Using Rodenticide Baits Inside Food Plants

Of the many topics relating to rodent control, few cause as much confusion and debate as the topic of rodenticide use in food plants. I can’t tell you how many times I’ve heard PCOs, quality assurance managers, sanitarians, city health inspectors and others say "rodenticide baits are not allowed" or "rodenticide baits should never be used" inside food plants or food-serving establishments. But are these statements accurate? Let’s examine this issue and attempt to clarify the confusion.

The Food and Drug Administration defines a food plant as "the buildings or parts thereof, used for, or in connection with the manufacturing, processing, packaging, labeling, or holding of human food." Some common examples of food plants include cereal processors, meat and poultry plants, fruit juice processors, bakery plants, grain processors, food distribution centers, food warehouses and breweries. But, as you can imagine, there are many others. In general, plants associated with meat and poultry products are United States Department of Agriculture (USDA) inspected. Most other food plants fall under FDA regulations and inspections.

Are rodenticide baits allowed by federal law inside FDA-inspected plants? Yes. Are rodenticide baits allowed by federal law inside USDA-inspected plants? Yes. In fact, rodenticide baits are permitted by federal regulations inside all types of food plants and other common food-handling establishments (restaurants, cafeterias, supermar-kets, etc.).

While we’re at it, federal regulations also permit the use of rodenticide tracking powders inside the above food plants and food-handling establishments. So why is there so much confusion regarding this issue? There are several factors involved.

INDEPENDENT ORGANIZATIONS. Many food plants use the services of various independent inspection services that provide a valuable and needed range of GMP and food safety audits to food-handling establishments of all types. The American Institute of Baking (AIB) is perhaps the most widely known, but there are others (e.g., American Sanitation Institute [ASI]). These inspection organizations often provide their own specific guidelines or standards as to the use (or not) of rodenticide baits and other pesticidal products inside and around the food plant they inspect. But it is important to note that these are guidelines, not regulations.

INDIVIDUAL FOOD PLANT POLICIES. Some food plants may establish their own pesticide risk reduction policy of minimal pesticidal use, including not allowing rodenticide baits inside their facility. Or, the food plant may totally adopt the standards and guidelines of their inspection service organization as their company policy. As a consequence, their in-house manuals and policies will state "rodenticide baits are not permitted inside any XYZ Baking Plants." When this message is transferred to contracted pest management technicians (as well as to new plant Quality Assurance [QA] managers, sanitarians, etc.), it is often incorrectly assumed that baits are not allowed because of federal regulations.

ASSOCIATED RISKS AND CONSIDERATIONS. Regardless of current regulations or specific company policies, the general mode of operation today in the food industry is that most food plants restrict the use of rodenticide baits to exterior programs and utilize a trapping program for interior areas. Still, baits are allowed to be used inside the majority of areas of both FDA and USDA food plants if: (A) conditions warrant such use; (B) they are used in such a manner so as not to present a contamination threat; and, (C) in the case of USDA facilities, they are used with the permission of the inspector in charge and under the specific USDA guidelines for such use.

However, there are some disadvantages and even risks associated with the use of rodenticides inside a food plant and these should be noted. First, rodents poisoned by baits may not die for three to eight days. In the meantime, they may venture into sensitive areas, contaminating food or food-preparation surfaces. Worse still, the sick rodents may enter product processing areas or stored product. It is likely poisoned rodents will not be recovered. Second, a poisoned rodent may die in inaccessible areas. The carcass may then create an odor and present a breeding medium for secondary pests such as various flies and other insects that decompose carcasses.

Other concerns and risks are often expressed by food plant personnel and inspectors, but in many cases these are no longer of the same significance they once were, or are not very plausible today. For example:

Another common misconception within the food industry is that because the rodenticides are "baits" (i.e., we use "baits" to lure and attract animals — fish bait, trap baits, etc.), rodent baits will therefore "attract" rodents into the plant. This is not true. Rodent baits are perhaps the equivalent of a dog biscuit or some similar compressed grain material. Such a small amount of food placed inside a bait station will not draw rodents into the plant nor to the exterior walls of the plant from the surrounding fields. This is especially true when you consider what role the various and copious amounts of food odors emanating from a food plant into the surrounding air might have in attracting the local insects, birds and rodents nearby.

RECOMMENDATIONS. In general, if the plant is employing good exterior rodent control programs, effective rodent-proofing techniques and good sanitation programs, rodent baits should have only a minor and "last resort" status for their use inside the plant.

But, a policy or attitude of never allowing baits inside the food plants may not be justified based on risks alone and does not provide the structure for a comprehensive rodent control program — including the judicious use of baits (see the following recommendations). There are cases when baiting inside a food plant may not only be required, but also be the wisest action relative to reducing risks associated with pest contamination. For example:

Personally, I’ve encountered several cases over the years, that if we had not used rodent baits indoors (at least for a temporary period), we would not have eliminated the rodents. However, when rodenticide baits are needed for use inside food plants, I recommend the following:

If a food plant or warehouse continually relies on baits to control rodents, then this is usually an indication of a serious problem with the facility or there is some extenuating circumstance outside of the facility involving a large rodent population exerting high pressure on the building. Rodenticide baits (inside or outside) cannot compensate for a plant that is not clean, does not maintain the exterior or does not practice pest-proofing procedures (keeping doors closed and rodent-proofed).

Some will argue that the risks associated with modern day bait applications are insignificant or minimal when baits are applied using proper precautions, when bait stations are used, when federal guidelines and laws are adhered to and when only those formulations that minimize bait translocation are used. Others contend that if any possibility — however small — of bait contamination exists, that alone is reason enough not to allow the use of rodent baits inside their food plant.

I feel that for 95% of the interior rodent control programs for well-managed food plants, baits should not, and need not, be used inside the plant. But to say never? My experience has been that Mother Nature is too demanding for the word "never" when it comes to attempting to solve the thousands of pest scenarios we as industry professionals must face on a daily basis — including rodents inside food plants. I want that 5% in my toolbox. I’ve needed it in the past. I know I’ll need it again in the future.