Spotlight on Food Safety, Sponsored by Bayer, Lessons from FSMA

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July 15, 2020

The Food Safety Modernization Act changed how we conduct pest management in food processing plants. Experts say these practices can elevate your service offering with other clients, as well. 

The Food Safety Modernization Act, enacted in 2011, made sweeping changes to how food manufacturing and processing plants operate to ensure food safety, including how they manage pests.

It shifted the focus from controlling pests to keeping them out of facilities in the first place.

“Preventive control is what it’s all based on,” said Hank Hirsch, president of RK Environmental Services, which specializes in pest management and food safety consulting for food processing facilities. As a result, these clients are more open to doing pest proofing. “They’ll make investments where they may not have in the past,” said Hirsch.

While the stringent regulations of FSMA are specifically geared to food manufacturers, they will likely influence how pest management is carried out in other food and beverage industry operations as well.

So, grain producers, local craft breweries and bakeries are subject to federal inspection under FSMA. Even restaurants, grocery stores and hospitality accounts, which are governed by state and local laws based on the Federal Food Code, a U.S. Food and Drug Administration (FDA) guideline, may be impacted.

“There is no question that FSMA has had a trickle-down effect on the FDA Food Code and how local and state regulatory bodies enforce their own regulations,” said Steven Sklare, who heads the Food Safety Academy and also operated a commercial pest management company for 25 years.

This means you have to pay attention to FSMA even if you don’t treat food processing plants, said Joe Barile, technical service lead at Bayer. “It’s going to impact everything,” he said.

Customers also understand the importance of FSMA and the essential role pest control plays in protecting the public’s health, food and property. “Pest control is a critical component of any food safety program,” observes Jorge Hernandez, vice president of quality assurance, The Wendy’s Company. “Pests are not only known carriers of food-borne pathogens … but also adulterate food themselves with foreign substances such as insect eggs, larval skins, hairs or waste. As if that wasn’t enough, few things can bring down a food business faster than pests. That’s why it’s importance cannot be underestimated.”

“Pest control is really the basic foundation for food safety,” added Charles Cortellini, vice president of research and development for Massimo Zanetti Beverage USA. “Without being able to control pests from incoming material/ingredients to the actual manufacturing floor, you cannot have any confidence in your food safety program. It really is your first line of defense.”

Whether your clients are food-processing plants, fast food restaurants or food service companies, you can elevate and differentiate your service offering by employing these best practices:


Embrace Real IPM. Under FSMA, food and beverage producers need a robust integrated pest management (IPM) program to fulfill the requirements of its Preventive Controls Rule, enforced by the FDA. “They’re seeing IPM as a critical component in their overall food safety system,” explained Hirsch.

Yet many PMPs spend most of their time at these accounts inspecting traps, fly lights, bait stations and other devices. This is not IPM; it’s pest monitoring, and it doesn’t leave the technicians with much time to do pest prevention.

As the industry continues to evolve, PMPs are shifting from a culture of pesticide application to a culture of diagnostic analysis and targeted treatments, which includes the adoption of innovative new tools like the Bayer Rodent Monitoring System.

As defined by the University of California, “IPM is an ecosystem-based strategy that focuses on long-term prevention of pests or their damage through a combination of techniques” including the elimination of conducive conditions, proper waste management, structural repairs and the targeted use of pesticides as necessary. It is just such an approach that enables PMPs, through the use of IPM techniques, to fulfill the prevention- and risk-based rules of FSMA.

IPM is not one-size-fits-all, but takes into account a facility’s age, construction materials, the building design, pest history, what the facility produces, where supplies come from, how they’re stored and used, and geographic location.

For instance, an urban facility will have pressure from rats and American cockroaches; a rural one will have issues with mice and overwintering pests. “Every food plant, even if they’re identical, is going to have a different risk,” said veteran PMP Dan Collins, who has treated a broad range of food processing facilities.

So, if you are focused only on the trap line, you would be missing the pest activity and conducive conditions that exist away from those traps. “There are so many things in a plant or even in a restaurant or grocery store that we need to train our technicians better to find,” pointed out Chris Del Rossi, founder of Food and Drug and the Bug, which provides pest prevention services to New England-based food and medicine producers.

For some companies the shift from the current pest management system, which emphasizes reaction rather than prevention, will be foundation shaking. “I see a very strong culture change that’s coming to us. We’re going to have to move from a culture of application to a culture of diagnostics,” said Barile.