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NPMA Introduces Industry-Wide Standards for Servicing Food Plants
April 19, 2006 - By Greg Baumann, Vice President, NPMA, gbaumann@pestworld.org
We’ve all been there. Your best technician working in a food plant analyzes the critical areas of rodent control and places rodent stations. Then the food plant’s third party auditor comes in and demands that they be moved to a different distance between stations. The technician complies. Then another auditor comes in from a major customer of the food plant and, sure enough, they demand that yet another distance between stations is set. The technician, in desperation, throws his or her hands up in frustration and tries to figure out the right thing to do.
This scene occurs all too often. Besides the ill-will of our customers, this situation spills into other significant pest management arenas as well from personnel management to insect control.
Surprisingly, the food industry perceived that the pest management industry had inconsistent service. This led to some food companies to consider bringing pest management in-house as opposed to using pest control firms. While it was not a huge issue, the trend started. Currently, approximately 75% of the pest control work is done by pest management companies.
For years, the pest management industry has discussed the concept of “standards of practice”. Some companies supported standards; other companies opposed standards. Some lawyers warned that standards can be trouble for the industry; some lawyers felt that standards would be a savior as a defense tool in court. For sure, historically, there has been no shortage of opinions.
Third party auditors have an important function to provide contract services to food plants to look at microbiological testing and contamination potential, chemical testing, incoming materials, food safety, sanitation, and Hazard Analysis and Critical Control Points (HACCP). The auditors are hired either by the food plants to perform inspections which will ensure that systems are in place to reduce liability. The standard vs. no standard scales were tipped in favor of standards when NPMA began hearing rumblings from third party auditors that there is a trend where food plants are taking the pest management programs in-house. Some believe if standards are not implemented, then the food industry will move from 25% in-house work to 75% in-house very shortly. The industry needed to react. After talking to large food manufacturing quality assurance representatives, they perceived that they didn’t have the controls they needed for their corporate quality assurance standards. They also perceived that service varied wildly due to no clear standards. The food industry complies with many standards from the auditors (AIB, ASI, Cook and Thurber, Silliker, YUM, etc.) but there is no universal standard regarding pest management. Interestingly, the food industry is not expecting every pest management company to do exactly the same thing. Instead they are looking for some minimum standard so that they can be sure there is some consistency.
The NPMA Commercial Division Steering Committee, chaired by Don McCarthy of
In fall of 2004, NPMA assembled the third party independent auditors in a historic gathering and developed a series of topics that should be addressed in the Standards. All parties supported allowing individual companies the freedom to customize their programs while meeting certain criteria in areas such as personnel and service. Upon completion of the key points, the Committee began work.
“The Players” - NPMA Commercial Division Committee and Correspondents Don McCarthy, Braemar Pest Management Services, NS, (Committee Chair)
Robert Baker, Clark Jerry Batzner, Batzner Pest Management, WI Billy Blasingame, Arrow Exterminators, GA Ward Combs, Charles Dixon, Eric Eicher, The Steritech Group, MD Freeman Elliott, Orkin Pest Control, GA Douglas Gardner, EcoLab Pest Elimination, MN Brad Henry, Industrial Fumigant, KS Debbie Hoffman, Crane Pat Hottel, McCloud Services, IL Bob Kunst, Fischer Environmental, LA Rich Muscarella, Mark O’Hara,
Correspondents: Joe Hope, Bayer Environmental Science, NC Randy Moser, Shep Sheperdigian, Rose Pest Solutions, MI
“The Food Industry Players” - Third Party Auditors and Advisors Dan Carlin, Association of Operative Millers Tom Huge, American Sanitation Institute Bill Miller, YUM Brands (Taco Bell, KFC, Pizza Hut, A&W, Long John Silver’s) Bill Schwartz, Cook and Thurber Gary Smith, Silliker (replaced by Rena Pierami and Kaz Wolkensperg) Al St. Cyr, American Institute of Baking
Parts of the NPMA The program consists of five sections: Personnel, Pest Management Plan, Communications, Recordkeeping and Contracts, and the National Organic Program. Each of these major market segments is addressed in detail in the Standards.
