By: Rick Paterni
A look into the FDA Food Safety Modernization Act’s criteria for preventative pest control and an exploration of effective products that support food safety compliance.
FDA FSMA Pest Control Compliance
The Food Safety Modernization Act (FSMA) became law when it was signed by President Obama on January 4, 2011. It is the first major piece of legislation targeting food safety in over seventy years and marked the Food and Drug Administration’s shift from reactive to preventative control.
The law gave the FDA authority to require comprehensive science-based controls across the food supply chain. The FSMA impacts every facet of the U.S. food system, from farms to manufacturing facilities to importers. The law is coming into full effect in the coming months, although compliance dates vary depending on business size and the rule or standard that the business falls under. Detailed information can be found at the FDA FSMA website.
One of the key controls the FDA is using, is that covered facilities must establish a food safety system. Title 21 CFR, Part 117, subpart C of CURRENT GOOD MANUFACTURING PRACTICE, HAZARD ANALYSIS, AND RISK-BASED PREVENTIVE CONTROLS FOR HUMAN FOOD, states that it must be a written plan that includes:
- A hazard analysis
- Preventive controls
- A risk-based supply chain program, if appropriate
- A recall plan, if there are any hazards associated with the food
- Procedures for monitoring the implementation of the preventive controls
- Procedures for verifying that the preventive controls are consistently implemented and are effectively minimizing or preventing the identified hazards
Businesses of the US or any other country that are required to register with the FDA as a food facility must comply with this rule. As part of preventative control, the FSMA also added the below criteria when it comes to pests:
FDA Food Safety Modernization Act (FSMA)
Federal Register Vol.80 No. 80.
- 117.35 Sanitary operations.
(c) Pest control. Pests must not be allowed in any area of a food plant. Guard, guide or pest-detecting dogs may be allowed in some areas of a plant if the presence of the dogs is unlikely to result in contamination of food, food contact surfaces or food-packaging materials. Effective measures must be taken to exclude pests from the manufacturing, processing, packing and holding areas and to protect against the contamination of food on the premises by pests. The use of pesticides to control pests in the plant is permitted only under precautions and restrictions that will protect against the contamination of food, food-contact surfaces, and food packaging materials.
FDA Current Good Manufacturing Practice.
Federal Register Vol.78 No. 11
What requirements apply regarding pest control in buildings?
(a) You must take those measures reasonably necessary to protect covered produce, food-contact surfaces and food-packing materials from contamination by pests in buildings, including routine monitoring for pests as necessary and appropriate.
(b) For fully-enclosed buildings, you must take measures to exclude pests from your buildings.
(c) For partially-enclosed buildings, you must take measures to prevent pests from becoming established in your buildings (such as by use of screens or by monitoring for the presence of pests and removing them when present).
Products for Pest Control Prevention
With the deadline for compliance approaching quickly—as soon as early 2018—now is the time to begin researching effective controls and implementing preventive measures.
While full FSMA compliance can be a daunting task, there are already products available to help with compliance in the pest control section. Organizations such as NSF International and AIB International (American Institute of Baking) have been in the forefront of testing and specifying products for the food service industry. These products have evolved into effective and easy to use preventative pest controls.
Most facilities have two types of openings; loading dock/service doors and personnel/customer doors. When preventing pests from coming in from loading dock doors, there are two products that can fill the need. Roll-up doors and air curtains are accepted industry standards.
Mesh Roll-Up Doors
Mesh roll-up doors allow ventilation while keeping persistent bugs and birds out. The roll up doors consist of a tight 17 x 11 weave mesh screen that rolls up in extruded aluminum guide tracks. Operation of the screen door can be handled in a number of ways. Spring loaded and chain hoist are the most economical operators, though motorized doors with various activation devices are also available.
The saying “always open/always closed” is often heard in relation to air curtain performance—“always open to customers and workers to freely walk through the opening but always closed to pests and environmental contaminants”.
Air curtains work as a pest deterrent in two ways. They provide environmental separation that helps keep the sweet smells inside the facility, therefore NOT ringing the dinner bell for every hungry insect in the area. The air curtain also creates a barrier of air that deters the insects from entering the facility. The National Sanitary Foundation International states in NSF/ANSI 37 that a service entry air curtain must be able to produce an air velocity of at least 1600 fpm at 36” above the floor. The air stream must also be at least 3” thick to provide adequate protection.
Insect control at personnel/customer entrances are usually handed by air curtains as it is the least obtrusive form of protection. Multiple activation options allow the air curtain to come on as soon as the main door is opened.
Mesh Strip Doors
Mesh strip doors are another effective option for personnel doors. These doors consist of plastic mesh strips that are installed with an overlap. The strips have PVC weights sealed inside mesh strip to provide resistance to breezes These strip doors allow ventilation while keeping pests outside where they belong. We have mounting hardware and overlap configurations for most door applications.
Insect Light Traps
Insect light traps act as an extra line of defense against pests when used inside a facility. Light traps offer 24-hour non-chemical trapping of insects. The insects are attracted to an ultraviolet light source and are captured on a replaceable adhesive board. The energy efficient UV lights are tuned to a high intensity that attract insects from a large area. There are lights on the market that provide insect coverage from 900-3500 square feet per light.
Ventilation is an important part of many facilities. Openings in ceilings and walls often provide pests an easy way into a facility. We can produce a custom mesh screen that will still allow ventilation and keep pests outside.
The Food Safety Modernization Act is as complex as it is important. Consulting a knowledgeable pest control specialist would be in any food facility’s best interest and can help alleviate many of the challenges associated with pest control compliance. With over 30 years of experience in pest control, Senneca Holdings offers a full line of high-quality mesh roll-up doors, mesh strip doors, air curtains and insect light traps that help fulfill FSMA pest control requirements.
The Senneca team works closely with food facility building supervisors and maintenance crews to provide complete pest control packages. This allows these individuals to dedicate their time to other FSMA-required procedures such as record keeping and visual inspections. Take advantage of Senneca’s experience in pest control and contact a knowledgeable representative to discuss your food facility’s pest control needs today.
About Senneca Holdings
Senneca Holdings is a diversified management and holding company whose companies are focused on the specialty door industry. Senneca oversees the operations of its companies, allocates resources among them, and helps to improve the performance of its operations. Senneca seeks out acquisition opportunities that strengthen our position in a business segment as well as companies that will diversify our portfolio of specialty doors.