Food processing facilities provide everything that pests need to survive: food and water, shelter and warmth. An effective food safety plan requires a pest management program that analyzes the risks of what could encourage pests to enter your facility — such as open doors or windows, product shipments, unfinished repairs and leaky roofs — and then proposes steps to help eliminate those areas of risk. This is the core of the HARPC approach to food safety management.
The old approach, that came before FSMA and was recommended until September 2016 in the United States, is called Hazard Analysis and Critical Control Points (HACCP). This approach was designed to create procedures for responding to threats in any part of the food supply system in the United States and abroad. This means that HACCP is reactive rather than proactive.
While American food safety is arguably at one of the highest levels in the world, the range of potential threats to its food supply today has increased to the point that it must take a more assertive approach. This is the reason that the HARPC regulations were put into place. The HARPC process requires identification and prevention of all reasonably foreseeable food safety hazards — whether naturally occurring or unintentionally introduced into the facility.
The seven requirements of HARPC are: (1) identify hazards, (2) include risk-based preventive controls, (3) monitor effectiveness, (4) set corrective actions, (5) verify effectiveness, (6) manage record-keeping and documentation, and (7) reanalyze every three years.
As part of these requirements, HARPC mandates that facilities:
- Conduct a thorough hazard analysis for all food processing procedures.
- Develop and implement preventive controls, and then monitor the controls’ effectiveness.
- Provide a detailed plan in writing, describing how the hazards will be controlled, the preventive controls put in place, and a schedule and methodology for monitoring the efficiency of the controls.
- Verify the effectiveness of the controls, also maintaining written records of the verification processes.
- Reanalyze the HARPC plan at least every three years; more often as new product lines are added, equipment is changed or upgraded and/or when other changes require a new analysis.
FSMA’s pest management impact
So what does this mean for your pest management plan?
It means that you need to focus on preventing rather than reacting to pest issues. The best way to do so is by working with your pest management professional to create an Integrated Pest Management (IPM) program. IPM places a focus on facility maintenance and sanitation, only using chemical treatment options as a last resort.
An IPM plan includes regular monitoring and analysis of pest activity within a given facility. Documentation is a crucial part of this, as a third-party auditor will be looking to see detailed reports on pest issues and the actions taken to resolve them. Your facility’s IPM plan should be tailored to your particular needs and risks, based on both internal and external factors. These factors include seasonal cycles, geographic location, maintenance and sanitation policies, number of staff and more. Work with your pest management professional to determine the best plan for your facility.
Once an IPM plan is in place, it will be easier to assess the biggest threats to your products and adjust appropriately to create the most effective, proactive plan possible.
Insects and other pests such as birds or rodents are among the most likely threats to food safety standards at a food processing facility. If you want to start working to protect your facility from these pests today, there are certainly some things that you can do.
Here are some exclusion and prevention tactics to help get you started:
- Walk around the outside of your facility and seal any openings and cracks with caulk or another waterproof sealant.
- Trim back vegetation from the outside of your facility. It should be at least 3 feet from the building for best results because pests will use plants as a “jumping off” point to get into your building.
- Keep doors and windows closed. This may sound simple, but it can make a big difference, especially if these are unscreened. If your facility does use door and window screens, check and make sure that there aren’t any holes.
- Clean and sanitize garbage bins and take out the trash regularly. Many pests are attracted to the odors and particles in and around trash receptacles, including dumpsters, and will congregate in these areas if left unclean for extended periods of time.
Even with an incredibly thorough IPM program, pests may still find a way into your facility. As soon as a pest sighting occurs, it’s important to react quickly to resolve the problem. Many pests are able to reproduce rapidly, so letting them exist within your facility might lead to an infestation within a matter of weeks.
In the case of a pest sighting, documentation is key, and your pest management professional can help. It’s important to record the type of pest, the location within the facility where it was found and the number of pests seen. As mentioned previously, you’ll want to record the actions taken to help keep the issue from reoccurring in the future and update your documents if you determine a change to your IPM plan is necessary.
It’s important to review and keep in mind the potential hazards — both seen and unseen — that could impact your facility to determine the risks that you should analyze for your IPM and overall food safety plan. The potential hazards have expanded under HARPC and include:
- Biological, chemical, physical and radiological hazards.
- Natural toxins, pesticides, drug residues, decomposition, parasites, allergens and unapproved food and color additives.
- Naturally occurring hazards or unintentionally introduced hazards.
- Intentionally introduced hazards (including acts of terrorism).
Because HARPC includes planning for potential terrorist acts and/or intentional adulteration and food fraud, your food defense plan should include additional security, such as visitor access and control.
Compliance with HARPC requires the same proactive approach you have been taking if you have an IPM plan in place. As a manager of a food processing facility, you play a critical role both locally and nationally in ensuring the safety of our food supply, so don’t forget about pest management as you work to improve your food safety policies.