[Commercial Pest Management] Inspection vs. Audit

Veteran food safety expert Al St. Cyr warned pest management professionals that working in food plants will require an exponential increase in documentation efforts due to new Global Food Safety Initiative (GFSI) requirements.

Initiated in 2000, the food industry created GFSI to deal with a number of food scares. Designed to enhance food safety and strengthen consumer confidence, the GFSI includes new food plant auditing programs that will impact pest management specialists.

"It is going to be a fairly big change for the pest management industry. For years we've been talking about the importance of documentation, but with the advent of benchmarked audits there is going to be a very serious change," said St. Cyr during his presentation, "An Auditor's Perspective of IPM," at PestWorld 2010, the National Pest Management Association's annual conference. St. Cyr, who has more than 30 years experience in pest management in food production facilities, is head of Food Safety Education at American Institute of Baking International (AIB), Manhattan, Kan.
 

Inspection Vs. Audit. A big part of the change, St. Cyr said, is the fundamental difference between an "inspection" and an "audit." At AIB, for example, inspections emphasize a physical observation of the facility and its practices at a moment in time — that means spending 75 percent of inspection time on the plant floor.

In contrast, benchmarked audits associated with GFSI focus on reviewing documentation. "The GFSI audit process, which will take 3 to 6 days depending on the size of the facility, is 90 percent paperwork evaluation. That is why the impact on the pest management industry is going to be pretty radical, because [the pest management industry] has not really stepped up on the documentation issue," St. Cyr said. Further, GFSI audits are ISO-based, meaning they cannot be prescriptive or educational. The result will essentially be pass or fail, with the auditor providing no consultation on how to improve.
 

Tell A Story. The key to compliance, St. Cyr said, will be giving GFSI auditors a thorough accounting of your pest management efforts, so that they can follow the logic of your actions. "Auditors don't have pest management training nor IPM expertise, but they can follow a paper trail from beginning to end," St. Cyr said.

For example, certain triggers, such as a pesticide application, will raise an auditor's antenna and he or she will want to see a comprehensive and clear paper trail documenting why the application was the best course of action.

According to St. Cyr, an effective paper trail starts by documenting the protocol you are using for pest management efforts in a food facility. "It is important that you have a recognized reference program to which the auditor can refer." For example, suggested guidance documents include the National Pest Management Association's Pest Management Standards for Food Plants, and/or AIB's Consolidated Standards for Inspection: Prerequisite and Food Safety Programs.

For specific products or techniques, regulatory documents and/or manufacturer's guidelines can serve as the necessary standard. For example, St. Cyr said EPA PR 94-7, which defines what a tamper-resistant bait station is, can serve as the standard for the auditor to refer to regarding rodent control. "An auditor isn't going to evaluate the design of the bait station you are using, he is simply making sure you have a standard in place for bait stations and is looking for documentation that links your decision making and the end result," St. Cyr said.

In the case of fly control, an auditor will be looking for citations, regulatory guidance or manufacturer's recommendations on the placement of insect light traps. "The auditor expects you to document your standards and then they will measure your compliance against the criteria that you set up for your program," St. Cyr said.

Further, pest management professionals must document any chemicals that may be used, have details on file (such as labels and MSDS), and document that the food plant has approved those substances and integrated them into a chemical control program. "The auditor is going to look at your pesticide list and the plant's chemical control list and they better find them on both, so make sure those documents are readily available and are consistent," St. Cyr said.

In the case of specific pest sightings and subsequent corrective action, technicians must create documentation that provides a clear, lineal path to demonstrate the logic of their actions. Explain and document: What happened? Why was it a problem? How was it dealt with? When was it done? Who did it? What were the results? What are you doing to prevent recurrence?

"This is where your technicians are going to have to write very clearly and concisely of exactly what transpired during that service. That's going to take more time and you are going to have to negotiate with your customer to account for these new requirements," St Cyr added.
 

Work Drives The Paper. With such a heavy focus placed on documentation, St. Cyr cautioned pest management professionals to ensure their work and their paperwork jibe. "I have repeatedly seen it happen where I can go through a facility and see significant challenges in the plant with their sanitation program, pest management program, maintenance, operational practices, etc., but then they have phenomenal data and records that indicate none of those challenges exist," St. Cyr said.

Clearly, in a food production environment, that disparity could have dangerous consequences. "Don't get caught up in the trap that if the documentation is good, so is the program. Do not let the technicians put their priority on the paperwork to the point that the execution of the job suffers," St. Cyr said.

The good news is that if you are a responsible PCO using sound IPM techniques, the GFSI audits shouldn't fundamentally change your services, they will simply require a layer of documentation you may not be accustomed to. "A lot of this is nothing more than you are already doing, but it is a matter of documenting it and having that document available. Because who gets blamed if that document can't be found? The food plant? No, you," St. Cyr said.

More Resources
To help make more sense of the Global Food Safety Initiative and its audits, check out these web resources:
https://www.aibonline.org/auditservices/GFSI_CertSchemes.html   
https://www.aibonline.org/auditservices/GFSI_FAQ_Aug2010.pdf
http://www.mygfsi.com/
http://www.ciesnet.com/2-wwedo/2.2-programmes/2.2.foodsafety.asp
http://www.foodsafetyintervention.com/gfsi-faqs.html
http://www.us.sgs.com/gfsi_audit_certification_program_retail_food_certification_us

 

The author is a frequent contributor to PCT. He can be reached at ssmith@giemedia.com.