Editor’s note: This Q&A article originally appeared in the November/December issue of AIB Update, published by PCT’s parent company, GIE Media. It is intended to help in the interpretation of requirements of the IPM section of the AIB International Consolidated Standards for Inspection as food and beverage processors prepare for that portion of an AIB inspection. Many PMPs service food-processing accounts, so this information will be a helpful tool for those involved — and those looking to get involved — in these types of commercial accounts. The numbers refer to the critical or minor requirements as listed in the Consolidated Standards for Inspection.
22.214.171.124 What should a written IPM program be based on?
A written IPM program should identify the goal, scope and procedures for execution of the program. The program should be based on current scientific information and combine the use of pest behavior, biology and environmental considerations.
126.96.36.199 What do you mean by consideration of other written prerequisite and food safety programs?
This means that components of the IPM program may overlap the requirements of some of the other prerequisite and food safety programs, so these programs should be considered. For example, any pesticide or chemical you use in a facility would be subject to its chemical control program. Additionally, for any facility in which you work, you would be required to have contractor GMP training with sign off and facility access that is in line with the guidelines of the facility food defense program requirements.
188.8.131.52 What is the goal of the annual assessment?
The goal of the annual assessment is to evaluate the status of the current IPM program and identify conditions at the site or within the facility that would offer the potential for development of pest activity. A best practice would be to conduct fewer in-depth quarterly reviews instead of a once-a-year review to ensure that the programs are being carried out and that they remain effective for identification and control of pest activity.
184.108.40.206 What do you specifically mean when you say the assessment should evaluate all areas inside and outside of the facility?
During the assessment, look for pest activity or conditions inside the facility or on the facility site (grounds and roof) that would encourage pest development or allow entry into the facility.
220.127.116.11 What is meant by the statement that IPM service providers must maintain evidence of competency by exam from a recognized organization?
Continuous education is vital to ensuring that personnel stay current on new scientific developments and technology available to the industry. A best practice would be to ensure all PMPs with food-processing accounts are undergoing continuous education through annual recognized training programs, comprehension assessment or testing in IPM and GMPs.
18.104.22.168 Are we required to record the lot number of the pesticides that we use at the facility?
You are required to record this only in the case that it is a requirement of the facility’s IPM program, if the company has an agreement with its customer to do so, or if it is or becomes a regulatory requirement. Whether or not this is a regulatory requirement is dependent upon the country where the facility is located. Many facilities have included this for traceability purposes as a part of their food defense programs.
22.214.171.124 When you say current levels of pest activity and recommendations, what kinds of information are you looking for?
In order to leverage this information to the best advantage, we need to know the species of pest and the numbers involved. This will allow the PMP and facility personnel to base the treatment and abatement plan on scientific information related to the biology associated with that pest.
126.96.36.199 What kinds of exterior monitoring devices should we be using and what should we be considering?
Exterior rodent monitoring can include use of mechanical rodent devices and/or bait stations. The device you use will be determined by the facility assessment. If bait stations are used, you will need to follow the usage directions on the label. There have been changes to the label in many countries that restrict where baits can be placed and used. Other areas that need to be considered as part of the assessment are roof locations and other structures that may be on site.
188.8.131.52 Is the distance indicated in this element of the standards a requirement?
The short answer to this question is that this is not an AIB mandate. If the facility assessment or survey conducted in element 184.108.40.206 indicates that a different distance is optimal based on the site or historical data, then this scientifically based and validated information should be used as the criteria for setting up this program. If there is no historical data from which to draw, the indicated distances are a suggested place to start until enough data can be collected and evaluated to determine placement of these devices. There also may be times that additional trap placement or a decrease in the device distance would be warranted based on activity.
220.127.116.11 Are non-toxic, food-grade attractants allowed to be used to enhance the effectiveness of our rodent trapping programs?
If there is a known rodent presence, then, certainly, they are an effective means of dealing with such a significant issue. Use of attractants, in accordance with label directions, would be permitted in the case of an identified rodent issue to expedite the removal of this presence.
18.104.22.168 Should I consider the roof when conducting my assessment for device placement?
Absolutely. Your assessment should consider all avenues by which pests may enter the building and appropriate measures, including trap or bait station placement on roof areas, should be considered as part of the assessment process.
22.214.171.124 What do you mean by spacing and number of traps is based on activity levels?
The spacing and number of traps and where they are used should be based on your facility assessment and evaluation of the trend data that is coming from the trap inspection and other programs. If the data from the rodent control program, self-inspection programs, or review of materials indicates that there is a rodent issue in the upper levels of the ingredient storage areas, or in the middle of product stored in racks in the warehouse, for example, then the expectation would be that the site would use this information and provide appropriate trapping devices in the area to assist in identifying and eliminating the rodent activity as identified through these tools.
126.96.36.199 Is the distance indicated in this element of the standards an AIB requirement?
The short answer to this question is that this is not an AIB requirement. As previously noted in relation to element 188.8.131.52, if the facility assessment or survey conducted for element 184.108.40.206 indicates that a different distance is optimal based on the site or the historical data, then this scientifically based and validated information should be used as the criteria for setting up this program. If there is no historical data from which to draw, the distances indicated are a suggested place to start until enough historical data can be collected and evaluated to determine device placement. Again, if the activity or trend analysis indicates that there is a need to add additional rodent control devices or to decrease the distance between the devices, then changes in the distance and number of devices used must be considered. (See graphic above.)
220.127.116.11 Is there any measure, other than changing bulbs annually, that we can use to ensure that insect lights are effective?
The manufacturer will have information regarding the lifespan of these bulbs to ensure peak performance. There is also testing equipment available that can be used to measure the effectiveness of the bulb.
18.104.22.168 How do I ensure that I am getting the maximum effectiveness out of my pheromone monitoring devices?
The label is the best place to start. It will tell you the species of insect for which the pheromone is effective, provide directions for installation and note when the devices need to be replaced to provide the most effective detection of stored product insects.
22.214.171.124 Why do you include domestic animals in this requirement?
This refers to feral animals, such as cats and dogs. Any nuisance animal on the grounds could enter the facility and pose a risk of product contamination.
Al St. Cyr works in food safety at Clark Pest Control and is former head of food safety education for AIB International. Bonnie Biegel is director of quality management systems at AIB International.