Personnel Traditionally, there have been few personnel requirements for contractors in food plants. There is no intent to preempt any federal, state, provincial, or local regulations so GMPs and all associated requirements must be met. While pest management companies have individual requirements, there were no clear industry wide requirements. For personnel issues, the Standards address:
· Employee identification · Uniforms · Security and background checks · Customer personnel practices · Vehicles and their use · Safety · Minimum training standards including testing · Compliance with Current Good Manufacturing Practices (or equivalent outside of the
One area that is new and will certainly support high quality work is the area of training and testing. Currently, there are several correspondence courses available and the testing is above and beyond any state or provincial requirements. Details are being worked out but testing will most likely be available via a web based service. The proof of technician testing will be retained in the plant. This testing provision is a departure from previous food plant servicing requirements.
This section is really the heart of the program in that the original momentum was generated because of inconsistent viewpoints amongst the food industry, auditors, regulators, and the food industry. The sections include:
· Rodent Program, including Exterior, Interior, Facility History, Depth Matrix, Setting of Stations, and Monitoring · Birds and Wildlife · Weed Control · Quality Assurance · Annual Training · Storage (for materials used in pest management)
One ground breaking area that is new to the industry is the addition of the Rodent Program Depth Matrix. The most frequent complaint in service by our industry is the lack of information on rodent station placement. Clearly there are opinions, and they vary wildly, but there is no set template that is globally accepted. The committee felt it was important to address this area as it is the top frustration of servicing food plants. Using published information, a matrix was developed to provide guidance to spacing based upon history of the account and sensitivity to infestation. While there is no magic number, the Standards use a method to determine spacing and placement for the first time in the history of the food industry. This allows justification of the technician’s judgment servicing the food plant. All parties involved unanimously accepted the matrix.
The Standards were also carefully developed to prevent intrusion on a pest management plan and service protocols of an individual company. The Standards are very clear, however, there is much freedom in how to perform the actual service work. For example, the Standards discuss programs but avoid things such as telling a technician which product to use in which area for which pest. That is best left to the company’s decision and is not the intent of the Standards.
Communication All documents must be available to the plant either in hard copy or via electronic records within a reasonable time.
Recordkeeping and Contracts · Contracts · Labels and Material Safety Data Sheets · · Licenses and Certificates · Service Protocols and Standard Operating Procedures (SOPs) · Service and Treatment Records
Without adequate recordkeeping, there is no way to trace what was done. One frustration that the food industry revealed to us is that inadequate records of outside contractors such as pest control companies may lead to significant liability. By setting recordkeeping Standards, the food plant personnel can feel confident that the proper work is documented with proper records. In case of an emergency, records can be used to see exactly what was done. This is positive for the pest management industry. For example, if there is a contamination of some kind over a weekend and the Recall Committee of the plant is concerned that it may have originated with a contractor, the pest management company records can show that the technician did not use the contaminating product.
Contracts should eliminate conflicts as to who is responsible for which phase of pest management. If the contract is not clear, the plant may assume that the technician will be responsible for pest proofing when the pest management company never intended pest proofing as part of the plan.
National Organic Program The National Organic Program is a USDA program governed by Rule 205.271 and requires the handler or management of an “organic” facility to use management programs to prevent pests. When pests are of a concern, then methods should be used pursuant to IPM. In emergencies or when all other methods fail, products may be used that would not normally be considered for the “organic” program but there must be specific documentation. This section defines the program and provides guidance as to methods.
Appendices There will be several aids as appendices. Currently, a model check sheet for pest management inspections is included as the NPMA-38 form. A full set of the Current Good Manufacturing Practices will also be included.
The Future
With these Standards, there is a bright future for our industry as vital to protection of the food supply. These Standards will show the world that we are truly professional in our important task of preventing pests and infestation of the food supply. Timed to coincide with the upcoming Food Safety Standards, NPMA has once again partnered with the American Institute of Baking (AIB) to present two, two-day Food Safety & Sanitation for Food Plants: Workshops for Pest Management Professionals, sponsored by BASF and Woodstream Corporation. These workshops are designed to provide PMPs with essential information and training to better understand a food safety program. May 2-3, 2006: Hyatt Regency August 29-30, 2006: Space is still available, so register today!
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