Pest Control requirements for bulk processed in sealed bags in cartons

Hello, 

We are preparing for organic certification as a Handler. And our pest control company has indicated that the entire warehouse needs to be sealed and all doors kept closed at all times, and that our racks must be 18" from all walls. Which we are 8" now. 

The organic product is purchased in bulk sealed cartons with product in sealed bags within carton with max wgt of 50 pounds, stored on pallets in segegated bin location. 

We built a "clean room" for the processing of the bulk product into retail containers. The room has sealed doors with  air curtians upon entry. Room is build on 2nd level in warehouse and is climate controlled. The room can only hold about half of the organic bulk product. The balance of the bulk product in sealed bags within cartons is stored in our warehouse in a racking system in segregated "organic" bin locations.

Our pest control company "expert" is recommending that we keep all the doors closed in our warehouse that the bulk organic in cartons in sealed bags be kept closed at all times due to insects. I have read the NOP USDA Facility Pest Control practices and can not find interpretation for this of bulk processed in sealed bags in cartons.  

We are following the multi-level hierarchical approach and need clarification if the bulk in seal bags within corrugated cartons stored in warehouse is the same as raw bulk material storage

Thank you all in advance. 

Hello, 

We are preparing for organic certification as a Handler. And our pest control company has indicated that the entire warehouse needs to be sealed and all doors kept closed at all times, and that our racks must be 18" from all walls. Which we are 8" now. 

The organic product is purchased in bulk sealed cartons with product in sealed bags within carton with max wgt of 50 pounds, stored on pallets in segegated bin location. 

We built a "clean room" for the processing of the bulk product into retail containers. The room has sealed doors with  air curtians upon entry. Room is build on 2nd level in warehouse and is climate controlled. The room can only hold about half of the organic bulk product. The balance of the bulk product in sealed bags within cartons is stored in our warehouse in a racking system in segregated "organic" bin locations.

Our pest control company "expert" is recommending that we keep all the doors closed in our warehouse that the bulk organic in cartons in sealed bags be kept closed at all times due to insects. I have read the NOP USDA Facility Pest Control practices and can not find interpretation for this of bulk processed in sealed bags in cartons.  

We are following the multi-level hierarchical approach and need clarification if the bulk in seal bags within corrugated cartons stored in warehouse is the same as raw bulk material storage

Thank you all in advance. 

Any particular FS Standard Involved ???

Americert Organic Certification. 

We are in process of finalizing of FSMA for FDA and HACCP plans as well. 

You don't have a HACCP plan in place already?

We have a HACCP plan.  We currently have a co-packer who does the organic product packaging into the retail containers. We are a distributor of the finished product currently.  But we want to move into packaging some of our products in-house. Our current plan for pest control is documented and recorded.

Hello, 

We are preparing for organic certification as a Handler. And our pest control company has indicated that the entire warehouse needs to be sealed and all doors kept closed at all times, and that our racks must be 18" from all walls. Which we are 8" now. 

The organic product is purchased in bulk sealed cartons with product in sealed bags within carton with max wgt of 50 pounds, stored on pallets in segegated bin location. 

We built a "clean room" for the processing of the bulk product into retail containers. The room has sealed doors with  air curtians upon entry. Room is build on 2nd level in warehouse and is climate controlled. The room can only hold about half of the organic bulk product. The balance of the bulk product in sealed bags within cartons is stored in our warehouse in a racking system in segregated "organic" bin locations.

Our pest control company "expert" is recommending that we keep all the doors closed in our warehouse that the bulk organic in cartons in sealed bags be kept closed at all times due to insects. I have read the NOP USDA Facility Pest Control practices and can not find interpretation for this of bulk processed in sealed bags in cartons.  

We are following the multi-level hierarchical approach and need clarification if the bulk in seal bags within corrugated cartons stored in warehouse is the same as raw bulk material storage

Thank you all in advance. 

Hi PFC,

Not my area of expertise but I deduce yr query is based on Americert's specific documentation requirements.

Not sure if anyone here is familiar with above so there may be a little delay in responses.

This seems bass-ackwards.  An Integrated Pest Management system does not rely on magically keeping insects out of the food.  Instead, it assumes that they are already present in low numbers within the food.  Your pest control expert may be concerned that 'Organic' means he can't use pesticides, but under any food safety scheme you are not supposed to use pesticides or even baited traps indoors.  In your situation I would work out my own IPM plan, starting with identifying which pest species I need to worry about.  While I was working on that plan, I would install pheromone traps for 'pantry pests' which is available for $14 for a pac of 6 on Amazon.  It attracts 6 common food pest species.  I would then check these every few days, then at least monthly.