In Part 2, we will delve into and discuss the second section of this program.

PEST MANAGEMENT PROGRAM.

RODENT PROGRAM — EXTERIOR PROPERTY SURVEY

Before developing a rodent management program at each facility site, a thorough
inspection must be made. The exterior property of the property should be inspected
and the following observations (at a minimum) must be identified and documented
using a diagram and/or notes:

• Areas of rodent infestation based upon sightings, harborages, or other evidence including all areas of the building including roofs
• Areas of the property conducive to infestation such as cluttered areas, open trash, standing water, potential or confirmed burrowing areas
• Dumpsters which are not on rigid cleanable areas such as concrete pads
• Open doors or gaps in building areas that could permit rodent entry
• Clutter or debris underneath load levelers
• Dock areas that have clutter or debris
• Offloading areas with clutter or debris
• Tall grass and vegetation on property, sidings, and adjacent to buildings
• Perimeter areas of buildings having less than 24” of clearance and areas not having gravel or other material which will reduce chances of rodent activity
• Neighboring properties which may have conditions conducive to infestation

A summary of infestation observations and potential infestation must be documented
and presented to the pest management contact of the facility

RODENT PROGRAM — INTERIOR SURVEY

All areas of the facility interior shall be surveyed for rodents and conditions which may lead
to rodent infestation. The following observations must be identified and documented using
a diagram and/or notes:

• Open doors, gaps beneath doors, or other holes, gaps or cracks which could permit rodent entry
• Clutter, debris or other potential rodent harborage location
• Lack of 18-inch inspection aisle along walls
• Spillage or other potential areas of rodent infestation based on sightings, droppings harborage or other evidence
• Spillage or other potential food sources which could lead to infestation
• Storage practices that are conducive to rodent infestation

A summary of recommendations shall be provided to the pest management
contact at the facility to reduce the likelihood of future infestations
Any rodent management devices shall be mapped and recorded.

RODENT PROGRAM — FACILITY HISTORY

Prior to designing and implementing a rodent management program, a company
representative shall interview facility contacts and review all available rodent history
information, including, but not limited to:

• Previous rodent management efforts
• Pest management records including rodent trend analysis
• Pest sighting data

RODENT PROGRAM — FREQUENCY OF SERVICE

Following the initial inspection, examination of infestation history, and discussions with facility personnel, the potential for infestation is assessed. Based on this assessment, the pest management program can be developed collaboratively by the pest management company and the facility’s management. Facilities that are well sealed and have minimal chances of rodent infestation experience reduced potential for infestation. Conversely, if contributing factors such as exposed food material, potential entry points, or open doors on the building exterior are present, the potential for infestation increases significantly.

FREQUENCY OF SERVICE — EXTERIOR AREAS
Inspection frequency is based on the company’s evaluation of the facility’s rodent history
and potential for infestation. The minimum frequency of service conducted on exterior devices
will be monthly. Should rodent activity occur, service frequency, if needed, will be increased.
Results of the rodent history and infestation potential analysis should be reviewed
by and accepted by the facility contact and may be reviewed and adjusted as necessary.

FREQUENCY OF SERVICE — INTERIOR AREAS
Inspection frequency is based on the company’s evaluation of the facility’s rodent history
and potential for infestation. Minimum frequency of service on interior rodent monitoring
devices will be weekly unless otherwise agreed upon with the customer. Appropriate
documentation of any change from the weekly service schedule will be documented
and maintained on file at the facility.

RODENT PROGRAM — SPACING OF RODENT MANAGEMENT DEVICES

SPACING OF RODENT MANAGEMENT DEVICES
Rodent populations in food processing and handling facilities exhibit dynamic behavioral
characteristics. The placement of rodent monitoring devices must meet these challenges
with flexibility based on inspection observations and known behavior of the species present.
Establishing proactive preventive rodent monitoring programs in food processing and
handling facilities is essential to prevent risk to food products and the health of consumers.
Proper placement of rodent management devices relies on a thorough assessment of the
physical conditions of the facility and the presence of existing activity levels before an initial
monitoring program can be established. Additionally, due to changing conditions, the program
should be reviewed on a quarterly basis to ensure the needs of the facility continue to be met.
Record of service verification such as stickers, cards, or bar codes shall be on the inside
of the device, requiring the device to be opened to record data or to scan.
Proper care must be exercised to comply with the label in terms of access by children or non-target animals. If it is not possible to install rodenticide bait stations in secure areas, glue boards,
snap traps or other mechanical traps may be used inside of locked and anchored stations.
Monitoring stations may also be used with a non-toxic bait.

