Non-conformance for SQF 13.2.4.2 Pest contractors and/or internal pest controllers competence

Good morning.

 

Just finished year 3 of our Packaging SQF Audit yesterday with a respectable 92 score. We received a non-conformance for 13.2.4.2 Pest contractors and/or internal pest controllers shall: i. Be licensed and approved by the local relevant authority.

 

For five years we had a licensed Pest Control company monitor and record the 27 traps they have inside out building. For those five years we have purchased, installed and monitored our own external 8 traps (more financially feasible for a small company). These traps were purchased in Canada at Home Depot and use a Bait Block (TomCat mouse Killer bait) inside the trap. Because of larger pest counts on inside devices this fall, the contracted pest control company recommended we add an 6 additional traps outside, these being the same as our previous 8 traps. This years Auditor was the same as last year. This year he cited us because our Maintenance Manager (who is the internal pest controller) is not formally trained as a pest control technician to bait and monitor external traps. 

 

I explained it was on the recommendation of the contracted pest control company we use traps and bait readily available to any consumer at Home Depot, Lowes, etc. I find no reference on the MSDS sheet, nor the front of back label of the bait product that suggests "must be used by a licensed contractor"!

 

Any suggestions on how to proceed with this CAPA?

So you're actually out of compliance re: the wording in the code (but I'm on your side), and that's why you were given a minor

The code does not make an exemption for using residential products vs those that require a pesticide license in your province/territory

 

your only choices are

A) have the PCO bait the exterior stations and you manage all of the rest of the monitoring and purchasing/replacing them

 

 or 

B) have your maintenance manager get their pesticide license.  They renew every two years (at least in Ontario)
 

Pest contractors and/or internal pest controllers shall:
i. Be licensed and approved by the local relevant authority;
ii. Use only trained and qualified operators, who comply with regulatory requirements;
iii. Use only approved chemicals;
iv. Provide a pest prevention plan (refer to 2.3.2.8), which includes a site map, indicating the location of bait stations traps and other applicable pest control/monitoring devices;
v. Report to a responsible authorized person on entering the premises and after the completion of inspections or treatments;
vi. Provide regular inspections for pest activity with appropriate action taken if pests are present, and
vii. Provide a written report of their findings and the inspections and treatments applied.

So if our local relevant authority confirms the bait is a consumer purchasable item and does not fall under any licensing restrictions to use are we still out of compliance?

That is correct. The code is clear on this one, regardless of what your province says.  I wish I had different news for you

So if our local relevant authority confirms the bait is a consumer purchasable item and does not fall under any licensing restrictions to use are we still out of compliance?

Hi queenb,

 

the issue here isn't necessarily about the product being able to be used by anyone, e.g. residential use, it is showing an element of control over devices and pesticides within your setting, like, not just letting any tom dick or harry handle devices and pesticides when you have a duty to provide packaging that complies with x y z 

 

hope this makes sense