Former Environmental Health and Sanitation Manager, Vikan North America

Cross-contamination control strategies, part 6: Dealing with the pest problem, product storage, and transport sanitation

Part 5 established the importance of risk-based sanitation control programs and procedures, which are essential to ensure the production of safe and high-quality food products.

This final blog in the series emphasises the importance of pest prevention within a food site and the need for sanitary storage, handling, and transportation of food products.

Pest prevention

Eliminating sources of food, water, and shelter can significantly reduce the risk of pest infestation in a facility. Maintaining a clean and tidy processing environment is a necessary step in pest control.

Pests are carriers of harmful microbiological hazards like Salmonella and are also responsible for foreign material contamination of food products through body parts, fur, faeces, etc.

Various regulatory authorities (such as the FDA, FSIS, and the European Commission) and global standards (including BRCGS, SQF, and FSSC 22000) mandate control measures to prevent pest infestation issues at a food site.

	21 CFR 117.35(c) on Pest Control, in part, states that: “Pests must not be allowed in any area of the food plant…Effective measures must be taken to exclude pests from the manufacturing, processing, packing, and holding areas and to protect against the contamination of food on the premises by pests …” In FDA fiscal year 2023 alone, there were 173 site violations of 21 CFR 117.35(c). FDA 21 CFR 117.20(a) requires that the grounds around the food facility must be kept in a condition that will protect against the contamination of food. In FDA fiscal year 2023 alone, there were 39 site violations of 21 CFR 117.20(a).
	9 CFR 416.2(a) on *Grounds and Pest Control*, in part, states that: “…Establishments must have in place a pest management program to prevent the harborage and breeding of pests on the grounds and within establishment facilities…”
	Regulation (EC) No. 852/2004 on the Hygiene of Foodstuffs, in part, recommends “…procedures, practices and methods to ensure that food is produced, handled, packed, stored and transported under appropriate hygienic conditions, including effective cleaning and pest-control."
	BRCGS for Food Safety, Clause 4.14: states that “The whole site shall have an effective preventive pest management programme in place to minimise the risk of pest presence, and resources shall be available to rapidly respond which occur to prevent risk to products.”
	SQF Code for Food Manufacturing, Clause 11.2.4.1 on Pest Prevention states that: A documented pest prevention program shall be effectively implemented. It shall: Describe the methods and responsibility for the development, implementation, and maintenance of the pest prevention program; Record pest sightings and trend the frequency of pest activity to target pesticide applications; iii. Outline the methods used to prevent pest problems; Outline the pest elimination methods and the appropriate documentation for each inspection; Outline the frequency with which pest status is to be checked; Include the identification, location, number, and type of applied pest control/monitoring devices on a site map; vii. List the chemicals used. The chemicals are required to be approved by the relevant authority and their Safety Data Sheets (SDS) made available; viii. Outline the methods used to make staff aware of the bait control program and the measures to take when they come into contact with a bait station;
	ISO/TS 22002-1 prerequisite programs on food safety for Food Manufacturing, Section 12.1, on the General Requirements for Pest Control requires that “hygiene, cleaning, incoming materials inspection and monitoring procedures shall be implemented to avoid creating an environment conducive to pest activity.”

Effective pest control measures may include (but are not limited) to the following:

Appropriate storage of equipment
Frequent removal of litter and waste
Ground maintenance including weed killing and grass and hedge cutting. Unkept grounds may attract pests or serve as breeding grounds or harborage spots.
Adequate draining of standing water that can become breeding/harborage points for pests.
Conduct regular inspections to identify pests and signs of pest activity.
Employ a professional pest control company to provide appropriate and effective pest control measures, e.g., flying insect traps, rodent traps, insect screens, and/or bait boxes.

Sanitary product storage and transportation

FDA 21 CFR 117.93 on warehousing and distribution, states that “storage and transportation of food must be under conditions that will protect against allergen cross-contact and against biological, chemical (including radiological), and physical contamination of food, as well as against deterioration of the food and the container.”

In FDA fiscal year 2023 alone, there were 52 site violations of 21 CFR 117.93.

Food storage areas and transportation carriers should be maintained in a sanitary state appropriate for the food being transported. In all cases, the sanitary condition of the storage and transportation facilities must minimise the risks of cross-contact with allergens, contamination by chemicals and foreign bodies, and adulteration. Some key precautions a food site may take (which have already been discussed in the previous blogs in this series) are as follows:

Hygienically designed surfaces, fixtures, and equipment in storage rooms and transport carriers so they’re easier to clean.
Ensure the proper layout and control of processes to minimise the risk of cross-contamination.
Manage hygienic and environmental monitoring zones. This can help improve sanitary conditions in warehousing and distribution scenarios.
Maintain cleaning and sanitation standards through proper policies, procedures, methods, and techniques to ensure food safety.

Other blogs in this series:

Amit M. Kheradia - Former Environmental Health and Sanitation Manager, Vikan North America

This blog emphasises the importance of developing, implementing, and maintaining the risk-based sanitation control programs and procedures necessary to ensure the production of safe high-quality fo...

Amit M. Kheradia - Former Environmental Health and Sanitation Manager, Vikan North America

Part 4 of our series discusses effective ways of managing hygienic zones and environmental monitoring zones that ensure that cross-contamination risks can be prevented, eliminated, or significantly...

Amit M. Kheradia - Former Environmental Health and Sanitation Manager, Vikan North America

In Part 3 of this series, we will focus on the importance of laying out an appropriate food processing environment and controlling the processes effectively to minimise the risk of product contamin...

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