EXTERIOR RODENT MANAGEMENT DEVICES
Based on the target species, mechanical devices and/or tamper resistant bait stations will
be installed in locations based on the risks identified through the assessment. Conditions
identified, as increased or likely risk of rodent activity on the exterior require devices to be
placed in locations likely to intercept the target rodent. Every effort must be made to work
with the facility to eliminate conditions likely to attract rodents to the facility or provide
access into the facility. All monitoring device placements must be in accordance with
local, state, and federal requirements. If the previous 12 months of historical data is unavailable, or changing conditions make it difficult to determine the exterior rodent pressure at the time of the assessment, it is suggested an initial spacing placement of 50 to 100 feet. This placement would be established until the quarterly assessments and routine servicing of units can establish a baseline. The data collected during the monthly service of devices will be used to determine and justify the number and location of the devices. Identification of high or significant activity should indicate a need for increased surveillance and possibly additional monitoring devices until the activity is resolved.

PROPERTY PERIMETER
If an exterior property perimeter program is utilized, then based upon history, rodent
management equipment, such as but not limited to rodent bait stations or multiple-catch
traps, shall be placed along property perimeter areas (e.g. fence lines or outer boundaries)
at intervals based on the professional judgment of the company and in accordance with
rodenticide label instructions (if applicable).

EXTERIOR BUILDING AREAS (buildings at or near exterior walls of buildings on facility property)
Based upon history, rodent bait stations shall be placed along building exterior areas
at intervals based on the professional judgment of the company in accordance with
rodenticide label instructions (if applicable).

INTERIOR RODENT MANAGEMENT DEVICES
Based on the facility assessment and evidence of rodent activity, rodent monitoring devices
appropriate for the species present will be installed in appropriate location and numbers
to protect the food products from contamination. Every effort will be made to identify
and eliminate conditions encouraging rodent activity within the facility.
Interior devices should be placed in locations determined to likely intercept rodents. Sensitive areas such as grade level doors, receiving doors and storage areas for products coming indirectly from an exterior source should be considered as a suspect when installing devices.
If the previous 12 months of historical data is unavailable or changing conditions make it difficult to determine the interior rodent pressure at the time of the assessment, it is suggested an initial spacing placement of 20 to 40 feet. Appropriate spacing adjustments will be made based on the data collected. In areas where there is no evidence of risk or conditions likely to attract and harbor rodent activity, device spacing can be increased accordingly. However, in areas where there is evidence of activity or conditions that increase the risk of rodent activity, spacing will be decreased, and additional devices will be installed as deemed necessary to eliminate the activity and protect food products.

All devices must be numbered and records must reflect the location of each placement.
Rodenticides shall not be used inside food facilities in any area unless approved by the facility contact and permitted by label. Upon such a request, any action and reasoning must be documented and should be temporarily used when there is no exposed food product.
Non-toxic monitoring blocks may be used if permitted by facility contact.
Facilities should have an inspection aisle of at least 18 inches along walls. Commonly, this
area is painted white or another light color in order to contrast with droppings or insects.
Traps may be placed along these areas.
Due to concerns about allergens, no peanut butter or nut-based attractants may be used
inside a facility unless approved by facility contact.

RODENT PROGRAM — MONITORING

Adjustments to the program based upon observations may be made at any time. Use of
“temporary” program changes are acceptable. All traps, bait stations, and other devices
must be opened and inspected. Record of service verification or bar code shall be on the
inside of the station requiring the station to be opened. Observations must be recorded
as outlined in the Recordkeeping section.
All devices installed, permanent or temporary will be reflected on a site map, numbered
and accounted for at each service. Devices will be inspected for activity, cleaned and the
results documented at each service. Data collected on the rodent monitoring devices will
be trended and the information provided to the facility IPM coordinator for appropriate
action. Damaged devices will be documented and replaced at the time of service or at
the earliest possible time.
Rodents must be disposed of offsite according to facility and company policy.
Rodents, droppings, and any urine deposits or residue must be handled using protective
equipment per company policy.

