12 replies to this topic

[Caleb51]

We have not had our 3rd party pest control company come to our plant in the last 5 month because of the cost.  Covid has been hurting our business and cash is super tight.  The rodent and fly traps are still in position, but we haven't been able to afford the best control company to come into our plant every 2 weeks like our pest control programs states because of the cost.  Will this be a major or minor?  How should I proceed in that our paperwork shows a gap of several months?  Thanks

[olenazh]

Your could do it yourself, why not? If you haven't had any complaints, deviations, objections, other issues related to pest infestation for that period, just write the reports post factum. Make a Management Meeting minutes or so RE: changing external pest control service to internal due to this and that (detailed explanation of current problems), all signed off properly. 

[Caleb51]

Thanks for the response!  Will it matter if we do it internally since we don't have a "trained" or "certified" pest control person on staff?  Also, will it be bad if we have no data on pest control for the last 4 or so months? We haven't had any issues or any sightings of pests, but I am just wondering if we have no data will this be bad or as long as long as everything is signed off properly, we should be ok? Thanks!

[olenazh]

You could do training papers and pest control records backdating - but you should have some data for that period. Regardless, you didn't have any issues, you should demonstrate your food safety system (including pest hazard) is under control.

[pHruit]

Honestly I'd be somewhat nervous in your position. I do genuinely sympathise with the predicament of financial uncertainty and limited funds given the craziness that this year has thrown at many businesses, but aside from section 4.11, I could see this potentially causing issues in relation to 1.1.4 - providing neither a trained internal person nor a suitable contract service may raise questions about the resource provision requirements of the standard.

As for the in-house approach, this is acceptable but there is a clear obligation for it to be undertaken in accordance with clause 4.11.3 - you need to be able to show that you have "trained and competent staff with sufficient knowledge", and there is also a requirement for resource etc.
If you have very detailed reports from e.g. the last full inspection then you might be able to use that as a guide, but unless you are very competent in this area it will be difficult to really undertake this yourselves to a suitable standard, and I would still be doubtful that it would satisfy the requirements of the section.

 

Perhaps a more sensible compromise might be to make an appointment with the pest management company to restart the service, but to kick off with a review including a reassessment of the visit requirements? If you have a demonstrable history of few/no issues then perhaps such a regular service is not needed, and particularly given that you've posted this in the BRC Packaging forum so the implication is that you're not actually handling food products and thus would be of fairly limited attractiveness to most pests?

I've no idea of the site structure/fabrication/location, but to me a scheduled visit every two weeks sounds like it could be more than is necessary? It's perfectly fine to reduce visit frequency (I've done this at BRC certified sites), but only if you have the data to show it is not putting your facilities/products at risk, and that the conclusion is agreed by someone who can prove that they know what they're looking at.

[Caleb51]

Thank you for your response as well as your suggestion.  I will definitively call up the pest control and do that.  

 

Is it in the BRC standard that it is required to have scheduled pest control visits every 2 weeks?  The facility is only 13,500 square feet. 

[pHruit]

Is it in the BRC standard that it is required to have scheduled pest control visits every 2 weeks?  The facility is only 13,500 square feet.

No, the BRC Standards aren't at all prescriptive in this respect - it is up to individual sites to determine the appropriate frequency, scope etc. for pest control services. You do therefore have quite a lot of potential flexibility, as long as you can justify the conclusion and it demonstrably provides a suitable service. This is why it's generally best to agree the frequency with the pest control provider, as they should be the experts in that area.
I have occasionally come across slightly less scrupulous providers who seem more interested in selling services and add-ons than on actually providing the *right* service - thankfully it seems to be relatively rare, but if your provider is recommending a visit frequency that seems unusually high then you could always speak to another couple of providers to get some quotes and discuss your requirements.

[SQFconsultant]

Interesting responses. You can't back-date and while  you could  undertake yourself the person would need to be licensed, permits, training, etc.

 

Pest control is a absolute essential service, not something that should have been curtailed - that one could have been worked out some way.

 

Obviously you need to have your PCO come in for a overall assessment and while you could try for showing an auditor that and the fact that trends were non-occuring (for instance) before I think this lack of cash for this essential is going to result in a major and even if your audit report comes up passing, your customers are going to want to know what that major was.

[MDaleDDF]

Honestly I'd be somewhat nervous in your position. I do genuinely sympathise with the predicament of financial uncertainty and limited funds given the craziness that this year has thrown at many businesses, but aside from section 4.11, I could see this potentially causing issues in relation to 1.1.4 - providing neither a trained internal person nor a suitable contract service may raise questions about the resource provision requirements of the standard.

As for the in-house approach, this is acceptable but there is a clear obligation for it to be undertaken in accordance with clause 4.11.3 - you need to be able to show that you have "trained and competent staff with sufficient knowledge", and there is also a requirement for resource etc.
If you have very detailed reports from e.g. the last full inspection then you might be able to use that as a guide, but unless you are very competent in this area it will be difficult to really undertake this yourselves to a suitable standard, and I would still be doubtful that it would satisfy the requirements of the section.

 

Perhaps a more sensible compromise might be to make an appointment with the pest management company to restart the service, but to kick off with a review including a reassessment of the visit requirements? If you have a demonstrable history of few/no issues then perhaps such a regular service is not needed, and particularly given that you've posted this in the BRC Packaging forum so the implication is that you're not actually handling food products and thus would be of fairly limited attractiveness to most pests?

