by Shane McCoy, ACE
Documentation has always been an important part of a food-processing facility’s operations, but now the Food Safety Modernization Act (FSMA) mandates documentation be even more organized, detailed and accessible.
A food-processing facility’s documentation must produce the following trail of information for auditors and inspectors:
- Show that a pest management program is in place to intervene and eliminate pest threats.
- Describe the pest issue and what the response was to the issue.
- Document the effectiveness of the response.
- Document that the risk to the facility has been mitigated.
The documentation provided by a pest management professional and the QA manager for the facility will be closely scrutinized by regulators and auditors. If there is a pest incident or failure, the documentation needs to show that the facility and its pest management partner did everything in their power to prevent it, and that the failure has been acted upon and the desired results (i.e., pest elimination) achieved.
While pest management professionals are accountable for their work, food-processing clients are ultimately responsible for the pest management program within their facilities. A big part of that responsibility is documentation.
DOCUMENTATION TOOLS. Two of the most important elements in the documentation process are the logbook and the service order. They paint the picture of what is happening at your facility when it comes to pest management.
The Logbook. A facility’s logbook includes all the essential pieces of information that a QA or facility manager and their pest management vendor needs. It contains all applicable business and applicator licenses, certificates of insurance, and proof of training in GMPs, food plant procedures and FSMA.
The logbook also may include a materials list of what pest control products are approved for use in the facility. The product’s trade name, manufacturer and EPA registration number, as well as product label and safety data sheet (SDS) also would be in the logbook. It is important to keep the materials list current. It is best to have both the technician and client contact sign off on the list each time a product is added or removed.
The Service Order. The service order used to be a basic summary of what was done during that visit to the facility. The new FSMA mandates have changed all that.
No longer will simply scanning barcodes on bait stations or noting basic sanitation issues cut the mustard. The devil is in the details and today’s service order must be heavy on the details.
Pest management technicians now include greater detail, sharing the who, what, where, when and why of their service. They detail who they spoke with, what pest-conducive conditions were present and what corrective actions were taken.
A good service order will always detail what product was used, how it was used (i.e., crack and crevice, spot treatment, bait station application, etc.), and where in the facility (i.e., a crack and crevice treatment in the shaker room corner) it was applied.
The comments section of today’s service order allows facility managers to visualize the services provided and keep track of the progress of their overall pest management program.
TOP 10 DOCUMENTATION INFRACTIONS
When it comes to documentation, pest management professionals working with QA and facility managers need to remember three things: accuracy, consistency and thoroughness.
What are the most common pest management documentation infractions? Review this list and see if your facility and pest management partner are making the grade when it comes to documentation.
- Missing Labels and SDSs
- Missing Business License
- Missing Technician Licenses
- Missing Certificate of Insurance
- Not Documenting Pest Conducive Conditions
- Missing or Out of Date Device Map
- Missing Temporary Device Map
- Missing Approved Materials List
- Missing Annual Facility Assessment
- Missing Annual Insect Light Trap Bulb Change Dates
CONTENT RULES THE DAY. It is not enough to just capture data today. It is about capturing the right data. Data that will help predict pest trends and allow pest professionals and QA managers to develop a proactive response is what really matters.
When pest control companies pull together documentation for a facility, technicians need to concentrate on the following items. These three critical areas can accurately portray — often in real-time — the current condition of the facility’s pest management program:
- Pest Thresholds
- Pest Vulnerable Zone Inspections
- Corrective Actions
Pest Thresholds. A strategic pest threshold paired with a corresponding corrective action plan is the foundation of a proactive pest management program. Collecting and monitoring data on pest thresholds identifies established action thresholds and provides a specific recommended response to a situation. If a threshold has been exceeded, the action plan provides a step-by-step game plan on how to react to the pest activity.
Pest Vulnerable Zone (PVZ) Inspections. Pest vulnerable zones are areas in a facility that require additional inspection because of the likelihood of increased pest pressure. Pest pressures tend to be heightened in areas that have historically seen pests, such as those determined by trending reports, or areas that are at a higher risk for infestations because of their business function, such as receiving and production areas. PVZs are barcoded in the area and scanned for verification while performing the inspection and, of course, all findings are documented.
- Corrective Action.
If a pest-conducive condition (i.e., damaged door sweep or opening in the roof) or pest activity, like rodent droppings or fly larvae in a drain, is observed, corrective action must be taken by either the pest management vendor and/or the facility.
Documenting the corrective action that was taken accomplishes several tasks:
- It creates a “paper trail” for tracking who was responsible for carrying out the corrective action.
- It details what actions were taken and when (see “Service Order” discussion).
- It outlines the results of the corrective action — something auditors pay close attention to when completing their audits.
THE BIG PICTURE. Continuously documenting specific and prescriptive comments allows QA managers and pest professionals to conduct a deeper dive into the real reasons behind a pest threat.
Detailed documentation also helps create a level of transparency and accountability. Using the latest in hand-held and digital technology (i.e., Google maps of where all the bait stations are located around your facility or characteristics of neighboring properties that could be creating conducive conditions) allows pest professionals to share information instantaneously with not only the local facility management, but also corporate QA contacts located across the country.
In the post-FSMA era, something that is not written down simply didn’t happen in the eyes of an auditor, inspector or the court. Establishing and following proactive documentation protocols will not only keep your facility compliant and improve efficiency in operations, it will protect your brand and your bottom line.
This Tech Talk article was originally published in the October 2018 edition of PCT magazine.