures and about 12% moisture, so maintaining a cooler, relatively dry environment, won’t be as conducive. Monitoring is also a good idea, which can be done by sampling, visual inspections, and placing pheromone traps strategically around your product. Finally, if you had an infestation in the past, you’ve probably already performed some corrective actions and you’ll want to continue ongoing monitoring to verify pest levels. And don’t forget to write it all down.

Indian meal moths

With a wingspan of roughly five-eighths of an inch, Indian meal moths aren’t as tough to spot as lesser grain borers, but they’ll still infest products if allowed access. Categorized as external feeders, they will feed on broken and milled grain. The larvae are the destructive stage and they spin a messy silken web that gums up food particles. They prefer humid conditions, and their presence encourages the growth of mold. To properly address this pest, make sure your preventative controls include inspecting all incoming shipments. And don’t forget exclusion, Indian meal moths have a native population on the outside, so don’t let them in. Use monitors to track populations and find hot spots, then plan corrective actions like installing mating disruption or spot treatments. Keep an eye on the monitors to verify if your treatments and other corrective actions are working. Keep up on that documentation so you have a record of all your hard work.


You might see them sneaking around in a corn bin. Or hear them hiding out in the walls or ceiling. Rodents are resilient and clever, so if they can find food, water, and shelter, they’ll stick around. They tend to stay out of sight whenever possible, but they’ll come out of hiding to feed on grain products and leave behind a trail of feces and urine. Aside from the contamination they leave behind, rodents can also carry disease-causing pathogens.

To keep rodents out of your facility focus on preventive controls that are based on exclusion tactics like sealing cracks and crevices around the exterior. Monitor using bait stations and traps to reduce populations and stop them before they can get to product. Where you find high numbers of rodents in your monitoring plan could point you to sanitation issues. If your facility isn’t clean, take corrective actions to minimize spillage and potentially clean up water sources a rodent could get to in order to minimize potential attractants. Verify, based on bait eaten and numbers trapped, that you have devices in the optimal spots; you may need to shift them around.

With any pest, keep in mind how the pest management strategies you’re implementing will need to be reevaluated and adjusted. Conditions in and around your site will change, and your plan should be modified, too. If you document all your efforts, then you will have a good base of knowledge on pest trends in your facility and how to respond.

Staying up to date on the latest pest issues affecting your facility is critical to demonstrate a proactive approach. That’s where documentation is necessary. It isn’t enough to simply implement a pest management program – you must prove it.

Keep these documents on hand so you can remain audit-ready any time:

  • Food safety plan. The most critical record to keep on hand. Language added under HARPC says facilities now need to hold suppliers accountable as well, so keep careful records of incoming shipments in addition to the documentation of all preventive actions taken to protect products within your facility.
  • List of monitoring devices/traps. It always helps to have a map of all monitoring equipment, traps, and other devices in the facility. Recording pest activity for each device over time will allow you to create a trend map highlighting the places most at risk for pests within your facility.
  • Annual assessments. At least once per year, take an in-depth look at your site, the pest history, the devices and the efforts taken to prevent and resolve the issues. Demonstrating constant improvement over time is a big deal and will show an auditor your food safety plan goes above and beyond.
  • Proof of training/certification. Keep your pest management license and certification document on hand to show your expertise. If you have an outside company performing your pest management, make sure their licenses and training info is on hand. With written evidence of the pest management professional’s training, there will be no doubts about the validity of your pest management program.

Pest management under FSMA doesn’t have to be stressful, but you do have to be prepared. Act early, monitor constantly, and document everything, and you’ll be set up for success.