REMOTE ELECTRONIC – MONITORING TECHNOLOGY

Remote electronic monitoring technology for pest management devices provide an
opportunity to use advancements in technology to improve the overall efficiency and
effectiveness of pest management activities. As the technology evolves, science based
reviews of the system confirm its value and customer acceptance expands; the devices
should become an accepted tool. The structural pest management industry embraces
proven advances in technology providing more effective and efficient IPM systems to
meet our customer needs.
Remote electronic monitoring devices will be able to signal an event notification to the
pest management provider and/or client. This type of information flow, if supported by
accurate data, may enable pest management companies to redirect their efforts to other
pest management actions. It is our belief that as the pest management industry gains
more experience with this technology and the equipment is refined; it will permit greater
flexibility in our ability to focus on the special pest management needs of a particular site.
Pest management companies will need to determine on a case by case basis how often
these devices need to be manually checked to maintain their functionality as part of
the food safety program.
The National Pest Management Association views this technology as a viable addition
to a sound science-based IPM strategy

INSECT PROGRAM

INSPECTION

A thorough inspection shall be conducted of the exterior of the building including
raw material receiving, receiving docks, shipping docks, load levelers, waste disposal,
entrances, roof areas, exterior storage such as silos, doors and windows, and ventilation
intakes to investigate signs of infestation or possible signs of infestation by insects.
A thorough inspection of the accessible components of the facility shall be conducted
not less than monthly. The areas to be inspected include but are not limited to floor/wall
junctures, drop ceilings, equipment, processing areas, warehousing materials and racking,
offices, locker rooms, mezzanines, raw material handling and processing, returned goods
areas, sample areas, windows, ventilation, shop areas, packaging storage and equipment,
laboratory areas, and cafeteria. In the course of the inspection, maintenance issues such as, but not limited to, holes in walls, pipe chases, bulk feed lines, spilled food items, or open doors/windows shall be noted.
Recommendations shall be made to the facility to reduce chances of future infestation.
A summary of infestation observations, potential infestations and recommendations for pest prevention shall be documented and presented to the facility’s pest management contact.

ACTION THRESHOLDS AND CORRECTIVE ACTION

Corrective action will be taken, when appropriate, based on inspection, monitoring
data and trend analysis in accordance with thresholds developed by the company in
partnership with the facility.

STORED PRODUCT INSECTS

Determination of the source of stored product pests must be completed where possible.
Sometimes, a certain lot of raw materials can be isolated as the source. If pests have spread into the facility, management measures must be performed.
Pheromones and pheromone traps may be used as part of the monitoring and management processes.

NON-STORED PRODUCT INSECTS AND OCCASIONAL INVADERS

Determination of source and entry point, real or potential, is necessary in developing a control/ management program. Commonly, mechanical alterations on the exterior will be necessary such as filtering incoming air, sealing cracks, repairing door gaskets or self-closing doors, etc.

PESTICIDE/ PRODUCT USE

In the event it is necessary to apply a pesticide product to help manage insects the product
shall be appropriately labeled for the intended use and site. These products may be residual, non-residual or non-regulated/exempt products.
An approved pest management product list should be developed
by the company and approved by the authorized facility contact person.
Space treatment may be used to reduce adult populations.
This may also include the use of insect growth regulators (IGRs).
General applications may be used only if the use of the product
will not contaminate the food product.
After coordination with the facility contact fumigation may be considered as part
of the management plan. These standards do not address fumigation specifically.
Insect bait stations may be used in areas not prone to heavy traffic or water accumulation.
Treatment of electrical panels and boxes must be done
with extreme care per the label and liquids should not be used.
All pesticide products must be used according to label instructions

INSECT LIGHT TRAPS AND OTHER FLYING INSECT TRAPS

Insect light traps (ILTs) may be installed to monitor and manage certain flying insects and to
be used as part of the decision making process for adjusting the program for certain insects
(e.g. Indian meal moths, fruit flies, etc.). Placement must be according to manufacturer’s
instructions and in compliance with any regulatory policies and guidelines. In absence of
instructions, ILTs should be placed in such a manner that will maximize insect capture without:
• interfering with facility operations
• being visible from the exterior
• being likely to attract insects to open food
Any ILT must be recorded on the site layout or map, and ILTs must have the same
recordkeeping as other types of devices.
Findings and seasonal requirements will dictate frequency of inspection as determined by
the company. Insect traps must be monitored based upon the contract. Weekly monitoring
is suggested for most cases, unless the traps are in an area or at a time of year when there
is no activity (e.g. unheated warehouse or in cold winter climates).
The type of ILT will be determined based on the area of the facility, regulations
and customer policy.
The trap must be cleaned in a manner that does not compromise product safety.

