Getting Hungry (AKA: Dirty truths)
I’m not sure if I’ve been sucked into some algorithm or if there really have been more news stories popping up on pests in food facilities. I posted last week on a pet store issue (yes, pet food is considered food!) and today about a meat seller in NYC whose trial just finished up. Then there have been numerous seafood violations lately. To me, the worst part is we won’t hear about any of these issues until months, even years after they have initially been cited.https://www.foodsafetynews.com/2023/07/rodents-flies-and-listeria-in-baking-companys-facility-prompt-fda-warning/
If you are a food processing or storage account, are a pest control company servicing these accounts, or want to know more about them in general, this is the week for you! If you aren't, keep reading, this is pretty interesting stuff.
First of all, audited accounts (like food processing sites) are a bit intimidating. You need to know the rules and regulations that govern these types of facilities to make sure they are properly protected. If you really like long government documents then you are in luck, there are a few standards you are going to need to understand. You will need to know FSMA, the FD&C Act (CFR 21), GMPs (CFR 21, Part 110), HARPc, possibly HACCP, USDA FSIS if you are doing meats or some other foods, and if that were not enough, you will need to learn the major audit codes including at least BRC and SQF. Still suffering from insomnia and need more? Great because you still need all the basics as they apply to pest control like EPA regulations, OSHA safety guidelines, and if you are lucky DOT and even Homeland Security rules.
That all sounds like a lot. It is a lot. When you think about it, it’s all about protecting the food supply to keep it safe. A beetle’s leg or a fly’s wing in your breakfast cereal might not sound like a big deal, until you think of all the diseases pests are capable of spreading and suddenly, those innocuous little bits don’t sound so small when you are feeding that breakfast cereal to your family in the morning.
If you want to look at this more “big picture”, it is about having a good pest management plan in place. That plan should address potential pest risks, prevention, and corrective actions when pests do occur. Let’s be perfectly real here: pest problems will occur. There is no way a facility, ANY facility can be pest free permanently. The goal is to have those happenings be rare (good prevention), and fast interventions as soon as they do occur.
Here's a great way to think about this. You can wait until you have a massive issue like this from a few years ago at a Family Dollar distribution center before doing something. Or, you can invest upfront to prevent 95% of those issues, and catch the remaining 5% within a week to a month of the first occurrence. Yes, these prevention and quick response strategies cost money. If folks choose not to go that route, here are some of the costs they are looking at when an issue goes nuclear:
Pest control costs. This may be as simple as adding more traps or it could mean lengthy shut downs for a full fumigation that could easily run into the millions of dollars.
Clean up costs. The pests may be killed by remedial actions…but there are still dead pests everywhere.
Recalls. The Family Dollar incident was estimated to reclaim 34 MILLION dollars of recalled products.
Disposal costs. Not only is the money lost on products that can’t be sold, they must also be disposed of, incurring more costs.
Legal fees. Even before any legal actions are threatened, there will be a team of lawyers needed to start heading off any threats they can.
Loss of reputation. We are a social media society, no way to escape it and as soon as a customer notices something wrong, it’s going up online. Then local and national media may pick it up.
This is all just the pest control portion of things. If you are working in food processing, you know that you have allergen controls, foreign supplier verifications, food safety and food security plans, and so much more.
If you are a pest control company, you need to know how to assess these accounts, build preventative and reactionary plans, and make sure to comply with all federal, company, and third party audit standards. Good news though, many of those third party audits cover US federal regulations and exceed them in most cases so following one of these ensures you are following at least the minimum requirements. There are great people you can hire (hint hint) to help you do this and do it exceedingly well.
If you are a food processing company, there are plenty of pest control companies that can reliably do this for you. Not just the “big guys” either, there are great independent companies that are well suited to help you with the pest control portion of all these standards. Before things go terribly wrong, you can always bring in someone to do an independent assessment (hint hint). After a problem occurs and regulators are brought in a lawyers are involved, costs will skyrocket.
Lagnaippe - it comes out tomorrow so I haven't seen it yet...I'm still recommending it:
Urban Pest Consulting