Pest Control - Pest Harborage in a staged semi-trailer

I'm wondering if anyone can provide some insight on SQF Pest Control clauses. We are a food packaging manufacturer and I was questioned about if we conduct pest monitoring for a semi-trailer that is staged at one of our docks for loading Gaylord containers of recyclable printed materials. The trailer comes in and gets staged at one of our docks (trailer doors are left open to facilitate staging and loading) and we load the trailer for about a week, then they pick up the full trailer and drop off another empty. I'm being told that we would receive a nonconformity for pest harborage in Module 13, clauses 13.2.9, 13.8.1.3 & 13.9.1.1.

It would be impossible for someone to inspect the 40" trailer that is either 1/4 1/2 or 3/4 loaded

13.2.9 invloves the entire management of pests and vermin (we have an IPM) and 13.2.9.1 speaks of "The premises, its surroundings, storage facilities etc. shall be kept free of waste so as not to attract pests - The trailer is meant for waste, and we inspect and clean the surround area of any waste that may come out of the trailer,


13.8.1.3 speaks to Trolleys, vehicle waste disposal equipment, collection bins and storage area shall be maintained in a serviceable condition and cleaned and sanitized regularly so as not to attract pests and other vermine.- There's no way we can regularly clean and sanitize the trailer - it's being loaded with filll recycle containers


13.9.1.1 speaks to the grounds and area surrounding the premises being free of waste - as mentioned, we regularly clean the grounds and surrounding area.


Other than having tin cat traps and ILT's next to the dock where the trailer is staged, I'm at a loss for a pest monitoring method in the trailer being loaded.

Thanks for any input on this!

This might be one that depends on your auditor but I think your rodent traps and ILTs are your monitors. You could add a visual inspection of the trailer when you spot to be sure you are not bring anything in with it but I don't see why you would need to do more.

This might be one that depends on your auditor but I think your rodent traps and ILTs are your monitors. You could add a visual inspection of the trailer when you spot to be sure you are not bring anything in with it but I don't see why you would need to do more.

Thanks - Thats what I thought also but the auditor wouldn't let go!!! We ended up putting a blurb in the PRP stating that the trailer is inspected for pest evidence such as nest building activities, feces etc each time recycled materials are loaded into it (generally 2-3 times a week) We also put a log by the dock where the staff member filling the trailer initials and dates that the trailer was inspected - really????seems a bit overboard but sometimes you just have to give in and put the argument to bed.

Thanks - Thats what I thought also but the auditor wouldn't let go!!! We ended up putting a blurb in the PRP stating that the trailer is inspected for pest evidence such as nest building activities, feces etc each time recycled materials are loaded into it (generally 2-3 times a week) We also put a log by the dock where the staff member filling the trailer initials and dates that the trailer was inspected - really????seems a bit overboard but sometimes you just have to give in and put the argument to bed.

Hi Tony,

As you are using the trailer as effectively for storage of waste and is connected to your facility I don't think the auditor has been unreasonable.

It seems you have resolved the problem relatively easily so happy days!

Regards,

Tony

First of all while giving a delivery you should clean the container in which you will deliver and ask the driver only to deliver your product and not of others. This will help you from other things touching your product