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Lisa Lupo

FDA Compliance

Food Safety Auditors’ Red Flag: No Documented Issues

Food plants are expected to have environmental issues, especially with pest management

Published: Tuesday, April 12, 2011 - 06:00

Companies aren’t perfect, and neither are the people who work for them. Since this is a fact rather than a judgment, it’s reasonable to expect errors in manufacturing and process management. When an audited company continues to show a flawless record for, say, a food-safety audit, chances are it has overlooked an issue or two.

“Food plants need to show and document that they are dealing with environmental deficiencies such as sanitation, maintenance, and conducive condition issues,” says Bruce Achterman, director of marketing and sales for In-Quiz-It Software. “They are expected to have them and expected to correct them. If they don’t have issues, then in most cases it will raise flags as to why they don’t have them.”

In addition, auditors cannot know all the minute details and processes of every segment of the industry, so they will want to see a paper trail, says Zia Siddiqi, Orkin Pest Control’s director of quality systems. “You can’t do that in a week and be prepared.”

“The first place I go to are the records,” says Richard Kammerling, president of RK Pest Management Services, commenting about plant inspections. “If they are in order and everything is properly documented, you can use them as a guideline.”

Audit-ready every day

Thus, while it may sometimes seem that a food safety auditor is spending more time inspecting paperwork than inspecting the plant, one need only remember the unseen dangers of the peanut product contamination to understand why inspectors place such importance on addressing issues as they occur—and documenting them, rather than attempting last-minute additions in preparation for an audit.

In addition, if a plant is not continually audit-ready, it is putting its product, and thereby the consumers of that product, at risk. And any such risk is a blight on the entire brand and industry. “You don’t want to have an incident on the 6 o’clock news,” says Siddiqi.

On the other hand, achieving high or perfect scores on audits can promote the brand and increase consumer trust. “In the last three years, this has become very important,” says Siddiqi. “People have become conscious and aware of it.”

“If you read about the issues at Peanut Corp. of America, they took three weeks to clean up before the audits,” says Achterman. “Then the plant looked like it did before the clean up within a short time after. If you’re doing the job the way you should be doing it, then you don’t need to really prepare.

Achterman compares an audit to readying one’s home for guests. “If you have to scurry to polish it up before guests arrive, then that is acceptable for a house. If you have to clean for three days beforehand, that’s seriously letting things go.”

When it comes to pest control, doing the job the way it should be done, Siddiqi says, involves training both plant personnel and the pest control operator—whether that be internal or third-party. Siddiqi cited a case where an auditor was checking records at a plant; when he came across the name of the plant’s pest control provider, the auditor asked to see his training and certification records.

Although it is not mandated, similar training requirements should be in place for plant personnel to include education on integrated pest management (IPM), the role each worker plays in its success, and the program as a whole.

“I do think the food processors themselves have to have a role in the pest control program,” says Hank Hirsch, president of RK Environmental Services. “It’s really the one part of the food-safety program that gets outsourced, so you need to take a managerial role to make sure it is being conducted.”

Pest management

Managing the pest control program is critical because, as Kammerling says, “Pest prevention is one of the major building blocks of a food safety program. Sanitation is pest control; without that, you really don’t have a pest program.”

Achterman agrees. “The whole reason plants get pest issues is that they’re not handling sanitation and maintenance issues,” he says.

If prevention, sanitation, and exclusion are not maintained, pest problems have more opportunity to develop. “You need to break the cycle,” says Kammerling.

One way to ensure that pest management is a regular part of plant processes is to incorporate it into the master cleaning schedule, Hirsch says. “Clearly it is something you cannot let lapse.” Hirsch explained that by making it part of the master cleaning schedule, you will regularly address seemingly minor issues that could lead to increased opportunities for pests. “It is small areas like product spillage that goes unresolved that can lead to pest infestation,” says Hirsch. “When it is done on a scheduled basis, it is so great, but when you let it lapse, things begin to fall apart.”

Data analysis

Although the industry is trending away from pest programs based on simple trap checking, pest control equipment, such as rodent stations and insect light traps, are still essential elements of a complete pest management program, and serve a critical function in monitoring for pest presence. “They work 24/7, and they support the visual inspection,” Kammerling says. “You can’t conduct an inspection effectively without the support of a monitoring system.” Thus, inspecting traps can provide a basis for the pest program. “It will tell you the hot spots and potential hot spots you need to address. Then the visual inspection has to take over. You need both.” However, any good program goes well beyond simple inspecting of traps and information gathering, adds Kammerling. “It’s what’s between the traps that really matters. It’s what you do with the information.”

It is that which is “between the traps,”—the data gathering that forms the basis for documentation, analysis, and corrective action—that is most important in audits and inspections, whether internal, government, customer, or third-party. “People are so keyed into inspecting the box that they lose sight that the box is representative of the area,” says Achterman. Thus, rather than simply inspecting a station and checking it off on a list, all documentation of equipment and surrounding area should be entered into an electronic system by which trend analysis can be conducted, he says. “It’s not just a gathering of data. If you’re really looking at the data, you’ll see trends; you’ll see spatial-type graphing.”

Achterman cited the example of a plant that had made a major investment for a contractor to caulk the entire exterior of the building. Yet the plant was still having a mouse problem. When they looked at the data, they saw it trended toward a high percentage of mice in a single area. Upon inspection, a large hole under an area of corrugated metal was found that had been completely missed. “You don’t see those things, but you see them on graphs,” he says.

“When you really get down to the role of a good pest control operator for food processing, their primary role is to make observations, communicate them, then work toward corrective action,” says Hirsch.

Corrective action

It is this corrective action that is not only critical in record keeping for audits, but also in ensuring a food-safe environment in your plant. And although it is the responsibility of a good pest control operator to assist the food plant in detailing the needed action, the plant holds primary accountability for taking action. “The food facility has the responsibility to address whatever corrective action the pest control company is recommending,” Hirsch says. “If the recommendation is documented, as it should be, and the plant has not taken or documented corrective action, then it will become an audit issue.”

Reprinted with permission from QA (Quality Assurance & Food Safety) magazine, May/June 2011.

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About The Author

Lisa Lupo’s picture

Lisa Lupo

Lisa Lupo is managing editor of QA magazine. She can be reached at llupo@giemedia.com.

Comments

Pest Management Audit in FOod Industry

I agree its not a one day Job. Most of the food industry feels the Pest Management Proffessional as a Magician and Solely responsible for the Pest Scenario. I have noticed that till last minute the facility do carry out the Housekeeping work and some time even avoid the Auditors to restrict the visit. The crucial areas serves as a major either breeding or pest attracting point. Merely not auditing such areas will not serve the purpose as the infestation is bound to cross migrate from this area to the treated areas. To overcome this situations industries should change their focus from Production Oriention to the Good Manufacturing Procedures. Preventive maintance will avoid such situtation and will always ready for the undeclared auditing of the facility.

Pest Management Audit in FOod Industry

I agree its not a one day Job. Most of the food industry feels the Pest Management Proffessional as a Magician and Solely responsible for the Pest Scenario. I have noticed that till last minute the facility do carry out the Housekeeping work and some time even avoid the Auditors to restrict the visit. The crucial areas serves as a major either breeding or pest attracting point. Merely not auditing such areas will not serve the purpose as the infestation is bound to cross migrate from this area to the treated areas. To overcome this situations industries should change their focus from Production Oriention to the Good Manufacturing Procedures. Preventive maintance will avoid such situtation and will always ready for the undeclared auditing of the facility.