Trapped Insects must be examined and should be categorized according to:
• Stored product insects
• Structure infesting flies
• Other flying insects
The technician should assess whether the types and quantities of insects surpass pre-established action threshold levels. If they do, the insect management program should be adjusted accordingly to address the issue. Additionally, bulbs in ILTs must be replaced based on the manufacturer’s guidelines. In the absence of such recommendations, they should be replaced annually. It’s essential to have shatter protection in place in areas where food or packaging could potentially be contaminated by glass.
Glue board style ILT must have glue boards replaced when the glue loses tackiness, or the
number of insects caught exceeds the pre-established threshold levels. This replacement
threshold should be determined with facility management as part of the pest management plan

PEST MANAGEMENT SURVEY

At least monthly, the pest management company shall perform an inspection to identify
pests and the potential for infestation. Building maintenance, employee practices,
physical conditions of the facility, incoming materials, processing, and shipping shall
be evaluated. Recommendations shall be presented to the facility contact including
the review of facility documents such as incoming materials inspection and pest
sightings, and technician observations.
Forms shall be used to record observations and recommendations and a copy shall
be disclosed to and signed by the facility contact.
Forms shall have one copy submitted to facility contact, one copy shall be filed with
the pest management records and a copy shall be kept by the pest management firm
unless the forms are filed and maintained electronically.

STORAGE — STANDARD NUMBER

All pesticides for use in pest management shall be stored off site or in a locked and
secured storage area with adequate spill control and safety equipment for all materials
stored. All storage must be in compliance with government regulations as well as the
policies of the food facility. Any storage requirements listed on the label must also
be addressed. If storage is in a locked cabinet, all room requirements must be met.
Fumigants shall not be stored onsite unless storage requirements of the label are met.
Records must be stored in a secured area

COMPLIANCE WITH FACILITY
FOOD ALLERGEN CONTROL PROGRAM

Many consumers have acute reactions to food allergens. “Big Eight” allergens include:
cow’s milk, eggs, peanuts, tree nuts, soybean products, wheat, fish, and crustacean shellfish.
Consequently, facilities must declare if there is a possibility of any of these products entering
the food either as an ingredient or an incidental additive. Facility policies and third party
auditor standards may require formal food allergen control programs and these programs
might affect pest management practices.
The pest management company must comply with any facility food allergen control
program as it relates to pest management practices.

QUALITY ASSURANCE

At least once per year (prior to the anniversary of the date on which the company began
pest management services at the food facility) a supervisor quality assurance staff person,
or a manager from the pest management company shall review the entire program onsite
and provide a quality assurance audit. The quality assurance audit shall include a review
of the program, records, pest activity trends and frequency of service, as well as the monthly inspections to make sure that all documentation is in order. In addition, labels and Safety Data Sheets must be reviewed to make sure that all products used have current information.
Safety Data Sheets and labels of pest management products used at that facility must be
filed either in hard copy or via electronic records.
Results of the quality assurance audit must be filed in the facility, with a copy in the pest
management company office

ANNUAL TRAINING

At least once per year, the pest management company shall offer to conduct an educational
program for facility personnel. The date, content, and list of those who attend must be kept in
the facility’s pest management records.
The following staff should be encouraged to participate:
• Management
• Supervisory staff
• Security
• Mechanics
• Production lead staff
• Warehousing staff
• Quality Assurance staff
• Facility contact
• HACCP committee, if applicable
• Others to be determined
by the facility management
While the facility manager ultimately makes the decision as to who may attend and
the content, critical topics in line with current regulations, third party audit standards
and general pest management program goals include:
• Review of the pest
management program
• Vulnerable areas
• Practices which may reduce pest pressures
• Review of audits and monthly reports
• Pest exclusion
• How to record a pest sighting
• Review of FDA, state, provincial, local, and third party audits and inspections as related to pest management.
• How facility personnel should interact with pest management tools and devices

ANNUAL REVIEW

A review of the entire pest management plan should be performed on an annual basis
and adjustments made as necessary.
The annual review shall include, but is not limited to:
• Thorough inspection of the exterior property
• Thorough inspection of the interior of the facility
• A summary of pest infestations and conditions conducive to infestation
• An analysis of pest trend data
• Results of the quality assurance audit

“Refer to Part 1 for a deeper dive into this topic. Stay tuned for more in Part 3!”