I've no idea of the site structure/fabrication/location, but to me a scheduled visit every two weeks sounds like it could be more than is necessary? It's perfectly fine to reduce visit frequency (I've done this at BRC certified sites), but only if you have the data to show it is not putting your facilities/products at risk, and that the conclusion is agreed by someone who can prove that they know what they're looking at.

I agree with this, but I would remove the 'somewhat nervous' and replace it with 'very worried'.  I can't imagine how that could even happen around my facility.   I understand tight pockets due to what's going on, but our pest control isn't hugely expensive, and there's certainly other things that would go first, that's too important. 

[Ted S]

Unfortunately, you need to do something about this deficiency today and move forward accordingly. You cannot back date data. That is unethical and just plain wrong. You will need to be honest with what happened, but also show that you have put corrective action in place moving forward. If money continues to be an issue, you will need to come up with a new game plan. As someone else here mentioned, ask your PCO if they would come in to do an audit (to re-establish a baseline) and have someone accompany them to learn what they do and how they do it. This person would then be responsible for continuing the bi-weekly audits and maintaining the documentation to prove that the audits are occurring. They would only contact the PCO if an issue requiring "treatment" was needed. In the US, you do not need to be licensed to perform the inspections, but you do need licensing/training to apply pest control chemicals, etc.... if situations arise. For factories that I have personally managed, we only brought in the PCO once a month, but did every two week inspections internally to save money. If we found a concern between the PCO visits, we would contact them and ask them to come in. This is considered an acceptable practice in the US. You will be required to prove that your internal person was trained, though. You will then need to update your Pest Control program documentation to reflect this change.

 

A more important concern to me is since you are not doing what your documentation states regarding Pest Control, what else is not being done to save money that does not match what your documentation states?  This non-compliance Pest Control issue will raise concerns with a good auditor, and they will dig even deeper in all other areas as well to identify what else might have been compromised due to the lack of money. Be prepared for this. Also, do an honest assessment to see what other programs might need to be modified due to the current financial situation so that you do not get into trouble in other areas as well. Good luck. 

[zoelawton]

Hi, 

 

I am super sorry for your situation and i can only imagine how people must be feeling who have ended up in this position. 

 

We recently had our BRC audit, and our pest control contractor is not up to scratch. It was 100% mentioned in a negative way that we undertake some form of pest control ourselves without any training, so if you are going to do this yourself i would suggest some form of training. This could be as simple as having the pest control company come out for just one more visit if you can push to that, walk around with them and get them to show you what they do, just make sure you have training document made up and then they can sign to say you've received some basic training and this should be sufficient to cover the foreseeable future. 

 

It is a tricky one - due to covid-10 you could have risk assessed at the beginning to say you are not allowing any contractors on site for the safety of employees etc. For the period now, i'm not sure as i know guidelines have changed etc. 

 

I know this hasn't been much help but i really wish you the best and hope you get this worked out!

[Mulan1010]

So sorry about your situation.  Balancing staying afloat financially and ideally making a profit (the goal to any business) vs. maintaining food safety, personal safety, keeping personnel satisfied enough so they stay and general maintaining of facility and equipment, not to mention making improvements so a company can grow is quite a challenge and can be a moral dilemma.  It is definitely a tough spot to be in.  

 

I would expect a non-compliance for this on your audit but maybe you can lessen the severity. Suggest you

• Fill out a deviation form on the issue to show it is recognized as an issue. 
• Take corrective action immediately, see if you can get the pest control contractor out there by negotiating or maybe check with competitors and look for a lower cost option (depending on your contract with current vendor, if you have one). 
• Complete the investigation of the cause and how you will prevent this lack of pest control prevention in the future.
• Complete a risk assessment and determine the needed frequency but be able to support your decisions.  Maybe you can do monitoring checks in-house to help support a slower frequency of the contractor visits. Consider the seasons. For us, winter is very mild usually non-existent pest activity but summer we get a lot of activity in our outside bait stations and each year it seems a different insect is a challenge so we have to increase frequency during summer and decrease frequency during the winter but never stop the service. 

 

Trying to do pest control in-house is very challenging with the training and maintaining any chemicals (lots of rules depending on the country you live in) but it can be done; just a lot of work and hassle for whoever gets that lovely task

 

Good Luck and hope your company can recover from the slump.

[kingstudruler1]

im pretty sure that the lack of an entire mandatory program is a major.


As others have stated reducing the PCO frequency and internal monitoring is acceptable and may be appropriate. Having no program at
all is not an appropriate response in this situation.



I would:

1. re-read the BRC requirement and audit check list and develop a way to meet as many requirements as possible.

2. come up with a agreement with the pco and ownership on a reduced pco schedule. A facility that size shouldnt be too expensive.
or find another company that will work with you.
I think you need a third party for handling baits & pesticides. Its not worth the headache to do this on your own.

3. Deveolop a schedule for internal inspection and trending or internal devices (traps and ilts) based on risk assessment.

4. develop a simple training for the person(s) monitoring devices.

5. re-write your program to include changes.

6. complete a nonconformance for lack of monitoring for the past months.

7. don't do it again.