HACCP Spells Change for PCOs

If you’re providing pest control services to food processing facilities you better be familiar with the Food and Drug Administration’s new system for managing contamination risks in our nation’s food supply.

Pest management professionals face many new challenges when it comes to servicing their food industry clients. For instance, the FDA’s adoption of the HACCP system for managing contamination risks has increased the pressure on PCOs to deliver the highest quality pest control service in these accounts.

What is HAACP (pronounced "has-sip")? If you’re not sure, you better find out because your food industry customers are depending on you to understand the key elements of this important FDA regulatory initiative.

DEFINING HACCP. HACCP is a systematic approach to food safety that involves an in-depth analysis of all sources of hazards to determine critical points at which control can be applied to eliminate them. The word “critical” is key here, since HACCP allocates finite control resources to those points deemed necessary to reduce risk to a “statistically insignificant” level. The results of the analysis become a written HACCP plan that must be verified and periodically reevaluated to confirm that it results in the production of safe food.

Increasing regulatory concern about pest control is encouraging closer cooperation and better communication between sanitarians and PCOs. Sanitarians are responsible for correcting many of the conditions that contribute to insect infestation in food processing facilities. As a result of their expertise in this area, PCOs are in an excellent position to pinpoint problem areas for sanitarians, based on the insect species and relative populations they observe when servicing these accounts.

Traditionally, industry representatives and regulators have depended on spot-checks within facilities and random samplings of final products to ensure safe food. This system, however, tends to be reactive rather than preventive and can be less efficient.

A prerequisite companion to the HACCP plan is the Sanitation Standard Operating Procedures (SSOP), a written daily procedure designed to ensure that unsanitary conditions do not introduce various hazards into the account. HACCP specifically requires that these procedures prevent contamination from occurring in areas where food is exposed after critical control points, such as cooking. This is the juncture where HACCP and pest control converge: Pests with the ability to transfer pathogens responsible for foodborne illness (i.e., cockroaches or flies) must not have an opportunity to introduce these pathogens where they can survive and threaten consumers. Common prerequisites for HACCP programs include specifications for cleaning and sanitation, personal hygiene, chemical control and pest control.

A recent Regulatory Action Criteria from FDA makes this point quite clearly. It states, “Within Hazard Analysis and Critical Control Point and other U.S. Food and Drug Administration regulatory frameworks, disease-causing flies are contributing factors to the spread of foodborne disease that require preventive and corrective actions as appropriate under Sanitation Standard Operating Procedures, Good Manufacturing Practices or pest control programs.” Obviously, given this regulatory language, the FDA is not inclined to overlook pests as potential hazards.

Of course, food industry clients can keep better tabs on pest populations if they make it standard policy to conduct regular pest monitoring programs. Monitoring is one aspect of pest control likely to be significantly affected by HACCP’s emphasis on paperwork. Until recently, regulators relied heavily on “organoleptic” inspections (using their eyes and noses) to detect unsafe products indicating unsatisfactory operating procedures.

But the more scientific HACCP method focuses on inspecting the procedures themselves rather than catching problems during periodic inspections or while taking random samples of the final product. That means examining mandatory records of the daily execution of the HACCP plan, including structural pest control procedures. Infestation monitoring data acquires added value as documentation in such a record-reliant system. And whether or not it is explicitly required in their particular HACCP/SSOP plan, you can bet your clients would appreciate having this written evidence of due diligence if it should be needed.

In that regard, pest-monitoring data may have further applications, namely, establishing objective criteria for what constitutes due diligence. Several sections in the FDA’s Food Code prescribe preventive measures and call for exclusion and control of pests. Since pest control is conducted in the real world — where perfection is not a realistic standard — how exactly do regulators and those being regulated determine whether these requirements are being met? Monitoring provides numerical data that can be analyzed for trends and compared to previous results as well as results for similar facilities. This should make it much easier to answer the question, “How are we doing?” Both the FDA and the food industry would benefit from the availability of an objective yardstick to measure performance.

THE ROLE OF IPM. But an even better reason for measuring performance with insect monitoring is to improve the quality of service in these accounts. Integrated Pest Management accomplishes this by using monitoring data to “target” control measures and make adjustments based on the results of the pest control program. Therefore, IPM is likely to receive a big boost in popularity from HACCP. IPM’s reliance on entomological knowledge to optimize control and reduce the need for chemicals makes it a natural partner to HACCP’s systematic, risk-minimizing philosophy.

The less hazardous suppression methods such as insect light traps that IPM favors rely heavily on effective sanitation and exclusion. But preventive measures of this type also harmonize particularly well with the proactive HACCP risk management philosophy. Not only must vectors of disease be minimized on the premises, but the opportunities for contamination before their removal must be minimized as well. This is best accomplished by keeping them out (via screens, weather stripping, air curtains, structural integrity, etc.), rather than a reactive strategy of knocking down their numbers after they reach unacceptable levels in sensitive areas.

CONCLUSION. Food safety awareness is steadily growing and with it the political pressure for more rigorous standards. This is the driving force behind the adoption of HACCP in the seafood and meat and poultry industries. It will shortly become law for fruit and vegetable juice producers and the first draft for the retail industry is already being considered. The phasing-in of enforcement progresses from the largest facilities to “mom and pop” operations in the affected industries.

PCOs can expect to see a steady increase in the percentage of HACCP accounts on their client lists. We have speculated on a few of the possible implications for the industry: a stronger partnership between PCOs and sanitarians, an expanded role for pest monitoring, an acceleration in the trend towards IPM and an increased emphasis on preventive measures such as exclusion. But it doesn’t require psychic ability to predict that HACCP will cause significant changes in food industry pest control. PCOs who plan to stay ahead of the competition would be well-advised to reevaluate their operations with that in mind.