The FSMA Requirement (21 CFR ยง117.35(c)): The plant must be constructed and maintained to prevent pests from entering. The effective use of pesticides is permitted, but they must be applied to prevent the contamination of food, food-contact surfaces, and packaging.
Recommended Solution & Expert-Level Pitfall:
- The Solution: Your pest control program must be an Integrated Pest Management (IPM) program. This means focusing on prevention first:
- Exclusion: Sealing doors, screening windows, and repairing structural defects.
- Harborage Reduction: Eliminating clutter, managing waste, and cutting vegetation away from the building.
- Monitoring: Using a robust, mapped network of traps (e.g., mechanical traps inside, bait stations on the exterior perimeter) checked and trended by a qualified person.
- The Pitfall to Avoid: Only “checking the traps.” A binder full of trap logs is useless if the data isn’t analyzed. An expert program trends this data to identify activity before it becomes an infestation. A critical failure is poor communication between your pest control operator (PCO) and your internal team. Your PCO’s service report is a sanitation corrective action log, not just an invoice.