QUESTION:
What are the guidelines and procedures for treating a Food Processing Plant?
ANSWER:
In general you are simply required to follow the product Label for any pesticides you may use in a food processing plant. However, this can depend upon a couple of things. One is whether or not the plant you are working with is inspected by AIB – the American Institute of Baking – which is a private organization that more or less polices food manufacturing in North America. They provide food safety inspections, audits of these businesses, training, and certifications all in the name of protecting the quality of food produced in North America and other countries around the world. If AIB inspectors do oversee the plant you are working with you will be obligated to work with their on-site inspector to follow the AIB guidelines, and you can access all of their “Standards” on their website at https://www.aibonline.org//
Another consideration will be whether or not there is any “Organic” production going on at the plant, in which case you would need to follow quite strictly the USDA requirements for the use of pesticides in organic facilities with their National Organic Program. You can find details on this at
http://www.ams.usda.gov/AMSv1.0/nop . You may also want to talk with the plant management to find out if they have any other programs going on, such as LEED Certification for green buildings. If so this will also affect how you do your work and the kinds of products you may be permitted to use.
But, in the absence of any other controlling circumstances you would need to ensure that any pesticides you use are specifically labeled for use in a food manufacturing plant, and if possible even more specifically labeled for the kind of plant – dairy, brewery, cannery, grain mill, etc. Most product labels seem to be fairly general once it gets to the “processing” stage of that production and they may not micro-divide it further than just Food Processing or Food manufacturing.
Within the plant you need to determine which areas are “food handling areas”, meaning those locations where food is “held, processed, prepared, or served”. Many pesticide products may be allowed for use outside the food handling areas but not within them, and it is important to know this and adhere to it in that plant. Even within a food handling area, if the product you choose is labeled for that use, you need to follow the label with respect to how it can be applied, and the choices usually are crack and crevice or spot treatment. This will be important in determining whether or not you can treat general surfaces or if you need to confine the material to voids and crevices and not on exposed surfaces.
I also believe that it is vital that you perform a careful and thorough Inspection before doing anything else. You should use a Written Inspection Report Form to document all of your findings so that you can present it to the management and discuss what needs to be done non-chemically. Clearly any pests residing comfortably within a food plant are there because of “contributing conditions”, and many of these conditions are unacceptable and should be fixed. This may include abundant openings from the outside that admit the pests and which can be permanently closed. It may be doors and windows propped open to admit flies. It may be exterior lighting that is inappropriate. It may be interior sanitation problems such as poor management of the waste stream, filth or spills on the floors, unnecessary wet areas, etc.
Depending on the kind of pests you should consider the use of pheromone traps for monitoring and UV light traps for flying insects. Anything you can do non-chemically to manage or reduce the pest problem is preferred over the use of chemicals, which are important but which should not be relied upon as the only tool you use. This, hopefully, is a basic overview of what is really a much more complex topic.
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Pest QuestionsSeptember 21, 2012